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Department of
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117'1 Environmental Quality
L. Scott Baird
State of Utah Executive Director
DIVISION OF WASTE MANAGEMENT
GARY R. HERBERT AND RADIATION CONTROL
Governor Ty L. Howard
Director
SPENCER J. COX
Lieutenant Governor
November 19, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection:
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
On November 16 and 17, 2020, an inspection was conducted at your facility by Ryan Johnson, a
representative of the Division of Waste Management and Radiation Control (DWMRC). Observations
from the inspection were discussed at the closeout meeting with White Mesa Uranium Mill staff. The
inspection was an examination of the activities conducted at your facility as they relate to compliance
with the Utah Radiation Control Rules, the license conditions of the RML No. UT 1900479, and Federal
Regulations. The inspection consisted of an examination of representative records, interviews of
personnel, and observations by the inspector.
The DWMRC considers this inspection closed. The DWMRC would like to thank the Mill staff for their
cooperation regarding this inspection.
If you have any questions concerning this letter, please contact Ryan Johnson by email at
[e-mail] or by phone at [phone].
Phfl Goble, Uranium Mills and Radioactive Materials Manager
Division of Waste Management and Radiation Control
(Over)
DRC-2020-018762 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]
urcuw.deq.utah.gov
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INSPECTION REPORT 77-2020 00Z3
Inspection Module: RADMOD-ALARA
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: 2019 Annual ALARA Report, Daily and Weekly Inspections and Monthly Reports
Inspection Dates: November 16 & 17, 2020
Inspector(s): Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted:
Terry Slade, Energy Fuels Resources Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479, License Condition 11.6
• Nuclear Regulatory Commission (NRC) Regulatory Guide 8.31
Onenin2 Meeting
Energy Fuels Resources:
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The Mill staff reminded the inspectors of the safety requirements for the Mill. The
Mill is currently conducting pilot tests on monazite ore for uranium and rare earth mineral recovery.
Inspection Summary
Item 1. Document Review- License Condition 11.6 of the Mill's RML requires the Mill to perform an
annual ALARA audit of the radiation safety program as per NRC Regulatory Guide 8.31. The 2019
ALARA Audit did not take place in April of 2020 due to the COVID-19 pandemic. Therefore the audit was
done remotely and at a later date in the year. The ALARA Report for 2019 was not available for review at
the time of the inspection and will have to be reviewed during an inspection in the 1st quarter of 2021. The
ALARA report is not required to be submitted to the DWMRC, therefore, it is only available to review by
DWMRC Staff at the Mill during onsite inspections.
Observations: The DWMRC inspector observed:
Daily and Weekly Inspections and Monthly Reports
• Several different people do daily inspection specific to their job function;
o Occupational Safety Staff Daily inspections documents housekeeping issues and postings
around the Mill;
o Operating Forman's Daily inspection documents maintenance issues and, if observed. any
radiation issues;
• The daily inspection forms are clear, concise and legible;
• The Inspector spot checked the daily inspection forms. Of the inspection forms reviewed by the
Inspector, no non-compliance issues were identified;
• The weekly inspections are done by the RSO (or designee) and someone from operations;
• The weekly inspection forms are clear, concise and legible;
• Weekly inspection forms mainly document housekeeping and maintenance issues around the Mill
and the inspection forms have initials and check marks next to the items identified indicating that
the issue had been taken care of
• The Inspector spot checked the weekly inspection forms. Of the inspection forms reviewed by the
Inspector, no non-compljance issues were identified; and
• The Monthly reports adequately summarize the information from the daily and weekly inspections.
Deficiencies: None
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad and the mill.
Observations: The DWMRC inspector also observed:
• Alternate feed being stockpiled on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE.
Radiolo ical readin s observed during Mill tour
Location Dose Rate (1.11t/hr)
Yellowcake Storage Yard 70
Ore Pad 200-1,000
Alternate Feed Circuit 150
During the Mill Tour the Inspector was able to confirm that the Posting of Notices to Workers as required
by R313-18-11 are on the bulletin board in the break room of the administration building. This included:
2 of Page 3
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Inspection Reports \Inspection Report RADMOD-ALARA 11 -18-2020.docx
Findings
None
Recommendations
None
Recommendation for Next Inspection
None
Prepared By:
• The DWMRC-04 form: and
• A memo indicating where the following documents can be found:
o State of Utah rules R313-15 and R313-18;
o Copies of EFRI' s current radioactive material license; and
o EFRI operating procedures; and
o Notices of Violation issued by DWMRC to EFRI.
Deficiencies: The Notice of Violation that was issued in October of 2020 was not in the bulletin board
when the inspection began. However, the Inspector discussed the requirement with the RSO and Radiation
Safety Staff and the NOV was posted before the inspection was completed.
Item 2. Follow-up Item:
During the Inspection conducted in October of 2020, a deficiency was identified an NOV was issued by the
Division for not documenting radiological release surveys. During this inspection, the Inspector reviewed
the radiological release surveys since the last inspection and confirmed that the corrective actions taken by
the Mill have been implemented and surveys had been properly documented.
Deficiencies: There were blank survey sheets because no surveys were conducted on the day documented
on the form. The RSO explained that there were no truck release surveys conducted on those days. The
inspector recommended to the RSO to write on the blank forms that no trucks were surveyed to explain why
the form was blank.
Closeout Meeting
Energy Fuels:
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
/M-2020
(Date)
Reviewed By: Phil Goble 104 2 020
(Print Name) (Signature) (Date
3 of Page 3
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Inspection Reports\Inspection Report RADMOD-ALARA 11-18-2020.docx
-• 1,96 •
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
FILE COPY
November 19, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
Thank you for Energy Fuels Resources (USA) Inc.'s letter dated November 12, 2020, informing us of
the steps taken to rectify the violations identified in a Notice of Violation dated October 14, 2020. We
have no further questions at this time and we will review Energy Fuels Resources (USA) Inc.'s
corrective actions during a future inspection.
Please note that corrective actions Energy Fuels Resources (USA) Inc. takes to avoid further items of
noncompliance are expected to be effective and lasting. Your cooperation is appreciated.
If you have any questions, please call Ryan Johnson at [phone].
Sincerely,
Ty L. oward, Direc
Divis on of Waste Management and Radiation Control
TLHIRMJ/as
DRC-2020-018682 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
ENERGY FUELS
DN of Waste Mannqement
and Radiation Control
November 12, 2020
NOV 1 6 2020
Sent VIA OVERNIGHT DELIVERY
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Re: Compliance Evaluation; Notice of Violation: Radioactive Materials License Number
UT1900479
Dear Mr. Howard:
This letter responds to the Notice of Violation ("NOV"), received by Energy Fuels Resources (USA) Inc.
("EFRI") on October 20, 2020, which lists a violation of the Utah Radiation Control Rules based on an
inspection of the White Mesa Mill (the "Mill") conducted by representatives of the Division of Waste
Management and Radiation Control ("DWMRC") on October 5 - 6, 2020.
The NOV requires EFRI to provide a written response within 30 days after receipt of the Notice,
including:
• The corrective actions which have been taken and the results achieved;
• The corrective steps which have been taken to prevent recurrence; and
• The date full compliance will be achieved.
The specific violation listed in the NOV and EFRI' s response is discussed below.
Violation
An inspection of the licensee's activities was conducted on October 5 & 6, 2020. As a result of the
inspection, a violation of the Utah Administrative Code (Radiation Control Rules) was identified. The
particular violation is set forth below:
R313-1 5-501 (1 )(b) states in part "Each licensee or registrant shall make, or
cause to be made, surveys of areas, ... Are reasonable under the circumstances to
evaluate: The magnitude and the extent of radiation levels; and
R313-15-1103 states in part "Each licensee or registrant shall maintain records
showing the results of surveys ... "
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
D R C- Zoo ZO - 0 I S 6 0 2_ www.energyfuels.com
Letter to Mr. Ty L. Howard
November 1 2, 2020
Page 2
Contrary to this requirement, Radiation Safety Technicians (RSTs) at the Mill have
been performing radiological surveys of vehicles being released from the restricted
area; however, not all of the RSTs have been documenting the results of the
radiological surveys on the Licensee's "Daily Vehicle Scan for Vehicles Leaving
the Restricted Area" survey sheets. The inspector documented that on September
15, 2020 at the West Gate vehicle number C0158CVQ a radiological survey was
performed to release the vehicle from the restricted area but the results were not
documented. Upon further investigation of the records review, additional surveys
from 2020's "Daily Vehicle Scan for Vehicles Leaving the Restricted Area" survey
sheets were found that were missing survey results.
This violation has been characterized as Severity Level IV. The base penalty for
this Severity Level is $1,500.00. However, there is no civil penalty assessed for this
violation because this is the first instance this violation has been documented.
EFRI Response
This is a case of improper training of our RSTs. The requirement to record all scans out of the
restricted area regardless of the perceived absence of risk, is so basic, that the failure of the Mill' s RSTs
to understand this requirement falls on improper training of the RSTs. Secondarily, the RSO and
Assistant RSO failed to have in place systems to periodically review scan sheets to ensure that they
have been properly completed. The requirement to ensure that no person or object leaves the restricted
area at any time without having been properly scanned is so fundamental to the Mill's license and
regulatory requirements that proper reviews of these activities is an important element of the Mill's
radiation safety program.
The Daily Vehicle Scan for Vehicles Leaving the Restricted Area forms are used to document scans of
non-haulage vehicles exiting the restricted area through the west gate. Non-haulage vehicles include,
but are not limited to, Personally Owned Vehicles ("POVs"), United Parcel Service ("UPS") trucks,
Fed Ex trucks, delivery vehicles (auto parts, tires, hardware etc.) and contractor vehicles (repair
personnel, sampling personnel, etc.). While onsite at the Mill, these vehicles travel using clean gravel
throughways and, while in the restricted area, do not travel in or to areas of potential contamination or
exposure prior to leaving through the west gate. In contrast, any vehicle traveling to areas of potential
exposure or contamination are released through the east gate after decontamination in one of the
decontamination pads. All haul trucks used for the delivery of Mill feed are required to exit the facility
through the east gate after the completion of the decontamination/scan procedures. There is very little
potential for any of the vehicles for which the scans were not documented to exceed the free release
criteria specified in the Mill's Standard Operating Procedures ("SOPs") or the required regulations.
Further, it is important to note that while the successful scans were not documented, in the unlikely
event that a failed scan occurred, immediate response actions would have been implemented, including
routing the vehicle to the decontamination pad and re-scanning after the decontamination process. The
response actions would be completed and documented prior to release.
Nevertheless, despite there being very little possibility for vehicles to be inappropriately released, EFRI
considers the missed documentation significant, particularly given the failure of the Mill' s RSTs to
understand the importance of documenting all scans out of the restricted area, regardless of the
perceived lack of risk of radiation contamination. Immediately following the DWMRC inspection on
October 5 - 6, 2020, the Mill implemented corrective actions to address the lack of proper training, the
Letter to Mr. Ty L. Howard
November 12, 2020
Page 3
missing documentation and the lack of supervisory reviews of scanning-out documentation.
Specifically, the Mill:
a. Completed re-training on October 6, 2020, (see Attachment A),
b. Changed the order of operations for vehicle scans as described below, and
c. Now collects and reviews the scan forms daily to verify documentation is complete.
Root Cause of Noncompliance
The Mill's Radiation Safety Officer ("RSO") reviewed the process for non-haulage vehicle releases in
place at the time of the NOV, and noted that the RST on duty is responsible for recording the vehicle
license number and state, and company name on the departing vehicle on the form in the gate house.
Upon recording the information, the RST would leave the gate house and complete the survey, as
required. The RST was then required to return to the gate house and document the scan results. The
missing documentation of scans occurred when the RST failed to return to the gate house to record the
scan results; the completion of the first two steps is not in question.
The root cause of this noncompliance is improper training of the Mill's RSTs. The RSTs should have
known better than to believe that a requirement to scan out of the Mill's restricted area would not need
to be properly recorded. Secondarily, the RSO and Assistant RSO failed to have in place systems to
periodically review scan sheets to ensure that they have been properly completed. This is considered
secondary, because it should go without saying that every scan out of the Mill's restricted area needs to
be properly recorded. The fact that the delivery trucks in question had very little risk of leaving the
Mill's restricted area without meeting the free release criteria specified in the Mill's SOPs or the
required regulations, is irrelevant. The fact that the Mill's RSTs failed to understand this and that there
were inadequate supervisory reviews is relevant.
Corrective Actions Which Have Been Taken and the Results Achieved
The steps for non-haulage vehicle release have been reordered to address the inadvertent failure to
completely document release scans. The previous steps in the process are described above. The
reordered process is as follows:
1. Scan the vehicle as described in the Radiation Protection Manual, Section 6.
2. Enter the gate house, pick up the clipboard with the correct forms. Record the scan results,
vehicle license number and state, and company.
The new procedure has resulted in no incidents of missed documentation since re-training was
completed on October 6, 2020.
Corrective Steps Which Have Been Taken to Prevent Recurrence
The Mill has changed its RST training program to place more emphasis on the fundamental need to
record the results of all scans and measurements, regardless of the perceived risk of the activity being
scanned or measured. The Radiation Protection Manual ("RPM") has been revised (Section 7 of the
RPM) to include a training for documentation completion. Section 7 of the RPM is included as
Attachment B to this response. In addition, the Mill has added the following procedure to further
prevent a recurrence of this particular violation. Each morning the RSO or his designee collects the
previous day's scan documents from the gate house. The scan documents are reviewed for
Letter to Mr. Ty L. Howard
November 12, 2020
Page 4
completeness. If any incomplete records are discovered the Mill personnel who did not complete the
records will be contacted immediately for re-training, or other personnel disciplinary action as required.
Date Full Compliance Will Be Achieved.
Compliance was achieved on October 6, 2020. There have been no incidents of incomplete
documentation since that date.
If you should have any questions regarding this report please contact me.
Yours very tpily,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: Scott Bakken
Dave Frydenlund
Julia Hoffmeier
Garrin Palmer
Logan Shumway
Terry Slade
ATTACHMENT A
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Training Attendance Record
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Time ende4 ID: 55 Total Time JP_Iijd j.
Full Name Job Classification

ATTACHMENT B
REDLINE
White Mesa Mill — Standard Operating Procedures
SOP PBL-RP-7
Book 9: Radiation Protection Manual, Section 7
Date: 11/10/2020 Revision: EFR 01
Page 1 of 1
1.0 TRAINING AND DOCUMENTATION
The radiation protection program at the Mill consists of several layers of controls to ensure conditions are
maintained As Low As Reasonably Achievable ("ALARA") and to achieve corporate and regulatory
agency compliance. The radiation protection program is documented in this Radiation Protection Manual
("RPM").
Radiation Safety Technicians ("RSTs") receive training to complete the monitoring activities in this
manual. The training consists of a combination of procedural review as well as hands on training with
meters and instrumentation associated with Sections 1 through 6 of this RPM. In addition to technical
training, RSTs receive training on the documentation of radiation protection program activities. The
documentation training applies to all activities contained in this RPM and is detailed below.
1.1 DOCUMENTATION
The importance of documenting accurately and clearly cannot be over emphasized. The documentation of
results from scans and procedures completed by the RST, and the review of such is fundamental to EFRI' s
license and regulatory requirements.
1.2 GUIDELINES FOR DOCUMENTATION
The first step in establishing accurate information is ensurin_g_that all information pertaining to a procedure
or scan is collected and accurately recorded. EFRI has established SOPs to maintain compliance to
regulatory requirements. Attached to the SOP are forms to help in gathering all information needed to fulfill
the requirements. The RST is required to make sure the form being used is the most current revision in the
SOP. Notify the RSO if the most current version is not being used and discard all versions of old form
when an SOP is updated.
After it has been verified that the correct form is being used for a survey, the RST will complete the survey
and document the findings on the form. All spaces on the form should be completed. If there is no
information for a space enter either a dash, NA, or some indication why the space was left blank. Double
check your work. The procedure or scan is not complete until all information is recorded.
RPM forms are collected and reviewed by a designated RST on a set frequency. During the reviews the
forms are checked for completeness, clarity, and accuracy. The RST picking the forms up checks them and
then initials the form after the review. The RST initial indicates that the form is complete. If the RST finds
incomplete forms the issue is forwarded to the RSO or designee for resolution.
In addition to the RST reviews, the RSO or designee reviews the forms for completeness and accuracy on
a monthly basis.
1.3 RSO REVIEWS
From observation, most errors occur when the RSTs are split between several tasks that occur
simultaneously. It is important that the RSO routinely observes the RST during surveys to ensure the SOPs
are being followed accurately and to give suggestions for improvements on the scanning process. Annual
observations by the RSO of the RSTs performing the tasks in the RPM, are also required. More frequent
observations may be performed if needed as indicated by the above referenced documentation reviews.
CLEAN
White Mesa Mill — Standard Operating Procedures Date: 11/10/2020 Revision: EFR 01 SOP PBL-RP-7
Book 9: Radiation Protection Manual, Section 7 Page 1 of 1
1.0 TRAINING AND DOCUMENTATION
The radiation protection program at the Mill consists of several layers of controls to ensure conditions are
maintained As Low As Reasonably Achievable ("ALARA") and to achieve corporate and regulatory
agency compliance. The radiation protection program is documented in this Radiation Protection Manual ("Rpm").
Radiation Safety Technicians ("RSTs") receive training to complete the monitoring activities in this
manual. The training consists of a combination of procedural review as well as hands on training with
meters and instrumentation associated with Sections 1 through 6 of this RPM. In addition to technical
training, RSTs receive training on the documentation of radiation protection program activities. The
documentation training applies to all activities contained in this RPM and is detailed below.
1.1 DOCUMENTATION
The importance of documenting accurately and clearly cannot be over emphasized. The documentation of
results from scans and procedures completed by the RST, and the review of such is fundamental to EFRI' s
license and regulatory requirements.
1.2 GUIDELINES FOR DOCUMENTATION
The first step in establishing accurate information is ensuring that all information pertaining to a procedure
or scan is collected and accurately recorded. EFRI has established SOPs to maintain compliance to
regulatory requirements. Attached to the SOP are forms to help in gathering all information needed to fulfill
the requirements. The RST is required to make sure the form being used is the most current revision in the
SOP. Notify the RSO if the most current version is not being used and discard all versions of old form
when an SOP is updated.
After it has been verified that the correct form is being used for a survey, the RST will complete the survey
and document the findings on the form. All spaces on the form should be completed. If there is no
information for a space enter either a dash, NA, or some indication why the space was left blank. Double
check your work. The procedure or scan is not complete until all information is recorded.
RPM forms are collected and reviewed by a designated RST on a set frequency. During the reviews the
forms are checked for completeness, clarity, and accuracy. The RST picking the forms up checks them and
then initials the form after the review. The RST initial indicates that the form is complete. If the RST finds
incomplete forms the issue is forwarded to the RSO or designee for resolution.
In addition to the RST reviews, the RSO or designee reviews the forms for completeness and accuracy on
a monthly basis.
1.3 RSO REVIEWS
From observation, most errors occur when the RSTs are split between several tasks that occur
simultaneously. It is important that the RSO routinely observes the RST during surveys to ensure the SOPs
are being followed accurately and to give suggestions for improvements on the scanning process. Annual
observations by the RSO of the RSTs performing the tasks in the RPM, are also required. More frequent
observations may be performed if needed as indicated by the above referenced documentation reviews.
ENERGY FUELS
COP Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com DRC- 2oZo - 010602._
Div of Waste Management
and Radiation Control November 12, 2020
NOV 1 6 2020
Sent VIA OVERNIGHT DELIVERY
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Re: Compliance Evaluation; Notice of Violation: Radioactive Materials License Number
UT1900479
Dear Mr. Howard:
This letter responds to the Notice of Violation ("NOV"), received by Energy Fuels Resources (USA) Inc.
("EFRI") on October 20, 2020, which lists a violation of the Utah Radiation Control Rules based on an
inspection of the White Mesa Mill (the "Mill") conducted by representatives of the Division of Waste
Management and Radiation Control ("DWMRC") on October 5 - 6, 2020.
The NOV requires EFRI to provide a written response within 30 days after receipt of the Notice,
including:
• The corrective actions which have been taken and the results achieved;
• The corrective steps which have been taken to prevent recurrence; and
• The date full compliance will be achieved.
The specific violation listed in the NOV and EFRI' s response is discussed below.
Violation
An inspection of the licensee's activities was conducted on October 5 & 6, 2020. As a result of the
inspection, a violation of the Utah Administrative Code (Radiation Control Rules) was identified. The
particular violation is set forth below:
R313-1 5-501 (1 )(b) states in part "Each licensee or registrant shall make, or
cause to be made, surveys of areas, ... Are reasonable under the circumstances to
evaluate: The magnitude and the extent of radiation levels; and
R313-15-1103 states in part "Each licensee or registrant shall maintain records
showing the results of surveys ... "
Letter to Mr. Ty L. How.
November 1 2, 2020
Page 2
Contrary to this requirement, Radiation Safety Technicians (RSTs) at the Mill have
been performing radiological surveys of vehicles being released from the restricted
area; however, not all of the RSTs have been documenting the results of the
radiological surveys on the Licensee's "Daily Vehicle Scan for Vehicles Leaving
the Restricted Area" survey sheets. The inspector documented that on September
15, 2020 at the West Gate vehicle number C0158CVQ a radiological survey was
petformed to release the vehicle from the restricted area but the results were not
documented. Upon fttrther investigation of the records review, additional surveys
from 2020's "Daily Vehicle Scan for Vehicles Leaving the Restricted Area" survey
sheets were found that were missing survey results.
This violation has been characterized as Severity Level IV. The base penalty for
this Severity Level is $1,500.00. However, there is no civil penalty assessed for this
violation because this is the first instance this violation has been documented.
EFRI Response
This is a case of improper training of our RSTs. The requirement to record all scans out of the
restricted area regardless of the perceived absence of risk, is so basic, that the failure of the Mill' s RSTs
to understand this requirement falls on improper training of the RSTs. Secondarily, the RSO and
Assistant RSO failed to have in place systems to periodically review scan sheets to ensure that they
have been properly completed. The requirement to ensure that no person or object leaves the restricted
area at any time without having been properly scanned is so fundamental to the Mill' s license and
regulatory requirements that proper reviews of these activities is an important element of the Mill's
radiation safety program.
The Daily Vehicle Scan for Vehicles Leaving the Restricted Area forms are used to document scans of
non-haulage vehicles exiting the restricted area through the west gate. Non-haulage vehicles include,
but are not limited to, Personally Owned Vehicles ("POVs"), United Parcel Service ("UPS") trucks,
Fed Ex trucks, delivery vehicles (auto parts, tires, hardware etc.) and contractor vehicles (repair
personnel, sampling personnel, etc.). While onsite at the Mill, these vehicles travel using clean gravel
throughways and, while in the restricted area, do not travel in or to areas of potential contamination or
exposure prior to leaving through the west gate. In contrast, any vehicle traveling to areas of potential
exposure or contamination are released through the east gate after decontamination in one of the
decontamination pads. All haul trucks used for the delivery of Mill feed are required to exit the facility
through the east gate after the completion of the decontamination/scan procedures. There is very little
potential for any of the vehicles for which the scans were not documented to exceed the free release
criteria specified in the Mill's Standard Operating Procedures ("SOPs") or the required regulations.
Further, it is important to note that while the successful scans were not documented, in the unlikely
event that a failed scan occurred, immediate response actions would have been implemented, including
routing the vehicle to the decontamination pad and re-scanning after the decontamination process. The
response actions would be completed and documented prior to release.
Nevertheless, despite there being very little possibility for vehicles to be inappropriately released, EFRI
considers the missed documentation significant, particularly given the failure of the Mill' s RSTs to
understand the importance of documenting all scans out of the restricted area, regardless of the
perceived lack of risk of radiation contamination. Immediately following the DWMRC inspection on
October 5 - 6, 2020, the Mill implemented corrective actions to address the lack of proper training, the
Letter to Mr. Ty L. How.
November 12, 2020
Page 3
missing documentation and the lack of supervisory reviews of scanning-out documentation.
Specifically, the Mill:
a. Completed re-training on October 6, 2020, (see Attachment A),
b. Changed the order of operations for vehicle scans as described below, and
c. Now collects and reviews the scan forms daily to verify documentation is complete.
Root Cause of Noncompliance
The Mill's Radiation Safety Officer ("RSO") reviewed the process for non-haulage vehicle releases in
place at the time of the NOV, and noted that the RST on duty is responsible for recording the vehicle
license number and state, and company name on the departing vehicle on the form in the gate house.
Upon recording the information, the RST would leave the gate house and complete the survey, as
required. The RST was then required to return to the gate house and document the scan results. The
missing documentation of scans occurred when the RST failed to return to the gate house to record the
scan results; the completion of the first two steps is not in question.
The root cause of this noncompliance is improper training of the Mill's RSTs. The RSTs should have
known better than to believe that a requirement to scan out of the Mill's restricted area would not need
to be properly recorded. Secondarily, the RSO and Assistant RSO failed to have in place systems to
periodically review scan sheets to ensure that they have been properly completed. This is considered
secondary, because it should go without saying that every scan out of the Mill's restricted area needs to
be properly recorded. The fact that the delivery trucks in question had very little risk of leaving the
Mill's restricted area without meeting the free release criteria specified in the Mill's SOPs or the
required regulations, is irrelevant. The fact that the Mill's RSTs failed to understand this and that there
were inadequate supervisory reviews is relevant.
Corrective Actions Which Have Been Taken and the Results Achieved
The steps for non-haulage vehicle release have been reordered to address the inadvertent failure to
completely document release scans. The previous steps in the process are described above. The
reordered process is as follows:
1. Scan the vehicle as described in the Radiation Protection Manual, Section 6.
2. Enter the gate house, pick up the clipboard with the correct forms. Record the scan results,
vehicle license number and state, and company.
The new procedure has resulted in no incidents of missed documentation since re-training was
completed on October 6, 2020.
Corrective Steps Which Have Been Taken to Prevent Recurrence
The Mill has changed its RST training program to place more emphasis on the fundamental need to
record the results of all scans and measurements, regardless of the perceived risk of the activity being
scanned or measured. The Radiation Protection Manual ("RPM") has been revised (Section 7 of the
RPM) to include a training for documentation completion. Section 7 of the RPM is included as
Attachment B to this response. In addition, the Mill has added the following procedure to further
prevent a recurrence of this particular violation. Each morning the RSO or his designee collects the
previous day's scan documents from the gate house. The scan documents are reviewed for
. Letter to Mr. Ty L. How.
November 12, 2020
Page 4
completeness. If any incomplete records are discovered the Mill personnel who did not complete the
records will be contacted immediately for re-training, or other personnel disciplinary action as required.
Date Full Compliance Will Be Achieved.
Compliance was achieved on October 6, 2020. There have been no incidents of incomplete
documentation since that date.
If you should have any questions regarding this report please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: Scott Bakken
Dave Frydenlund
Julia Hoffmeier
Garrin Palmer
Logan Shumway
Terry Slade
ATTACHMENT A
Date ID - ke — ZO
Time started to ; 45 Anit
Training Attendance Record
.7— Instructor I er 7 51004ed

Time ended I 1:>: 55 Total Time it, AL HA, c.

Subject

ATTACHMENT B
REDLINE
White Mesa Mill — Standar perating Procedures
SOP PBL-RP-7
Book 9: Radiation Protection Manual, Section 7
41110Date: 11/10/2020 Revision: EFR 01
Page 1 of 1
1.0 TRAINING AND DOCUMENTATION
The radiation protection program at the Mill consists of several layers of controls to ensure conditions are
maintained As Low As Reasonably Achievable ("ALARA") and to achieve corporate and regulatory
agency compliance. The radiation protection program is documented in this Radiation Protection Manual ("Rpm").
Radiation Safety Technicians ("RSTs") receive training to complete the monitoring activities in this
manual. The training consists of a combination of procedural review as well as hands on training with
meters and instrumentation associated with Sections 1 through 6 of this RPM. In addition to technical
training, RSTs receive training on the documentation of radiation protection program activities. The
documentation training applies to all activities contained in this RPM and is detailed below.
1.1 DOCUMENTATION
The importance of documenting accurately and clearly cannot be over emphasized. The documentation of
results from scans and procedures completed by the RST, and the review of such is fundamental to EFRI' s
license and regulatory requirements.
1.2 GUIDELINES FOR DOCUMENTATION
The first step in establishing accurate information is ensuring that all information pertaining to a procedure
or scan is collected and accurately recorded. EFRI has established SOPs to maintain compliance to
regulatory requirements. Attached to the SOP are forms to help in gathering all information needed to fulfill
the requirements. The RST is required to make sure the form being used is the most current revision in the
SOP. Notify the RSO if the most current version is not being used and discard all versions of old form
when an SOP is updated.
After it has been verified that the correct form is being used for a survey, the RST will complete the survey
and document the findings on the form. All spaces on the form should be completed. If there is no
information for a space enter either a dash, NA, or some indication why the space was left blank. Double
check your work. The procedure or scan is not complete until all information is recorded.
RPM forms are collected and reviewed by a designated RST on a set frequency. During the reviews the
forms are checked for completeness, clarity, and accuracy. The RST picking the forms up checks them and
then initials the form after the review. The RST initial indicates that the form is complete. If the RST finds
incomplete forms the issue is forwarded to the RSO or designee for resolution.
In addition to the RST reviews, the RSO or designee reviews the forms for completeness and accuracy on
a monthly basis.
1.3 RSO REVIEWS
From observation, most errors occur when the RSTs are split between several tasks that occur
simultaneously. It is important that the RSO routinely observes the RST during surveys to ensure the SOPs
are being followed accurately and to give suggestions for improvements on the scanning process. Annual
observations by the RSO of the RSTs performing the tasks in the RPM, are also required. More frequent
observations may be performed if needed as indicated by the above referenced docurnentation reviews.

0 White Mesa Mill — Standar perating Procedures
SOP PBL-RP-7
Book 9: Radiation Protection Manual, Section 7
41110Date: 11/10/2020 Revision: EFR 01
Page 1 of 1
• •

1.0 TRAINING AND DOCUMENTATION
The radiation protection program at the Mill consists of several layers of controls to ensure conditions are
maintained As Low As Reasonably Achievable ("ALARA") and to achieve corporate and regulatory
agency compliance. The radiation protection program is documented in this Radiation Protection Manual ("Rpm").
Radiation Safety Technicians ("RSTs") receive training to complete the monitoring activities in this
manual. The training consists of a combination of procedural review as well as hands on training with
meters and instrumentation associated with Sections 1 through 6 of this RPM. In addition to technical
training, RSTs receive training on the documentation of radiation protection program activities. The
documentation training applies to all activities contained in this RPM and is detailed below.

1.1 DOCUMENTATION
The importance of documenting accurately and clearly cannot be over emphasized. The documentation of
results from scans and procedures completed by the RST, and the review of such is fundamental to EFRI' s
license and regulatory requirements.

1.2 GUIDELINES FOR DOCUMENTATION
The first step in establishing accurate information is ensuring that all information pertaining to a procedure
or scan is collected and accurately recorded. EFRI has established SOPs to maintain compliance to
regulatory requirements. Attached to the SOP are forms to help in gathering all information needed to fulfill
the requirements. The RST is required to make sure the form being used is the most current revision in the
SOP. Notify the RSO if the most current version is not being used and discard all versions of old form
when an SOP is updated.
After it has been verified that the correct form is being used for a survey, the RST will complete the survey
and document the findings on the form. All spaces on the form should be completed. If there is no
information for a space enter either a dash, NA, or some indication why the space was left blank. Double
check your work. The procedure or scan is not complete until all information is recorded.
RPM forms are collected and reviewed by a designated RST on a set frequency. During the reviews the
forms are checked for completeness, clarity, and accuracy. The RST picking the forms up checks them and
then initials the form after the review. The RST initial indicates that the form is complete. If the RST finds
incomplete forms the issue is forwarded to the RSO or designee for resolution.
In addition to the RST reviews, the RSO or designee reviews the forms for completeness and accuracy on
a monthly basis.
1.3 RSO REVIEWS
From observation, most errors occur when the RSTs are split between several tasks that occur
simultaneously. It is important that the RSO routinely observes the RST during surveys to ensure the SOPs
are being followed accurately and to give suggestions for improvements on the scanning process. Annual
observations by the RSO of the RSTs performing the tasks in the RPM, are also required. More frequent
observations may be performed if needed as indicated by the above referenced documentation reviews.
0 0 White Mesa Mill — StandarOperating Procedures
4111Date: 11/10/2020 Revision: EFR 01 SOP PBL-RP-7
Book 9: Radiation Protection Manual, Section 7 Page 1 of 1
1.0 TRAINING AND DOCUMENTATION
The radiation protection program at the Mill consists of several layers of controls to ensure conditions are
maintained As Low As Reasonably Achievable ("ALARA") and to achieve corporate and regulatory
agency compliance. The radiation protection program is documented in this Radiation Protection Manual
('''ZI:11/19').
Radiation Safety Technicians ("RSTs") receive training to complete the monitoring activities in this
manual. The training consists of a combination of procedural review as well as hands on training with
meters and instrumentation associated with Sections 1 through 6 of this RPM. In addition to technical
training, RSTs receive training on the documentation of radiation protection program activities. The
documentation training applies to all activities contained in this RPM and is detailed below.
1.1 DOCUMENTATION
The importance of documenting accurately and clearly cannot be over emphasized. The documentation of
results from scans and procedures completed by the RST, and the review of such is fundamental to EFRI' s
license and regulatory requirements.
1.2 GUIDELINES FOR DOCUMENTATION
The first step in establishing accurate information is ensuring that all information pertaining to a procedure
or scan is collected and accurately recorded. EFRI has established SOPs to maintain compliance to
regulatory requirements. Attached to the SOP are forms to help in gathering all information needed to fulfill
the requirements. The RST is required to make sure the form being used is the most current revision in the
SOP. Notify the RSO if the most current version is not being used and discard all versions of old form
when an SOP is updated.
After it has been verified that the correct form is being used for a survey, the RST will complete the survey
and document the findings on the form. All spaces on the form should be completed. If there is no
information for a space enter either a dash, NA, or some indication why the space was left blank. Double
check your work. The procedure or scan is not complete until all information is recorded.
RPM forms are collected and reviewed by a designated RST on a set frequency. During the reviews the
forms are checked for completeness, clarity, and accuracy. The RST picking the forms up checks them and
then initials the form after the review. The RST initial indicates that the form is complete. If the RST finds
incomplete forms the issue is forwarded to the RSO or designee for resolution.
In addition to the RST reviews, the RSO or designee reviews the forms for completeness and accuracy on
a monthly basis.
1.3 RSO REVIEWS
From observation, most errors occur when the RSTs are split between several tasks that occur
simultaneously. It is important that the RSO routinely observes the RST during surveys to ensure the SOPs
are being followed accurately and to give suggestions for improvements on the scanning process. Annual
observations by the RSO of the RSTs performing the tasks in the RPM, are also required. More frequent
observations may be performed if needed as indicated by the above referenced documentation reviews.
Department of
Environmental Quality
L Scott Baird
Executrve Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
FILE COPY
October 14, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation
Notice of Violation
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
CERTIFIED MAIL
7005 0390 0000 7508 7160
On October 5-6, 2020, an inspection was conducted at the facilities of Energy Fuels Resources (USA)
Inc. (Licensee) near Blanding, Utah by representatives of the Division of Waste Management and
Radiation Control. The inspection consisted of selective examinations of procedures and representative
records, interviews of personnel, independent measurements, and observations by the inspector to assess
compliance with State requirements. The inspector documented that not all activities related to
Licensee's radioactive materials license were conducted in compliance with State requirements. The
enclosed Notice of Violation is based on findings documented during the inspection.
If you have any questions, please call Ryan Johnson at [phone].
Sincerely,
Ty L Howard, Director
Division of Waste Management and Radiation Control
TLH/RMJ/as
Enclosure: Notice of Violation
DRC-2020-016622 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 100% recycled paper
U.S. Postal Service,,,
CERTIFIED MAIL, RECEIPT
omestic Mail Only; No Insurance Coverage Provided)
delivery information visit our website vvv Lisps Ofri
.* USE
Postage
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Retum Receipt (Endorsement
Restristed (En
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DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
NOTICE OF VIOLATION
Energy Fuels Resources (USA) Inc. Radioactive Materials License
225 Union Blvd., Suite 600 Number UT 1900479
Lakewood, CO 80228
This Notice of Violation (NOV) is issued by the Director of the Division of Waste Management
and Radiation Control (Director) to Energy Fuels Resources (USA) Inc. (Licensee) pursuant to the
Radiation Control Act, as amended, Utah Code Section 19-3-101, et seq. and the Solid and
Hazardous Waste Act, as amended, Utah Code Sections 19-6-104 and 19-6-107.
VIOLATION
An inspection of the licensee's activities was conducted on October 5 & 6, 2020. As a result of
the inspection, a violation of the Utah Administrative Code (Radiation Control Rules) was
identified. The particular violation is set forth below:
1. R313-15-501(1)(b) states in part "Each licensee or registrant shall make, or cause to be
made, surveys of areas,... Are reasonable under the circumstances to evaluate: The
magnitude and the extent of radiation levels; and
R313-15-1103 states in part "Each licensee or registrant shall maintain records showing
the results of surveys..."
Contrary to this requirement, Radiation Safety Technicians (RSTs) at the Mill have been
performing radiological surveys of vehicles being released from the restricted area;
however, not all of the RSTs have been documenting the results of the radiological surveys
on the Licensee's "Daily Vehicle Scan for Vehicles Leaving the Restricted Area" survey
sheets. The inspector documented that on September 15, 2020 at the West Gate vehicle
number C0158CVQ a radiological survey was performed to release the vehicle from the
restricted area but the results were not documented. Upon further investigation of the
records review, additional surveys from 2020's "Daily Vehicle Scan for Vehicles Leaving
the Restricted Area" survey sheets were found that were missing survey results.
This violation has been characterized as Severity Level IV. The base penalty for this
Severity Level is $1,500.00. However, there is no civil penalty assessed for this violation
because this is the first instance this violation has been documented.
CORRECTION OF VIOLATION
Correction of the documented violation in this NOV is mandatory. A written response to the
Director is required within 30 calendar days after receipt of this NOV describing (1) the corrective
action taken and the result achieved; (2) how this corrective action will prevent the violation from
recurring; and (3) the date the violation was resolved or will be resolved.
PAGE 1 of 3
By:
Ty L. Hoird, Director
Division of Waste Management and Radiation Control
CONTESTING THIS NOV
This NOV is effective immediately upon issuance and shall become final unless contested in
writing within 30 days of the effective date of the NOV. See UAC R305-7-303(8).
To contest this NOV, the Licensee must respond in writing and must comply with the applicable
procedural requirements found at Utah Admin. Code R305-7, and with the applicable
requirements of the Utah Administrative Procedures Act, including Utah Code § 63G-4-201(3)(a)
and (b). Those provisions of the Utah Administrative Procedures Act require, among other things,
that Licensee state the factual and legal reasons for disagreeing with this NOV, and that Licensee
state the action it would like the agency to take (e.g, withdrawing the NOV). Under the rules, a
paper copy of the signed, written appeal must be received by the due date. Initiation of an appeal
proceeding via email or fax is not permitted.
For purpose of compliance with this NOV or service of a contest, the Director's address is:
Ty L. Howard, Director
Division of Waste Management and Radiation Control
PO Box 144880
Salt Lake City, UT 84114-4880
Failure to file a Request for Agency Action within the period provided waives any right of
administrative contest, reconsideration, review, or judicial appeal. An extension is only available
under R305-7-303(5) of the Utah Administrative Code.
Dated this 14th day of October 2020
PAGE 2 of 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY thAt I mailed a true and correct copy of the foregoing NOTICE OF
VIOLATION on the tom day of October, 2020 by US Certified Mail (7005 0390 0000
7508 7160) to:
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
PAGE 3 of 3
INSPECTION REPORT 2020 —0/00 2- 2—
Inspection Module: RADMOD-SSS: Surveys, Sources and Security
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiological Release Surveys, Check Sources and Facility Security
Inspection Dates: October 5 & 6, 2020
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Larry Kellum, DWMRC
Personnel Contacted: Terry Slade, Radiation Safety Office (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Teny Slade, RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Larry Kellum (Health Physics Inspector)
During the opening meeting, the inspectors discussed the inspection items and documentation to be
reviewed during the inspection. The Mill staff reminded the inspectors of the safety requirements for the
Mill. The Mill is currently processing uranium from tailing solution.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 78 301072 8/12/2021
Dose Rate Bicron 9048 6/1/2021
Contamination Ludlum 2360 245764 11/8/2020
Inspection Summary
The inspection consisted of reviewing documentation, interviewing the RSO and RSTs and a mill tour. The
following discussion provides more detail of the specific items reviewed.
Item 1. Radiological Surveys
Observations:
The inspector was able to observe an ore truck being surveyed for release from the restricted area by an
RST. The inspector was able to see verify:
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• The RST was following the Mill's procedure;
• The appropriate radiation detection meters were being used; and
• The survey consisted of direct measurements and wipe samples.
The inspector was able to perform a confirmatory survey on the ore truck and a yellowcake drum. The
Surveys indicate that both the truck and the drum meet the appropriate release criteria. The inspector's
survey consisted of direct measurements and wipe samples.
The inspector reviewed completed release survey forms and observed:
• The Intermodal Container Unrestricted surveys documented:
o The Mill uses the release criterial for NRC Regulatory Guide 8.30 Table 2;
o Used the Mill's release limits 0.2 mR/hr @1 cm 1.0 mR/hr max for 13/7 readings;
o The survey forms were complete and legible;
o Appropriate units were used;
o Meter information such as efficiency, calibration, background was recorded on each form;
and
o The survey included 30 locations inside and outside the container.
• The Daily Vehicle Scan for Vehicles Leaving the Restricted Area surveys documented;
o The Mill uses the release criterial for 49 CFR 173.443 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr @1 cm and 1.0 mR/hr max for 13/y readings;
o The survey forms were complete and legible;
o Appropriate units were used; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• The Equipment Unrestricted surveys documented:
o The Mill uses the release criterial for NRC Regulatory Guide 8.30 Table 2;
o Used the Mill's release limits 0.2 mR/hr @1 cm and 1.0 mR/hr max for 13/y readings;
o The survey forms were complete and legible;
o Appropriate units were used; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• The Ore truck restricted surveys documented:
o The Mill uses the release criterial for 49 CFR 173.443 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr @1 cm and 1.0 mR/hr max for 0/7 readings;
o The survey forms were complete and legible;
o Appropriate units were used; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• Restricted Release Surveys documented:
o The survey forms were complete and legible;
o Appropriate units were used;
o Meter information such as efficiency, calibration, background was recorded on each form;
Deficiencies: While reviewing documents, the inspectors found that the Radiation Safety Technicians
(RSTs) at the Mill have been performing radiological surveys of vehicle being released from the restricted
area. However, not all of the RSTs have been documenting the results of the radiological surveys on the
Licensee's "Daily Vehicle Scan for Vehicles Leaving the Restricted Area" survey sheets. On September
15, 2020 at the West Gate vehicle number C0158CVQ a radiological survey was performed to release the
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Inspection Reports\Inspection Report RADMOD-SSS 10-7-2020-pg (1).docx
vehicle from the restricted area but the results were not documented. Upon further review additional
surveys from 2020's "Daily Vehicle Scan for Vehicles Leaving the Restricted Area" survey sheets were
found that were missing survey results. The RSO committed to provide training to staff. The inspector will
follow up on that training in a future inspection.
Item 2. Calibration Sources
Observations: The DWMRC inspector observed:
• The check sources are exempt sources;
• The check sources are kept in a locked safe in the rad tech office;
• Checked sources are checked out and checked in using a checkout form; and
• The inventory list of the check sources is kept up-to-date as an attachment to the Mill's Radiation
Safety plan.
Deficiencies: None
Item 3. Site Security (10CFR37.11(c))
Observations: The DWMRC inspector observed:
• A short-circuit camera system that record activities at each of the gates, the product yard and other
locations scattered throughout the Mill;
• Gates were closed and locked except when being used; and
• Exterior doors are lock and require a badge to open them.
Deficiencies: None
Item 4. Mill Tour: The inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, and solvent the extraction building.
Observations: The DWMRC inspector also observed:
• Ore (natural ore and alternate feed) being stockpiled on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill; and
• OSL badges are properly being stored;
Radiolo ical readin s observed during Mill tour
Location Dose Rate (µR/hr)
Mill 100
Alternate Feed Circiut 100
Solvent Extraction Building 120
Tailing Impoundment #2 50
East Gate 100
Deficiencies: None
Item 5. NESHAP Sampling: During the inspection, the Mill was performing its 1/41y radon NESHAP
sampling of tailing impoundment 2 and 3.
Observations: The DWMRC inspector observed:
• Activated carbon being put into the sampling canisters; and
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Inspection Reports \Inspection Report RADMOD-SSS 10-7-2020-pg (1).docx
2_0
Ryan Johnson
(Print Name)
(Signature)
/0- /6-2020
tr
(Date)
• The sampling canisters being placed on tailing impoundment #2
o The canisters were placed in a grid pattern
o Soil was placed around the edge of the canisters to seal the canisters
o The date and time of placement was recorded on each canister;
Deficiencies: None
Closeout Meeting
Energy Fuels:
Terry Slade, RSO
Garrin Palmer, RST
Justin Perkins, RST
Abel Mendoza, Jr., Safety Technician
Utah DWMRC:
Ryan Johnson, Health Physics Inspector
Larry Kellum, Health Physics Inspector
Findings:
While reviewing documents. The inspectors found that the Radiation Safety Technicians (RSTs) at the Mill
have been performing radiological surveys of vehicle being released from the restricted area. However, not
all of the RSTs have been documenting the results of the radiological surveys on the Licensee's "Daily
Vehicle Scan for Vehicles Leaving the Restricted Area" survey sheets. On September 15, 2020 at the West
Gate vehicle number C0158CVQ a radiological survey was performed to release the vehicle from the
restricted area but the results were not documented. Upon further review additional surveys from 2020's
"Daily Vehicle Scan for Vehicles Leaving the Restricted Area" survey sheets were found that were missing
survey results. The RSO committed to provide training to staff. The inspector will follow up on that
training in a future inspection.
Recommendations
Conduct refresher training on doing and documenting release surveys.
Recommendation for Next Year's RADMOD-SSS Inspection
1. Follow-up on the RSO commitment to retrain RS s to properly document survey results.
2. Review documentation to confirm all r olo al survey are being properly documented.
Prepared By:
Reviewed By:
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GARY R F1ERBERT
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
FILE COPY
September 18, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection: Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
On September 14 and 15, 2020, an inspection was conducted at your facility by Ryan Johnson,
Phil Goble and Russ Topham, representatives of the Division of Waste Management and Radiation
Control (DWMRC). Observations from the inspection were discussed at the closeout meeting with
White Mesa Uranium Mill staff. The inspection was an examination of the activities conducted at your
facility as they relate to compliance with the Utah Radiation Control Rules, the license conditions of the
RML No. UT1900479 and Federal Regulations. The inspection consisted of an examination of
representative records, interviews of personnel, and observations by the inspector.
The DWMRC considers this inspection closed. The DWMRC would like to thank the Mill staff for their
cooperation regarding this inspection.
If you have any questions concerning this letter, please contact Ryan Johnson by email at
[e-mail] or by phone at [phone].
Sincerely,
Phil Goble, Manager
Division of Waste Management and Radiation Control
(Over)
DRC-2020-015503 195 North 1950 West • Salt Lake City, UT
Mailing Address- P 0 Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
unow.deq.utah.gov
Printed on 100% recycled paper
PRG/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
INSPECTION REPORT
Inspection Module: RADMOD-PEM: Surveys/Posting/Exit Monitoring DRC-Zozo-O tri 062.
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiological Postings, Routine Surveys and Employee Exit Monitoring
Inspection Date: September 14 & 15, 2020
Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control
(DWMRC)
Personnel Contacted: Terry Slade, Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Justin Perkins, RST
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Openin2 Meeting
Energy Fuels Resources:
Terry Slade (RSO)
Garfin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (U-Mill/RAM Section Manager)
Russ Topham (DWMRC Engineer)
During the opening meeting, the inspectors discussed the inspection items for the inspection. The Mill staff
reminded the inspector of the safety requirements for the Mill.
DWMRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 4/27/2021
Contamination Ludlum 3002 25017719 10/1/2020
Inspection Summary
The inspection consisted of:
• Observing radiological postings around the Mill;
• Observing Mill personnel perform exit surveys:
• Reviewing documentation of:
o Weekly Alpha surveys;
o Monthly Gamma surveys; and
• Taking dose rate and contamination measurements around the Mill.
The following discussion provides more detail of each inspection items.
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Item 1. Radiological Postings:
Observations: During the Mill Tour the inspector observed the following posted areas:
Posting Locations Observed Postings Observed Dose Rates
Yellowcake Storage Area Caution Radiation Area 70 µR/hr
Laboratory Caution Radioactive Materials 40-50 µR/hr
Laboratory Sample Storage (aka
Balance) Room
Caution Radiation Area 100 µR/hr
Packaging Area Caution Radiation Area 180 µR/hr
Caution Airborne Area
Bird Centrifuge Area Caution Radiation Area 180 µR/hr
Door to the outside on the North
side of the Administration
building
Any Area within this Mill May
Contain Radioactive Material
Not Measured
Sample Preparation Room Caution Airborne Area 50 µR/hr
Nuclear Gauge in Mill near ball
mill
Caution Radioactive Material 1,200 µR/hr
Perimeter fence Caution Radiation Area Not Measured
Perimeter gates Any Area within this Mill May
Contain Radioactive Material
Not Measured
Ore Pad No Posting 100-400 µR/hr
Mill No Posting 100 µR/hr
Solvent Extraction Building No Posting 50 µR/hr
Alternate feed Circuit No Posting 50-350 µR/hr
Note: Due to no uranium production at the time of the inspection there are fewer posted areas in the Mill.
The Inspector also collected large area swipe samples in three areas within the restricted area.
Location Alpha (dpm/100cm2) Beta (dpm/100cm2)
Scale House 5 Below Background
Lunch Room Below Background Below Background
Lunch Room #2 Below Background Below Background
Deficiencies:
None
Item 2. Exit Surveys: The Inspector observed employees survey themselves out of the restricted area and
checked the alpha meter used.
Observations: The Mill uses Alpha scintillators for exit surveys. The Inspector checked the settings of the
survey instruments and found that they were set properly. Meters are calibrated annually. The Mill
personnel that were observed performing exit surveys, did the surveys appropriately. The Mill's RSTs also
perform random checks on exit surveys.
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Meter Location Model Meter Serial # Probe Serial # Cal. Due Alarm
Setting
80 West Admin. Door Ludlum 177 489581 19024 June 8, 2021
East Admin. Door Ludlum 177 159170 192467 April 10, 2021 80
Lab Admin. Door Ludlum 177 185038 17632 June 4, 2021 80
Lunch Room Ludlum 177 159117 16489-1A Dec 4, 2020 80
Lunch Room #2 Ludlum 177 264740 191566 June 8, 2021 80
East Decon Gate Ludlum 177 322883 342603 April 10, 2021 80
Replacement Meter
for Lab Door
Ludlum 177 322900 359856 Dec 4, 2020 80
Deficiencies: The calibration sticker on the meter by the laboratory door indicated that the meter was out
of calibration. Upon closer examination the meter was calibrated in December of 2019. R313-15-501(3)
states that instruments used in determining quantitative radiological measurements shall be calibrated every
12 months. Energy Fuels procedures also say that meters are to be calibrated every 12 months. So the
meter still met the calibration requirements in Rule and procedure. The RSO switched the meter out during
the inspection until a new calibration sticker could be obtained. The Inspector discussed this finding with
the U-Mill/RAM section manager and decided not to pursue an enforcement action because the meter was
still in calibration even though the calibration sticker indicated it was not. However, both the DWMRC
Inspector and the Section Manager thought that the Mill's radiation safety staff should have identified the
problem with the meter's calibration sticker during the three months that the sticker said that the meter was
out of calibration and the time of the inspection.
Item 3. Radiological Surveys and Monitoring: The Inspector reviewed the weekly surveys done around
the Mill.
Observations: The Inspector reviewed the radiological monitoring documentation performed at the Mill
site. The documentation indicated that:
• All areas of the Mill are being survey for radiological conditions;
• Surveys indicate that the Mill is being maintained within regulatory radiological parameters
• Documentation is legible, complete and using appropriate units; and
• "Clean" areas are being maintained.
The Inspector also looked at dosimeter usage. The inspector observed:
• Mill personnel were properly wearing their dosimeters on the torso of the their bodies;
• Dosimetery was being properly stored in the locker room and administration building; and
• Each employee is assigned a dosimeter.
Meter Type Model Meter Serial # Probe Serial # Cal. Due Meter
Condition
Alpha Scintillator Ludlum 3 337521 376358 June 8, 2021 Good
Side Window G/M Ludlum 3 337622 377298 April 10, 2021 Good
Alpha Scintillator Ludlum 3 337536 378523 June 4, 2021 Good
Side Window G/M Ludlum 3 237483 17694 Dec 4, 2020 Good
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(Date)
(Date)
Recommendation for Next Inspection
None
Prepared By:
Reviewed By:
7--1.2.2_-o
Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (U-Mill/RAM Section Manager)
Russ Topham (DWMRC Engineer)
During the closeout meeting the Inspector discussed the issue with the meter by the laboratory door but that
no enforcement action would come from this inspection.
Recommendations
None
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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
FILE Co
August 18, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection: White Mesa Uranium Mill
Radioactive Material License (RML) Number UT 1900479
Dear Ms. Weinel:
On August 10 and 11, 2020, an inspection was conducted at your facility by Ryan Johnson and
Larry Kellum, representatives of the Division of Waste Management and Radiation Control.
Observations from the inspection were discussed at the closeout meeting with White Mesa Uranium Mill
staff. The inspection was an examination of the activities conducted at your facility as they relate to
compliance with the Utah Radiation Control Rules, the license conditions of the RIVIL No. UT1900479
and Federal Regulations. The inspection consisted of an examination of representative records,
interviews of personnel, and observations by the inspector.
The DWMRC considers this inspection closed. The DWMRC would like to thank the Mill staff for their
cooperation regarding this inspection. If you have any questions concerning this letter, please contact
Ryan Johnson by email at [e-mail] or by phone at [phone].
Sincerely,
Phil Goble, Manager
Division of Waste Management and Radiation Control
PRG/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
DRC-2020-013964 195 North 1950 West • Salt Lake City, UT
Mailing Address. P 0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T D D [phone]
zuww.deq.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-RWP: Radiation Work Permits DRC -2020-0 1706 1
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Work Permits and Supporting Documentation
Inspection Dates: August 10 and 11, 2020
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Larry Kellum, DWMRC
Personnel Contacted:
Terry Slade, Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Openin2 Meeting
Energy Fuels Resources:
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Larry Kellum (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. The Mill was not recovering uranium at the time of the inspection but
was recovering vanadium from its process liquids that are stored in the tailing impoundments. The
Mill staff reminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 4/27/2021
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A
Inspection Summary
The inspection consisted of reviewing documentation, a mill tour and interviewing Mill staff. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The inspector reviewed radiation work permits (RWPs) from the
beginning of 20 1 9 to present. The Inspector also reviewed dosimetery records from 20 1 9.
Observations: The DWMRC inspector observed:
• The Mill's RWPs were appropriately filled out and contained the following information:
o A unique identification number;
o The date the RWP was issued;
o A description of the work to be done;
o The location where the work is to be done;
o Identified the personnel working on the job being done and how much time they were
working on the specific job assignment;
o The estimated time that it would take to do the job;
o The personal protective equipment (PPE) requirements for the job;
o The radiological and other occupational monitoring requirements for the job;
o The radiation technician observations and surveillance of the job (when applicable); and
o The RSO's signature indicated that he reviewed everything associated with the work that
was done under the RWP.
• Other documents attached to the RWPs included:
o The Mill's Safe Work permits (SWPs), which document occupational safety concerns;
o The Mill's Confined Space Work permits (when applicable);
o Lock out/tag out information (when applicable);
o Breathing Zone air sample results (when applicable);
o Bioassay results of personnel working on the RWP (when applicable); and
o Photographs of work being done (i.e. Sequoyah Fuels project).
• The Mill's dosimetry documentation for the calendar year of 2018 included:
o The dosimetry logbook that is used to document what happened to the missing OSL badges
(i.e. The employee took the OSL badge home, left the OSL badge in their office or locker,
or lost their OSL badge).
• Other documentation associated with dosimetry included;
o The computer spreadsheet that is used to calculate the annual TEDE for each employee.
• All forms that were observed were legible and complete.
Deficiencies: None
Item 2. RST Interview:
Discussion Points: The DWMRC inspector discussed with the Mill RST:
• The Mill has spare (aka "blank") OSL badges and they assign Mill personnel who lose their
OSL badges a new badge; and/or
• Depending on the situation, to account for the lost badge, the Radiation Safety Staff will assign
the Mill personnel who lost their OSL badge the highest dose received by a coworker of the
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\
same work crew that they work with.
In addition, the Inspector also discussed with the RST how an RWP request is reviewed:
• Each RWP request is different but it could take up to 2 hours to review and RWP;
• The RWP process begins when a supervisor requests an RWP;
• The Radiation Safety Staff goes out to the job location and determines:
o If an RWP is required;
o What type of PPE will be needed;
o What type of radiological monitoring is needed; and
o What other safety issues are present.
• The Radiation and Occupational Safety Staff will then fill out the necessary paperwork:
o The RWP;
o The SWP; and when applicable
o Confined Entry Permits; and
o Lockout/Tag out forms.
• After the RWP is completed the RSO reviews the RWPs for completeness.
Deficiencies: None
Item 3. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the new decontamination (decon) pad, the mill, the tailing impoundments, solvent
the extraction building and the alternate feed circuit.
Observations: The DWMRC inspector also observed:
• The product yard containing full yellowcake (uranium) and black-flake (vanadium) drums;
• Alternate feed and ore being stockpiled on the ore pad;
• OSL badges were appropriately being worn and used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE.
Radiolo ical readin s observed durin Mill tour
Location Dose Rate (p,R/hr)
Ore Pad 100-4,000
Mill 100
Product Yard (at fence line) 50
Solvent Extraction Building 100
Deficiencies: None
Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
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Recommendation for Next Inspection
None
Prepared By: Ryan Johnson
(Print Name)
Reviewed By: Phil Goble
(Print Name)
SVS) —2o2c,
(Date)
(Signature) (Date)
Ryan Johnson (Health Physics Inspector)
Larry Kellum (Health Physics Inspector)
Findin2s
None
Recommendations
None
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Department of
Environmental Quality
L Scott Baird
Executive Director
Fitakf etip v
GARY R HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L Howard
Director
July 16, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-RPP:
Radioactive Material License (RML) Number UT 1900479
Dear Ms. Weinel:
On July 13 and 14, 2020, an inspection was conducted at your facility by Ryan Johnson, a representative
of the Division of Waste Management and Radiation Control (DWMRC). Observations from the
inspection were discussed at the closeout meeting with White Mesa Uranium Mill staff. The inspection
was an examination of the activities conducted at your facility as they relate to compliance with the Utah
Radiation Control Rules, the license conditions of the RIVIL No. UT1900479 and Federal Regulations.
The inspection consisted of an examination of representative records, interviews of personnel, and
observations by the inspector.
The DWMRC considers this inspection closed. The DWMRC would like to thank the Mill staff for their
cooperation regarding this inspection. If you have any questions concerning this letter, please contact
Ryan Johnson by email at rmjohnsongutah.gov or by phone at [phone].
Sincerely,
Phil Goble, Manager
Division of Waste Management and Radiation Control
PRG/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Mill Manager, White Mesa Uranium Mill, EFRI
DRC-2020-012422 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]
wzuw.deq.utah.gov
Printed on 100% recycled paper
TAZG-ZOW -01 <5504-
INSPECTION REPORT
Inspection Module: RADMOD-RPP: Respiratory Protection Program (RPP)
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Respiratory Protection
Inspection Dates: July 13 & 14, 2020
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted: Terry Slade, Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
• NRC Regulatory Guide 8.15
Opening Meeting
Energy Fuels Resources:
Terry Slade, RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. The Mill staff reminded the inspectors of the safety requirements
for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 4/27/2021
Inspection Summary
The inspection consisted of a RSO interview, reviewing applicable documentation and a mill tour.
The following discussion provides more detail of the specific items reviewed.
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Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
• The current Respiratory Protection Manual and confirmed all required respirator protection
procedures from R313-15-703 and NRC Reg. Guide 8.15 are covered in the manual;
• The respirator issuance log;
• Respirator Damage Sheet;
• Fit testing and respirator training documentation;
• Respirator survey forms; and
• The new Medical Clearance form.
The Inspector followed up on the documentation of Medical Clearance requirement from 2019s
inspection on the RPP. The Mill has developed a new form in which a medical doctor declares if
an employee is:
• Cleared to wear a respirator without medical restrictions;
• Cleared to wear a respirator with minor medical restrictions; or
• Cannot wear a respirator.
The doctor then signs the form at the bottom of the page. If the employee has minor restrictions or
cannot wear a respirator a brief explanation is recorded. The Inspector determined that this form
properly documents the Medical Clearance requirement and no further follow up is required.
In addition, the Mill is now allowing employees to use half-face respirators when appropriate. The
Mill has updated their respiratory protection procedures for the use of half-face respirators and
how the radiation safety staff will determine when the use of half-face respirators is appropriate.
Deficiencies: None
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The
tour included ore pad, the mill, the solvent extraction building, the alternate feed circuit, the tailing
impoundments and the respirator room.
Observations: The DWMRC inspector also observed:
• OSL badges were appropriately being used by all observed employees at the Mill;
• Respirator room was clean and well organized;
• Respirators were clean and in good repair; and
• Meters used to survey respirators were calibrated and in good repair.
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Radiolo ical readin s observed durin Mill tour
Location Dose Rate (j.tR/hr)
Mill 100
Product Storage Yard 70
Solvent Extraction Building 70
Ore Pad 250-1,000
Alternate Feed Ciruit 60
Deficiencies: None
Closeout Meeting
Energy Fuels:
Terry Slade, RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Findino
None
Recommendations
None
Recommendation for Next Inspection
None
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Print Name) (Signature)
9-27- 2o2c7
(Date)
7 zd52_,c3
(Dat
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01.11 I I
I 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
Respiratory Protection Approval Form
Name: Date:
Employee can wear respiratory equipment without any medical restriction.
(Self-contained breathing apparatus excluded.)
Employee will incur minor restrictions
(Please explain.)
Employee cannot wear respiratory equipment.
(Please explain.)
Signature of Doctor:
White Mesa Mill — Standard Operating Procedures Date: 03/6/2020 Revision: EFR 11
SOP PEL-RP-2
pook: Radiation Safety Manual, Section 2 Page 1 of 17
2.0 RADIATION MONITORING — AREA
2.1 HIGH VOLUME AIRBORNE AREA AIR SAMPLING
Area air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airborne
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high volume sampler or similar high
volume pump will be used for this purpose. Samples will be analyzed as per standard
gross alpha analysis procedures using a sensitive alpha detector.
2.1.1 Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of 40 1pm or
geater for one hour or longer. A variety of equipment may be used for area air sampling,
however normally the equipment used is an Eberline RAS-1, Scientific Industries Model
H25004, or equivalent. Equipment is calibrated prior to each usage as per Section 3.6 of
this manual.
2.1.2 Frequency/Locations
Area dust monitoring frequency is monthly for the locations shown in Table 2.1.2-1.
Table 2.1.2-1
Airborne Radiation Sample Locations
Code Location/Description
BA1 Ore Scalehouse
BA2 Ore Storage
BA3 Sample Plant
BA4 SAG Mill Area
BA5 Leach Tank Area
BA6 CCD Circuit
BA7 Solvent Extraction Building/Stripping Section
BA8 Solvent Extraction Building/Control Room
BA9 Yellowcake Precipitation & West Storage Area
BA10 North Yellowcake Dryer Enclosure
BAll South yellowcake Dryer Enclosure
BA12 Yellowcake Drying & Packaging Area
BA13 Yellowcake Packaging Enclosure
BA14 Product Yard
BA15 Bucking Room
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
FILE COPY
June 17, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection: Radioactive Material License (RML) Number UT 1900479
Dear Ms. Weinel:
On June 9, 2020, an inspection was conducted at your facility by Ryan Johnson of the Division of Waste
Management and Radiation Control (DWMRC) of the Utah Department of Environmental Quality.
Observations from the inspection were discussed at the closeout meeting with White Mesa Uranium Mill
staff. The inspection was an examination of the activities conducted at your facility as they relate to
compliance with the Utah Radiation Control Rules, the license conditions of the RML No. UT 1900479
and Federal Regulations. The inspection consisted of an examination of representative records,
interviews of personnel, and observations by the inspector.
The DWMRC considers this inspection closed. The DWMRC would like to thank the Mill staff for their
cooperation regarding this inspection. If you have any questions concerning this letter, please contact
Ryan Johnson by phone at [phone] or by email at rmjohnsongutah.gov.
Sincerely,
Phil Goble, Manager
Division of Waste Management and Radiation Control
PRG/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
DRC-2020-01 1316 195 North 1950 West • Salt Lake City, UT
Mailing Address: P 0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
min v.detbutali.gov
Printed on 100% recycled paper
T12C-2020-01,3503
Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted:
INSPECTION REPORT
RADMOD-IM: Internal Monitoring
Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Occupational Air Sampling and Bioassay Monitoring
June 9, 2020
Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Terry Slade, Energy Fuels Resources Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Justin Perkins, RST
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The Mill is processing calcine alternate feed. The Mill staff reminded the inspector
of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 4/27/2021
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Inspection Summary
The inspection consisted of a RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
• Calibration sheets for general area and breathing zone sample pumps;
• General area air sampling worksheets;
• Breathing zone sampling worksheets; and
• Bioassay analytical results and chain of custody forms.
While reviewing the paperwork for breathing zone sampling, the inspector noticed that the derived air
concentration (DAC) values being recorded were lower than in previous years. The DAC values observed
in 2019 ranged between 0 and 20% DAC and the first half of 2020 ranged between 0 and 4,105.28% DAC.
These low DAC values are a result of the Mill primarily recovering vanadium in 2016 and processing
alternate feeds in first half of 2020. The Inspector and the RST discussed these values and the RST also
informed the Inspector the radiation staff have been observing and evaluating how the alternate feed
material is being dumped. Based off the observations the radiation staff were able to work with the work
crews to find way to lower the dusting inside the drum dumps. Those changes probably accounts for the
lower DAC values in the first half of 2020. The monthly airborne sampling results were also very low due
to the Mill not processing uranium in 2019 and small quantities in 2020.
The work at the Mill has been done under Radiation Work Permits (RWPs) or according to Standard
Operating Procedures (SOPs). The inspector verified that:
• Respirator protection was being used by the mill personnel performing the work;
• Bioassay samples were being collected from the mill personnel performing the work;
• Bioassay results indicated that the mill personnel were not inhaling uranium; and
• Bioassay sampling and analysis standard operating procedure (SOP) was being followed.
While reviewing the paperwork for the bioassay results the inspector noticed that bioassay samples were
above the Mill's action level in 2019 and the first half of 2020. Most samples were non-detect during this
time.
Deficiencies: None
Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the alternate feed circuit and solvent extraction building.
Observations: The DWMRC inspector also observed:
• Ore and Alternate feed material being stored on the ore pad; and
• OSL badges were appropriately being used by all observed employees at the Mill.
Item 3. Stack Sampling: The Mill was conduct 1/41y stack sampling at the time of the inspection. The
Inspector observed some of the sampling event. While observing the sampling one of the samplers
informed the RST accompanying the Inspector that there are some cracks in one of the stacks. This is
maintenance issue at this time but the Inspector passed on the information to the Division Engineers to
conduct the appropriate follow-up.
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iesg'atr
(Date)
2_0
Radiolo ical readin s observed during Mill tour
Location Dose Rate (uR/hr)
Ore Pad 200-1,000
Mill 200
Yellowcake Storage Area 50
Solvent Extraction Building 50
Packaging Area 200-1,000
Deficiencies: None
Closeout Meeting
Energy Fuels:
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Findino
None
Recommendations
None
Recommendation for Next Inspection
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately;
2. Personnel Exit Monitoring;
Prepared By: Ryan Johnson
(Print Name)
Reviewed By: Phil Goble
(Print Name) (Signature) (Date)
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Inspection Reports\Inspection Report RADMOD-IIVI 6-11-2020.docx
GARY R. HERBERT
Governor
SPENCER J. COX
Lteutenant Governor
Department of
Environmental Quality
L. Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
FILE COPY
May 27, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection: Radioactive Material License (RML) Number UT 1900479
Dear Ms. Weinel:
On May 13 and 14, 2020, an inspection was conducted at your facility by Ryan Johnson and Phil Goble,
representatives of the Division of Waste Management and Radiation Control (DWMRC). Observations
from the inspection were discussed at the closeout meeting with White Mesa Uranium Mill staff The
inspection was an examination of the activities conducted at your facility as they relate to compliance
with the Utah Radiation Control Rules, the license conditions of the RML Number UT 1900479 and
Federal Regulations. The inspection consisted of an examination of representative records, interviews
of personnel, and observations by the inspector.
The DWMRC considers this inspection closed. The DWMRC would like to thank the Mill staff for their
cooperation regarding this inspection. If you have any questions concerning this letter, please contact
Ryan Johnson by email at [e-mail] or by phone at [phone].
Sincerely,
Phil Goble, Manager, Uranium Mills and Radioactive Materials Section
Division of Waste Management and Radiation Control
PRG/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
DRC-2020-010102 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 100% recycled paper
ePP--2020-0 / 350z
INSPECTION REPORT
Inspection Module: RADMOD-AFIL: Alternate Feed and Insitu Leach
Inspection Location: Energy Fuels Resources Inc. (EFRI) - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Alternate Feed Material storage and processing, 11e.(2) disposal, and Equivalent
Feed and Yellowcake Sluny storage and processing
Inspection Dates: May 13 and May 14, 2020
Inspectors:
Personnel Contacted:
Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Phil Goble, DWMRC
Logan Shumway, Energy Fuels Resources, Mill Manager
Terry Slade, Energy Fuels Resources, Radiation Safety Officer (RSO)
Garrin Palmer, Energy Fuels Resources, Radiation Safety Technician (RST)
Justin Perkins, Energy Fuels Resources, RST
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Teny Slade, RSO
Ganin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (U-Mill/RAM Section Manager)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The main portion of the Mill was not in operation during this inspection except for
the north drum dump station and pulp storage which is being used for alternate feed processing. The Mill
staff reminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 4/27/2021
Inspection Summary
The inspection consisted of an RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items reviewed.
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Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
• 11e.(2) Shipment paperwork;
• Alternate Feed receipts;
• Equivalent Feed paperwork; and
• Tailing Capacity Form.
The 1le.(2) shipment paperwork documented;
• Where and how the 11e.(2) material was disposed of in Tailing Cell #3;
• Where the 1le.(2) material came from and how much material has been sent to the White Mesa
Uranium mill for disposal; and
• The radiological surveys of the truck and 11e.(2) material that was received by the mill.
The alternate feed receipts documented:
• Which alternate feed material is currently being accepted and stored on the Mill's ore pad; and
• How much alternate feed material is currently onsite.
The equivalent feed paperwork documented how much equivalent feed material has been accepted and
processed at the mill.
The Tailing Capacity Form documents that there is space in the tailing cells for the amount of feed material
(both alternate feed and conventional ore) that is currently stored on the ore pad.
Deficiencies: None
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, and the alternate feed circuit. Currently Calcine alternate feed material is
being processed using the North drum dump station next to the grizzly and being stored in the pulp and
leach tanks.
Observations: The DWMRC inspector also observed:
• Alternate feed being stored on the ore pad;
• Proper PPE was being worn by Mill employees within all observed areas of the Mill;
• Proper Radiological Posting were being used within all observed areas of the Mill;
• Proper Radiological Monitoring was being done at the North drum dump station; and
• OSL badges were appropriately being used by all observed employees at the Mill;
Radiolo ical readin s observed durin Mill tour
Location Dose Rate (uR/hr)
Product Storage Yard 50
Ore Pad 300-400
Ore Pad 100-150
Solvent Extraction 40-50
Alternate Feed Circuit 30
Deficiencies: None
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(Print Name)
Reviewed By: Phil Goble
(Print Name)
(Da))
...54.4 r
(Signature) (D
Zc-c,
Closeout Meeting
Energy Fuels:
Teny Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (U-Mill/RAM Section Manager)
Findino
None
Recommendations
None
Recommendation for Next AFIL Inspection
1. Confirm procedures are being followed if Alternate Feeds are stored off the ore pad;
2. Verify appropriate postings and radio1ogjç njnitoring for processing alternate feeds;
/---. , Prepared By: Ryan Johnson J 2 dec.
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Inspection Reports \Inspection Report RADMOD-AFIL 05-19-2020.docx
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
FILE COPY
March 19, 2020
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection: Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
On March 18, 2020, the Annual Safety and Environmental Review Panel (SERP) reports for the year
2019 was reviewed by Ryan Johnson of the Division of Waste Management and Radiation Control
(DWMRC). The report was reviewed to determine the compliance with the requirements of License
Condition 9.4 of your facility's Radioactive Material License Number UT 1900479. The DWMRC staff
determined that the requirements were met.
The DWMRC considers this inspection closed. If you have any questions concerning this letter, please
contact Ryan Johnson by email at "rmjohnsongutah.gov" or by phone at [phone].
Sincerely,
Phil Goble, Manager
Division of Waste Management and Radiation Control
PRG/RMJ/al
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer
Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
DRC-2020-005082 195 North 1950 West • Salt Lake City, UT
Mailing Address P 0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T D D [phone]
www.deq.utah.gov
Printed on 1 00% recycled paper
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140 Dgc-202o-ooSZ www.energyfuels.com
Div of Waste Managerrem
and Racfiation Control
MAR 2 0 2020
March 18, 2020
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 U11900479
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 ("SERF") Report. Attached is the annual 2019 SERP Report required by
RML Condition 9.4D.
A copy of the Standard Operating Procedure ("SOP") that resulted from this SERP is included as
Attachment A. The SOP is attached because it was inadvertently omitted from the 2019 annual SOP
_submission, which was transmitted _to die Division _of Waste Management and Radiation Convol
("DWMRC") on December 17, 2019.
If you should have any questions regarding this report please contact me at 303-389-4134.
Yours very truly,
tGet
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: Scott Bakken
David Frydenlund
Paul Goranson
Garrin Palmer
Logan Shumway
Terry Slade
WHITE MESA MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL ("SERP")
2019 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 18, 2020
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 ("SERP") evaluation conducted for the
period of January 1, 2019 through December 31, 2019. The SERP evaluation and review was
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 evaluation is 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
the License, or irnpair 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. 2019-01 May 7, 2019
Mini-SX (DEHPA Process)
2.1.1. Proposed Action
Review and approve a proposed SOP to modify the uranium solvent extraction circuit to
include a mini-SX circuit that can be activated as needed to allow recovery of uranium
from solutions with impurities.
2
2. 1 .2. Descriptions of Change, Tests or Experiments
Periodically, the Mill recovers dissolved vanadium and uranium from the solutions in the ponds
(Cells). Recovery of vanadium from the pond solutions requires all of the uranium to be removed
from the solution before processing in the vanadium solvent extraction circuit ("VSX").
Removal of uranium is accomplished in the uranium solvent extraction circuit ("USX") using
normal USX 'procedures and chemicals. The uranium removed from the pond solution is
concentrated into a solution containing impurities which requires additional processing before it
can be recovered as a final product (yellowcake). The basic steps of the "additional processing"
are: acidification and processing through the mini-SX with di-(2-ethylhexyl)phosphoric acid
("DEHPA") extractant.
The proposed system will process the liquids utilizing existing Mill facilities and equipment.
The uranium solution acidification step that will precede the mini-SX has been used in the Mill
previously for other uranium bearing solutions.
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 according to the 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 mini-SX is a smaller version of the USX circuit
utilizing one additional chemical 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 mini-SX in accordance with the SOP.
The purified and concentrated yellowcake that will be produced will not cause the Mill to exceed
the yellowcake production limit under the License.
Processing according to the proposed SOP is consistent with the plans and SOPs referenced in
the License and its renewal application.
Processing according to the SOP does not require modification of the Mill's Air Approval Order.
Processing according to the SOP does not require modification of the Mill's Clean Air Act Risk
Management Plan.
3
Processing according to the 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 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 SOP involves use of DEHPA, which has been previously
handled in the Mill for processing of certain alternate feed materials.
The SOP proposes receiving DEHPA in two plastic 250-gallon totes. The totes will be stored in
a bermed area at the north end of, and within, the USX building or other secure location. 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.
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?
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 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 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 containination to the environment.
Processing according to the SOP is within the envelope of conditions evaluated in the Mill's
MILDOS model for dose to off-site receptors.
Processing according to the SOP will have no effect on commitments or the quantities addressed
in the Reclamation Plan.
The SERP determined that there would be no change to any criterion that would affect the Mill's
surety. There would be no change to the footprint of the Mill. There would be no increase in the
4
quantity of tailings generated. If the Mill were to cease operations and the inventory of DEHPA
and additional kerosene in the mini-SX as required by the SOP were to be disposed in the
tailings management system, the quantity would be immeasurably small, approximately 500
gallons of DEHPA and 5,000 gallons of additional kerosene.
2.1.3.3 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 mini-SX area of the SX building or other secure location.
The SERP assessed potential emissions and effluents and determined that the 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 SOP would not
produce any increase in the quantity of emissions.
The SERP assessed that the wastes from the mini-SX 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 500 gallons in two separate 250-
gallon plastic totes. If the entire quantity were to be transferred to the Mill's tailings
management system, and as a result of spill or disposal, the maximum concentration in any one
cell would be approximately 1 ppm. The SERP 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 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.
2.1.4 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
5
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 new SOP has
been completed and is included as an attachment to this report.
2.1.5 SERP Action
The SERP concluded that processing using the mini-SX Process in accordance with the SOP
meets the criteria set forth in the SERP SOP for approval, and approved the SOP.
The SERP authorized immediate implementation of the SOP.
6
3.0 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
William Paul Goranson
Chief Operating Officer (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
David Frydenlund
Chief Financial Officer, General
Counsel and Corporate Secretary
Independent Safety/Environmental
Evaluation
Jo Ann Tischler
Independent Chemical Engineering
Consultant
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 SOP Timo Groves
Process Engineer
7
ATTACHMENT A
No.: PBL-24 ENERGY FUELS RESOURCES (U. INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES
Date: May 17, 2019 Title: Mini SX (DERPA Process)

Page 1 of 5

1.0 Purpose
The methods and procedures set forth in this standard operating procedure (SOP) are to
ensure worker safety and safety of the environment, maintain safe and appropriate
operation of process equipment and allow for efficient operation of this process. This
process involves recovery of uranium from a byproduct stream from the Pond Solution
Vanadium Recovery process as well as other uranium solvent extraction streams
containing high chloride concentrations.
Recovery of vanadium from the pond solutions requires all of the uranium to be removed
from the solution before processing in the vanadium solvent extraction circuit (VSX).
Removal of uranium is accomplished in the uranium solvent extraction circuit (USX) using
normal USX procedures and chemicals. The uranium removed from the pond solution is
concentrated into a solution containing residual soda ash and other impurities (specifically
chlorides and molybdenum) which requires additional processing before it can be
recovered as a final product (yellowcake). The basic steps of the "additional processing"
are: acidification (2.0), and processing through the mini SX with DEHPA extractant
(3.0). These steps will produce a concentrated uranium solution that is able to be stored in
available mill tanks and can be processed in the normal USX process at a later time. This
SOP will also describe necessary handling and safety precautions for di-(2-
ethylhexyl)phosphoric acid (DEHPA).
2.0 Uranium Solution Acidification
The uranium bearing solution produced in the USX must be acidified in order to remove
any carbonates and to prepare the solution for extraction with DEHPA. The uraniurn
bearing solution is pumped from the USX #3 stripper into the USX acid wash. Passing the
solution through the acid wash allows any entrained amine organic to separate and allow
any entrained solids (soda ash) to settle out of the solution to the bottom of the settler. The
solution is then pumped from the acid wash to the USX #1 stripper. Acid is added to the
solution at this point (either at the back of the acid wash as the solution is leaving or in the
#1 stripper) to decompose the carbonate and adjust the pH of the solution to be amenable
with DEHPA (pH 1-2). The acidified solution will be pumped from #1 stripper to the mini
SX feed tank.
Always visually ensure that the aqueous solution pumped to the mini SX feed tank is free
of any organic. Entrained organic from the USX contains amines and are a different
extractant than the DEHPA and will contaminate the mini SX organic making it less
efficient.
1. Ensure that a workplace exam has occurred before or at the beginning of your shift.
2. Inspect all pipes, pumps and tanks for leaks or abnormalities.
3. Check for motors that are running hot and any other possible ignition source.
No.: PBL-24 ENERGY FUELS RESOURCES (uip INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES
Date: May 17, 2019 Title: Mini SX (DEHPA Process)

Page 2 of 5

4. Carbonates decompose to form carbon dioxide (CO2) when acidified. Significant
foaming will occur where the acid is added. Make sure acid is added consistently
and at rates that will prevent the settlers from overflowing.
5. Check parameter targets for any changes since the previous shift and maintain
appropriate parameters as established by your supervisor (flow rates, pH, etc.).
6. Stay in communication with the USX operator to ensure that any upsets or changes
are known and accounted for.
7. Document any abnormalities and changes in the circuit log book.
3.0 DEHPA Extraction in the Mini SX Circuit
Once the uranium bearing solution is acidified it is ready to be fed to the mini SX circuit.
The mini SX circuit has three extractors, one acid wash and three strippers. The acid wash
step is unnecessary in this process and the tank will be bypassed. The extractors will be
operated counter-currently producing a loaded organic containing uranium and a raffinate
solution which is nearly barren of uranium but still contains chlorides. The strippers will
also be operated counter-currently. The loaded organic will be stripped with soda ash
solution producing barren (stripped) organic that can be recycled back to the extractors.
"Loaded strip" will also be produced in the strippers (from the soda ash solution) which
will contain the concentrated uranium. The organic in the mini SX contains DEHPA and
tridecyl alcohol (TDA) in a kerosene diluent. Organic solutions containing DEHPA require
special handling which is discussed in the next section.
The raffinate solution produced by the mini SX will be barren of most of the vanadium. It
will contain high concentrations of chlorides. Chlorides are problematic to USX and VSX
operation which may necessitate this solution be pumped to a specific tailing cell or
evaporation pond as dictated by your supervisor. Loaded strip from the mini SX circuit
will be transferred batch-wise and stored in large tanks until the solution can be processed
by normal USX operation.
Important:
The mini SX circuit organic has DEHPA which extracts uranium but not chlorides. The
VSX and USX do not contain DEHPA. Those two circuits utilize amines to extract
vanadium and uranium and behave very differently than DEHPA. If organic containing
ANY amount of DEHPA spilled or leaked into either the VSX or the USX circuits, the
organic in the VSX and USX would be contaminated and unusable for future processing.
IT IS EXTREMELY lMPORTANT TO ENSURE THAT THE ORGANIC FROM THE
MINI SX IS NEVER ALLOWED TO ENTER INTO THE OTHER SX CIRCUITS OR
ANY SUMP, TRENCH OR TANK THAT COULD BE PUMPED BACK INTO THE
VSX OR USX. Unused totes of DEHPA•must also be stored in such a place that any leak
or spill would not be able to contaminate the VSX or USX. If a contamination does happen
or if you think contamination may have happened contact your supervisor no matter how
small the possible contamination was.
No.: PBL-24 ENERGY FUELS RESOURCES (U. INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES
Date: May 17, 2019 Title: Mini SX (DEHPA Process)

Page 3 of 5

DEHPA is a weak acid and is corrosive to metal. Pure DEHPA as well as organic that
contains DEHPA must never be stored in metal containers. In the event of a fine, burned
DEHPA can create phosphine gasses which are a breathing hazard.
1. Ensure that a workplace exam has occurred before or at the beginning of your shift.
2. Inspect all pipes, pumps and tanks for leaks or abnormalities.
3. Check parameter targets for any changes since the previous shift and maintain
appropriate parameters as established by your supervisor (flow rates, pH, soda ash
concentration, temperature, etc.).
4. Document any abnormalities and changes in the circuit log book.
4.0 Radiation Monitoring
Radiation exposure is consistent with normal operations. Monitoring and sampling will
stay consistent with normal mill operations as outlined in SOP book 9.
4.1 DAC Determination
DACs will not change.
4.2 Breathing Zone Sampling
Sampling will be conducted under normal conditions and frequencies as outlined
in SOP book 9.

4.3 Environmental Sampling
Any spill outside of containment areas needs to be reported and cleaned, in keeping
with the SPCC and the SWBMPP. The clean-up material will be placed in the
tailings area.
No additional sampling is required.

4.4 Tailings Management
The quantities of materials used in this process are small and will have negligible
impact on tailings system function, operation or capacity

4.5 Surveys For External Radiation
Conducted as during normal operations. See SOP book 9.

4.6 Surveys for Radon-222, Radon-220 and Their Daughters
Conducted as during normal operations. See SOP book 9.
No.: PBL-24
Rev. No.: R-0 III Date: May 17, 2019
ENERGY FUELS RESOURCES (U. INC.
STANDARD OPERATING PROCEDURES
Title: Mini SX (DEHPA Process)
Page 4 of 5
5.0 Hazard Identification and Safety
The hazard identification for the processes around and in the mini SX circuit do not differ
from those of the rest of the SX building (refer to SOP "Uranium SX" Book 4) with the
exception of DEHPA handling.
5. 1 Required Personnel Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed
shoes are required as a minimum. These must be worn in all areas of the Mill with the
exception of the Administration Building. DEHPA is more corrosive than typical organics
used in the mill. It is a weak acid and should be treated as such. Any contact to one's
person should be washed thoroughly with water immediately.
The following PPE is required when transferring DEHPA into the mini SX extractors.
1 . Wet suits both top and bottom.
2. Rubber gloves.
3. Rubber boots.
4. Face shield (or full face respirator if preferred).
5.2 Industrial Hazards and Safety
1. Use caution when walking in the area. Floors can be slippery when wet,
especially when wetted with organic.
2. Do not leave trip hazards.
3. Clean up all leaks and spills immediately.
4. Do not use any spark generating tools or equipment.
5. If burned, DEHPA can produce poisonous gas. In the case of a fire, immediately
evacuate the area surrounding the fire. Any close proximity fire-fighting is to
be done by trained individuals using self-contained breathing apparatus (SCBA)
units.
6.0 Radiological and Environmental Concerns
The White Mesa Mill has a robust program for monitoring and preventing radiation
exposure to workers and the environment as well as monitoring and preventing
No.: PBL-24 ENERGY FUELS RESOURCES (U. INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES
Date: May 17, 2019 Title: Mini SX (DEHPA Process)

Page 5 of 5

contamination and harm to the environment (See SOP book 9, 11, and 19). Current
procedures and monitoring program will adequately monitor and prevent any radiological
and environmental concerns as a result of this process.
6.1 Urinalysis
No additional requirements to the current urinalysis program (as described in SOP
Book 9). The current urinalysis program will identify any potential uptake.
6.2 Personal Hygiene
1. All personnel will survey their hands, boots and clothing for surface
contamination prior to eating or leaving the restricted area.
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
ALE COPY
March 9, 2020
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Compliance Evaluation Inspection: Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
On February 25, 2020, an inspection was conducted at your facility by Ryan Johnson a representative of
the Division of Waste Management and Radiation Control (DWMRC). Observations from the
inspection were discussed at the closeout meeting with White Mesa Uranium Mill staff. The inspection
was an examination of the activities conducted at your facility as they relate to compliance with the Utah
Radiation Control Rules, the license conditions of the RML No. UT1900479 and Federal Regulations.
The inspection consisted of an examination of representative records, interviews of personnel, and
observations by the inspector.
Enclosed is the inspection report regarding this inspection for your review. The DWMRC considers this
inspection closed. The DWMRC would like to thank the Mill staff for their cooperation regarding this
inspection. If you have any questions concerning this letter, please contact Ryan Johnson by email at
rmjohnsongutah.gov or by phone at [phone].
Phil Goble, Manager
Division of Waste Management and Radiation Control
PRG/RMJ/al
Enclosure: Inspection Report, February 25, 2020
c: Kirk Benge, Health Officer, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Department
Scott Hacking, P.E., DEQ District Engineer
DRC-2020-004285 195 North 1950 West • Salt Lake City, UT
Mailmg Address P 0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T D D [phone] www deq utah gat
Printed on 100% recycled paper
-WC-2020-10050 I
INSPECTION REPORT
Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted:
RADMOD-Training: Radiation Protection Training, Respiratory Protection
Training, RSO Training, and Rad Tech Training
Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Annual Radiation and Respiratory Protection Training
February 25, 2020
Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Terry Slade, Energy Fuels Resources Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Wayne Palmer, Safety Coordinator
Logan Shumway, Mill Manager
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Terry Slade, Mill RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The main portion of the Mill was not in operation during this inspection. The Mill
staff reminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 05/13/20
Inspection Summary
The inspection consisted of an RSO interview, reviewing applicable documentation, observing the Mill's
Annual Radiation Safety/Respiratory Protection refresher training and a mill tour. The following discussion
provides more detail of the specific items reviewed.
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Item 1. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the alternate feed circuit, and the SX building.
Observations: The DWMRC inspector observed:
• Proper PPE was being wom by Mill employees within all observed areas of the Mill;
• Proper Radiological Posting were being used within all observed areas of the Mill; and
• OSL badges were appropriately being used by all observed employees at the Mill;
Radiolo ical readin s observed during Mill tour
Location Dose Rate (uR/hr)
Alternate Feed Circuit 28
Product Yard 60
Ore Pad 100-300
Solvent Extraction 50
Mill 100
Deficiencies: None
Item 2. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed:
. Training documents for contractor and new hire training from 2019. These documents included:
o Radiation Safety and Respiratory Protection Exams;
o Initial/Refresher Training as documented on the MSHA form;
o Personnel Monitoring;
o Medical Clearance; and
o Fit Tests.
. The Inspector also obtained copies of:
o The 2020 exams;
o The 2020 radiation safety training outline;
o White Mesa Mill's contractor radiation safety training; and
o The 2020 training schedule.
Deficiencies: None
Item 3. RSO Interview:
Observations: The DWMRC inspector discussed the following with the Mill's RSO:
The Inspector and the RSO discussed the training that the RSO and the Radiation safety techs would be
receiving this year. The Inspector also reviewed the training certificates of the RSTs and obtained copies of
Garrin Palmers training certificate because he is the RSO's designee when the RSO is not present. The
RSO and all of the RSTs have been appropriately trained and have relevant additional training for their
positions. Examples of training that they have had include:
• Radiation Safety Officer Training (RSO and Designee);
• Transportation of Radioactive Material (Radiation Safety Staff);
• Dosimetry (Radiation Safety Staff); and
• Instrumentation (Radiation safety Staff).
The Inspector determined that the training received by the Radiation Safety Staff is appropriate for the jobs
and has been done at the appropriate refresher intervals. The Inspector also interviewed the safety
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Recommendations
None
Recommendation for Next Inspection
None
Prepared By:
Reviewed By:
-4/--2020
3 26'20
(Dat )
coordinator to discuss contractor training.
Deficiencies: None
Item 4. Annual Refresher Course: The Inspector observed the annual Radiation Safety and Respiratory
Protection refresher training.
Observations: The DWMRC inspector observed:
• The Mill Manager discussed:
o President Trumps decision on Uranium; and
o Company policies on working hours, lunch times and cell phone use.
• One of the Mill's Radiation Safety Technician discussed Storm water training:
o If a spill occurs:
• Clean it up. Using dry methods whenever possible;
• Document the spill using pictures and the "orange" cards; and
• Preventing spills is the best policy.
• The RSO Discussed the following:
o Discussed 20 1 9 employee exposure and what that exposure means;
o Relevant topics from NRC Reg. Guide 8.3 1 section 2.5;
o How to reduce exposure: Time, Distance and Shielding. Examples were discussed on how
time distance and shielding is used at the Mill;
o Posting requirements: What is a radiation area, an airborne area and a contamination area
are and what is required in each area;
o Characteristics of Alpha, Beta and Gamma Radiation.
Deficiencies: None
Closeout Meeting
Energy Fuels:
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Findino
None
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White MesaMill 41!1 riear 41010‘ doe ge_A- r ov\ .5‘4., IF
Date: 1 19 Revision: EFR 3.5
Book #13 Training Manual 72 of 86
Rcstat,S ar Appendix E razA‘
13 f-c.on
Annual Refresher Training
RADIATION SAFETY TRAINING OUTLINE FOR ANNUAL REFRESHER TRAINING
The following topics will be discussed in this training:
1. Relevant information that has become available during the past year
(a) Processing changes that may affect exposures
(b) Posting changes, if any
(c) Discussion of air, radon and beta/gamma survey results
(d) Changes to SOPs that affect Radiation Safety
2. Review of safety problems that have arisen during the year
(a) Discuss issues that have been raised through daily and weekly inspections
(b) Housekeeping issues
(c) RWP's
3. Changes in regulations and license conditions
(a) Discuss changes that affect the operation or other activities in the Mill
(b) Discuss NOVs or recommendations from the DRC
4. Exposure trends
(a) Average exposure for the previous year
(b) Highest exposure for the previous year
(c) Comparison of exposures versus background
(d) Discussion on the exposures rates received and how those results compare with the
ALARA goals
5. Other current topics
(a) Discuss any problem areas that may have arisen
6. Review of Key Radiation Safety Topics
(a) At the discretion of the instructor, selected key radiation safety topics, such as one or
more of the topics listed on the handouts included in Addenda D1 or on the Radiation Safety
Training outline.
Name:
Date:

Revised 02/02/18

Respirator Quiz 2018
1. A full-face respirator has a protection factor of
a. 10
b. 100
c. 1,000
d. 10,000
2. A full-face respirator can be worn in which environments?
a. Dusty
b. Dusty/Chemical
c. Chemical/Moist
d. Moist
e. All of the above
3. A field test is not required eveiy time the seal is broken during usage:
a. True
b. False
4. A field inspection consists of:
a. Inspecting for cracks, wear marks and split rubber.
b. Checking the seals.
c. Checking the face shield.
d. All of the above
5. A half-mask respirator may be worn under the following circumstances:
a. When you are tired of wearing a full-face.
b. On weekends when no one is around.
c. When you have been approved to wear one at the Mines.
d. It is not okay to wear one at the Mill.
6. What may cause an individual to not be able to wear a respirator?
a. Hairy knuckles
b. Facial Hair
c. Bald head
d. All the above
7. Who is responsible for the maintenance of your spectacle kit?
a. The Safety Department
b. Your immediate supervisor
c. Whoever cleans the respirators
d. Me
8. Bioassay samples can indicate if respiratory protection is adequate.
a. True
b. False
9. Once issued a respirator, while in one's working area, it is alright to leave
the respirator outside of the Ziploc bag.
a. True
b. False
10. Who may issue a respirator?
a. Any supervisor.
b. I can check out my own respirator.
c. A member of the Radiation Safety Department.
d. My direct supervisor •
Rev 02/02/18
Name Date
Radiation Protection Quiz 2020
Select the correct answer from the possible choices.

1. What is the annual regulatory dose limit for radiation workers:
a. 500 rems
b. 50 rems
c. 5 rems
d. 0.5 rems

2. What is a good recommendation to decontaminate a person's skin:
a. Scrub vigorously
b. Wash normally with soap and water
c. Rinse with diluted sulfuric acid
d. High pressure air

3. An area posted as "Caution Radiation Area" means:
a. Airborne uranium concentrations are above 25% of DAC.
b. You must wear a respirator.
c. Beta-Gamma Values are at or above 5 mrem/hr.
d. None of the above.

4. The ways to reduce worker's exposure to gamma radiation are:
a. Decrease time.
b. Increase distance.
c. Shielding.
d. All of the above.

5. An area posted as "Caution Airborne Radioactivity Area" means:
a. Airborne uranium concentration is above 25% of DAC.
b. Beta-Gamma levels are at or above 2 mrem/hr.
c. You must wear a respirator when you work in the area.
d. Both A and C.
e. None of the above.
' 4 '
6. Which of the following forms of radiation travels the shortest distance in
air:
a. Alpha
b. Beta
c. Gamma
d. They all travel about the same
7. Chewing tobacco in the Restricted Area is alright when,
a. You scan your fingers before you pinch one off.
b. If you have someone else put it in for you.
c. It is never okay.
d. If you don't get caught.
8. External exposures to radiation are monitored by which of the following:
a. Alpha scanning at the exit points
b. Visiting the doctor on an annual basis
c. Bioassay sampling
d. OSLs
9. In an emergency situation, measures to save the use of a person's limb take
precedence over contamination considerations?
a. True
b. False
10. Bioassay samples are analyzed for
a. Marijuana
b. Cocaine
c. Uranium
d. All of the above
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
2020 Training Schedule for Energy Fuels Resources, White Mesa Mill 42-01429
Date Topic Instructor
January 21,23,24, 27 ----Mandatory Health and Safety Standards / 1977 Mine Act Wayne Palmer
February 21,24,25,28 ---- Radiation and Respiratory Protection Terry Slade
March 17,19,20,23 ---- Accident Prevention Wayne Palmer
April 17,20,22,24 ----First Aid Abel Mendoza / WP
May 15,18,20,22 ---- Hazcom WP
June No Set Topic will hold only if needed
July 21,23,24,27 ---First Aid Abel Mendoza / WP
August 18,20,21,24----Escape, Emergency Evacuation Plan, Fire Warning WP
September 18,21,23,25 ----Electrical Hazard Elect. Depart.
October 13,15,16,19----Transportation Controls, Communication Systems, Ground Control... WP
November 16,18,20,30----Emergency Medical Procedures
December No Set Topic
Each training session will be held in the Lunch Room starting at 7: 00 A.M.
No new employee training scheduled
No Contractors are scheduled.
Abel Mendoza / WP
Person Responsible for training is Wayne Palmer, Safety Coordinator. 435-678-2221 ext. 107 or email
[e-mail].
ENERGY FUELS
White Mesa Mill Da11/7/13 Revision: EFR 3.1
Book #13 Training Manual 91 of 101
CONTRACTOR SAFETY RULES
Contractor shall be responsible for compliance with all local, State, Federal and Company safety,
health and environmental laws and regulations in effect. Contractor shall also be held to
understand that this site is a State of Utah Division of Radiation Control licensed facility and is
governed by the rules and regulations of the Owner, State of Utah DRC and MSHA. Owner
requires that all work conducted by Contractor and its employees be perfonned in a responsible
manner with special attention and mutual cooperation on the part of everyone involved including
Contractor, its employees and the employees of the Owner.
As part of its Contractual obligation, Contractor and its employees are expected to abide by all
applicable safety rules. Mandatory, (MSHA, OSHA, State or Company, etc.) safety and health
training must be received by all workers prior to starting any work on site. The rules listed
below are minimum basic Owner Safety Rules and Regulations; they do not in any way contain
every necessary rule. If the Contractor has questions concerning Safety Rules and Regulations,
Contractor shall consult with Owner's Representative before starting work.
The fact that other applicable rules, regulations or requirements (Federal, State or local) are not
printed herein will not be an excuse for any violation. Any violations of these rules and
regulations be it accidental or intentional may be cause for termination of this contract.
OWNER SAFETY RULES AND REGULATIONS
I. TRAINING
All contract employees must receive the training required by Owner prior to starting
work on site.
II. PERSONNEL PROTECTION
Hardhats, safety glasses, identification badges and steel toe shoes will be required
when entering the mill area. Whenever, work is performed in an environment, which
requires special protection, such as respirators, hearing protection, goggles or face
shield, wet suits, etc. this protection must be worn. If there is a question as to
whether this special equipment is required, contact the Owner's Representative.
Persons with hair that extends longer than two (2) inches below the tee shirt collar
must confine the hair.
White Mesa Mill Date: 411103 Revision: EFR 3.1
Book #13 Training Manual 92 of 101
If respiratory protection is required a respirator fitness physical and fit test are
required. Any question regarding this subject shall be directed to the Owners
Representative.
Appropriate fall protection shall be worn at locations where there is a danger of
falling and/or where required by Owner.
III. RADIATION PROTECTION
The White Mesa Mill has a radioactive materials license with the State of Utah
Division of Radiation Control. Under that license, there are certain items that must be
observed by all parties on site. Those are, but not limited to:
a. Eating, drinking and chewing are only authorized in desigiated areas. These
areas are determined and posted by the Radiation Safety Officer. Potentially
contaminated PPE is not allowed in these areas.
b. All personnel, equipment and vehicles that enter into the restricted area, must be
surveyed for radiological release prior to leaving the restricted area. All mobile
equipment must travel through the decontamination wash station before being
presented for release from the site.
c. Before work assignments commence, the Contractor must present their job
assignment to the Radiation Department. The Radiation Department will
determine exposure potential and will issue a Radiation Work Permit if
applicable.
d. All Contractor personnel must submit to periodic bioassay monitoring for the
determination of potential uptake or ingestion of uranium.
e. Respiratory protection may be needed if there is determined that an area is
contaminated. If respiratory protection is required, the Contractor will provide
medical clearance for their personnel. Respiratory devices will only be issued
upon the successful completion of the medical evaluation and onsite respirator fit
testing.
f. Personnel must monitor him or her with the use of an alpha monitoring device
prior to leaving the restricted area. Monitoring locations are under surveillance to
ensure that proper techniques are being applied. Contractor personnel will be
trained in the proper use of these instruments.
g. Failure to comply with these items and others as deemed necessary by the
Radiation Safety Officer will be grounds for immediate termination of services at
the facility.
IV. HOUSEKEEPING AND STORAGE
Debris will not be allowed to accumulate. Regular removal to designated areas is a
requirement. Tools, equipment and materials will be stored in a safe and orderly
fashion that minimizes interference with operations or traffic. Upon completion of
the job, Contractor shall remove all construction debris and leave the site neat and
orderly.
White Mesa Mill Datill/13 Revision: EFR 3.1
Book #13 Training Manual 93 of 101
V. FIRE PROTECTION
a. Fire extinguishers are to be provided by Contractor and will be kept immediately
available when burning or welding in areas adjacent to combustible material.
They must not be obtained by removing Owner's extinguishers from established
locations.
b. The White Mesa Mill is a smoke free work place. Therefore smoking is
prohibited in the administration building and the restricted area. It is necessary
however to post areas as no smoking areas wherever flammables are stored.
c. No person shall use open flames within 50 feet of where flammable materials are
stored.
d. Combustible material; i.e., grease, lubricants, flammable liquids, etc. shall not be
allowed to accumulate where they can create a fire hazard.
e. Personnel must be familiar with site emergency procedures; i.e. fire drills
evacuation drills, etc. as instructed by the Owner's Representative.
f. Fire alarm procedures will be provided by Owner's Representative.
g. Flammable liquids (flash points below 100°F) shall not be used for cleaning
purposes.
h. Containers of combustible or flammable liquids shall be bonded and grounded
whenever liquid is being transferred; hose must be in metallic contact during
transfer.
i. Flame pennits will be used where required by Owner's Representative.
j. Flammable or combustible materials must be stored in spill proof containers and
properly labeled.
VI. GENERAL
a. Utilities — Connection to or disruption of service of any utility, such as electricity,
steam, water, gas, etc., requires notice to and approval of Owner's Representative
before action is taken.
b. Alcohol and Drugs — No person will be permitted to work while under the
influence of or in the possession of alcohol or drugs. Persons taking medication
will not be permitted to work if is affects their performance or judgment. A drug
and alcohol testing policy is in place at this facility. All Contractor personnel will
be subject to random and accident investigation samplings.
c. Signs and Warnings — Anytime work is performed which could present a hazard
to others; the area must be roped off or barricaded. All posted signs and other
warnings devices shall be strictly observed.
d. Horseplay — Horseplay will not be tolerated.
e. Eating Areas — Eating, drinking and chewing is permitted only in designated areas
by the Owner.
f. Restricted Area — A radiation survey must be performed on all personnel and
equipment prior to leaving the restricted area. The restricted area consists of all
operational and disposal areas.
White Mesa Mill Date: 3 Revision: EFR 3.1
Book #13 Training Manual 94 of 101
g. All contractors while working on Company property are subject to Energy Fuels
Resources (USA) Inc. Drug and Alcohol Testing Policy. Testing may include
accident investigation, behavioral changes or impaired job performance,
perceived drug or alcohol influence and random testing. A copy of the policy will
be provided for each contracting company.
VII. SPECIAL PROCEDURES
a. Lockout procedures — When work is to be performed on any equipment, tanks and
lines the "Zero Energy" concept will apply.
Each job, which requires lockout must be authorized by Owner's Representative
before any equipment is turned off or locked out. Owner's Representative will
assist Contractor to assure proper lockout procedure is followed.
To assure that the correct drive switch has been locked out; an attempt must be
made to start the equipment before work is started. The assurance can be gained
on interlocked systems by attempting to start the equipment at its local control
station. If this proves satisfactory, push the stop switch again.
Any gas or chemical lines that enter work locations must be blanked or have the
valve locked in the closed position. The valve must be locked or tagged so it can
easily be identified as a Contractor lockout. It will be the responsibility of the
Contractor, to assure lockout knowledge and compliance from their employees.
b. Flame Permits — A flame permit will be required and must be displayed when
welding or torching anywhere a fire hazard exists. A fire extinguisher and a
pressurized water hose must be ready at the job location during all welding and
torching. A person must be standing by and able to watch for any sparks which
could start a fire.
No welding or cutting will be done within 50 feet of fuel storage areas.
c. Confined Space Entry — Whenever work is done that involves entry into tanks,
bins or similar enclosures, a Confines Space Entry Evaluation and Safe Work
Permit will be required.
Other Safe Work Permit area include: working on chemical lines, working on any
high pressure system, operating equipment close to electrical lines or any
hazardous operation as determined by the Site Safety Coordinator.
Where a hazardous or oxygen deficient atmosphere is possible, special
precautions will be needed in addition the normal safety precautions, such as
lockout, air fans, respirators, safety ropes, etc. Safety precautions may be found
in the Safe Work Procedure, which will be furnished by the Owner's
Representative if applicable.
White Mesa Mill Date:013 Revision: EFR 3.1
Book #13 Training Manual 95 of 101
d. Process Lines — Process lines which contain or may have contained hazardous
chemicals or gases can be worked on only with specific approval of the Owner's
Representative.
VIII. MOBILE EQUIPMENT
Equipment will be kept in safe operating condition and be checked frequently. All
equipment must be operated by experienced operators and will be confined to the
work areas or places designated by the Owner's Representative. Drivers must be
licensed if driving on public roads. Speed limits and traffic rules will be observed.
Owner's equipment has the right-of-way. Observe caution, yield to traffic control
signs. Speed limits on property shall not exceed 1 5 mph.
Cranes, power shovels and similar equipment will be directed by a responsible person
on the ground when being moved through congested areas. Special attention must be
paid to overhead wires, piping and other obstructions. (The ten-foot rule must apply)
All suspended loads which are being moved by mobile equipment; i.e., winch truck,
cherry picker, etc., shall be secured with a tagline to prevent it from swinging.
All persons shall ride inside the cab or truck bed; absolutely no one is to ride on the
fenders or running boards. All persons riding in a vehicle shall keep both body and
feet within the protective area of the vehicle frame.
Protruding material that extends (2) feet beyond the rear of the vehicle shall be
flagged.
Operators of gasoline powered vehicles shall stop the engines and place the ignition
in the off position when refueling.
Drilling equipment must not be operated within (50) feet of any energized power line.
IX. HEAVY EQUIPMENT
a. All self-propelled equipment shall have adequate overhead protectors (Roll-over
Protective Structures - ROPS) to insure worker protection.
b. All self-propelled equipment (except wheeled tractor scrapers) shall be equipped
with backup alarms and the alarms must function when equipment is in use. A
second person will be responsible to guide tractor scrappers when scrapers are in
reverse.
c. Buckets, lifts or blades shall be left down when equipment is not in use.
d. Dump truck beds shall be in the down seat position while traveling.
e. No person shall place any part of his/her body under a suspended load. Push,
never pull. A suspended load, thereby keeping one's feet and body in the clear.
Whenever possible, use a device to direct the load.
White Mesa Mill Date: 3 Revision: EFR 3.1
Book #13 Training Manual 96 of 101
f. After a piece of equipment has been down, the operator shall walk around and
inspect the equipment before moving it.
g. Persons shall not get on or off moving equipment.
h. Operators of equipment shall not work under overhanging walls until all safety
precautions have been taken and then only after a Safe Work Permit has been
issued.
i. Travel speed of equipment shall be consistent with road conditions.
X. TOOLS AND EQUIPMENT
Tools and equipment will be kept in safe condition with all safety devices and guards
kept operable. Electrical tools will be provided with gounding protections (separate
ground wire, double insulated and or Ground Fault Interrupter). All portable
electrical lights will be properly guarded. Extension cords hoses; etc. will be kept in
good condition and strung so as not to create a hazard. All electrical devices will be
checked prior to start of work for resistance to ground to insure proper grounding is
provided.
Compressed .gas cylinders will be secured in an upright position. Gauged bottles will
be protected and guarded and shut off when unattended. Hoses and leads will be
checked for leaks prior to each use and repaired or replaced if found defective.
The "quick opening" coupling on compressed air, steam or any other high-pressure
hose must be pinned and whip checked. All bull hose must be securely chained.
XI. EXPLOSIVES AND BLASTING
a. All explosives shall be properly stored per ATF "Table of Distance" as to
distance. The construction of the magazine shall meet the ATF specifications.
b. All magazines shall be licensed.
c. No open flame shall be permitted in or within 1 00 feet of any explosive magazine.
d. Explosives and detonators (primers) shall not be transported together. When
being transported in the same vehicle, they shall be in different compartments,
with appropriate signs on vehicle (see local regulations).
e. All unused explosives and detonators shall be returned to their proper magazine.
f. All blasts shall be properly guarded.
g. Warning signs shall be used to halt use of two way radios during the loading and
blasting cycle when electrical blasting caps are used.
h. For blasting in open pit works, Owner's Representative shall be notified of each
blast prior to the blast. All blasting plans and guarding procedures shall be
approved by the Owner's Representative.
i. All blasting materials and magazines will be removed by Contractor upon
completion of job.
White Mesa Mill DatO/13 Revision: EFR 3.1 Book #13 Training Manual 97 of101
XII. REGULATORY AGENCIES
Code of Federal Regulations specifies that independent contractors will be held
responsible for compliance with all standards. The regulations require that the
independent contractor provide Owner with the following;
a. Contractor's trade name, business address, telephone number, contractor's ID
number for MSHA/OSHA or State and name of person in charge of project.
b. A description of the work to be performed and the place where it will be
performed.
Contractor must provide Owner with the same information for each subcontractor
before each subcontractor begins work on Owner's Work Site.
XIII. ACCIDENT REPORTING
All accidents and/or injuries shall be reported to Owner's Representative
immediately.
XIV. TRAFFIC CONTROL
Only those vehicle authorized by the Owner's Representative will be permitted in the
restricted area. All Contractor vehicles, equipment and personnel will be scanned for
radiological release prior to leaving the restricted area.
XV. MONITORING CONTRACTOR'S EMPLOYEES
Owner may perform certain monitoring on Contractor's employees, from time to
time, to ascertain the exposure of such employees to various substances they may
encounter in the course of their work under Contractor's contract with Owner.
Owner will select the times, the conditions and the equipment to be used for such
monitoring. Owner will conduct such monitoring using its own personnel, but will do
so solely as an agent for the Contractor, and on the Contractor's behalf. Owner's
monitoring may have for the protection and surveillance of the Contractor's
employees and the performance of such monitoring shall not be deemed a waiver by
the Contractor or as an assumption by Owner of such responsibilities.
XVI. ADDITIONS OR CHANGES TO RULES
Additional area restrictions, rules or procedures not defined in the Special Rules, etc.,
will be provided by Owner's Representative or the department supervisor as
necessary and must be observed. Contractor personnel must immediately contact
Owner's Representative if there are any concems about potential hazards or proper
methods before proceeding.
White Mesa Mill Date:013 Revision: EFR 3.1
Book #13 Training Manual 98 of 101
XVII. ARCHAEOLOGICAL DETERMINATION
During the course of any work performed by Contractor, if any archaeological
evidence is discovered, i.e., artifacts or remains, the work must cease immediately
and Contractor must notify the Owner Representative immediately.
XVIII. LIGHTNING
If you hear thunder, lightning is close enough to strike you. Immediately stop what
you are doing and seek safety in a substantial building or metal topped vehicle with
the windows up. In the event that thunderstorm conditions develop, Energy Fuels
Safety Department will notify all on site personnel to seek shelter. Stay in until 30
minutes after you hear the last thunder or until the Safety Department determines it is
safe to resume work activities.
White Mesa Mill Date.13 Revision: EFR 3.1 Book #13 Training Manual 99 of 101
By signing this acknowledgement, each Contractor denotes acceptance of all of the above safety
requirements of this Contract and agreement to abide by all federal, state and local laws and
regulations.
Name: Date:
(Print)
Contractor:
Brief Job Description:
Signature:
White Mesa Mill
Book #13 Training Manual
Date: 113 Revision: EFR 3.1
100 of 101
APPENDIX I
NRC REG. GUIDE 8.13
f
()RAU
This is to certify that
Garrin Palmer
has completed the
200-Hour Applied Health Physics Course
conducted by
the Professional Training Programs of ORAU
This nth day of October, 2019
in Oak Ridge, Tennessee
Glenn Hathaway M.S., Health Physicist
dget A. Smith
Instructor
0 c
Garrin Palmer
Has successfully completed the 24 hour technical short course entitled
Transportation and Packaging of Radioactive Materials
November 14, 2018 - November 16, 2018
This certificate presented in Las Vegas, NV, on November 16, 2018
By Nevada Technical Associates, Inc.
Certificate Number: 1541980999
""".•>
(Ds
,-"'••• •
G arrin Palmer
Has successfully completed the 16 hour technical short course entitled
Radiation Safety Officer Refresher
November 12, 2018 - November 13, 2018
This certificate presented in Las Vegas, NV, on November 13, 2018
By Nevada Technical Associates, Inc.
wlget A. Smith
Instructor
Certificate Number: 541987018
0 c
(1)
< ,
t
<7-7177

0 G
Garrin Palmer
Has successfully completed the technical short course entitled
Refresher Radiation Safety Officer
May 25, 2015 - May 26, 2015
This certificate presented in Las Vegas, NV, on May 26, 2015
By Nevada Technical Associates, Inc.

10.

;;;)

Ken Smith Instructor
Certificate Number: 1432537204

Garrin Palmer (),
0 o'

Has successfully completed the technical short course entitled
Transportation of Radioactive Materials
May 27, 2015 - May 29, 2015
This certificate presented in Las Vegas, NV, on May 29, 2015
By Nevada Technical Associates, Inc.

Ken Smith Instructor

Certificate Number: 1432710006

Garrin Palmer
Has successfully comp feted the technical short course entitted
Transportation and Packaging of Radioactive Materials
November 14, 2012 — November 16, 2012
ghis certificate presented in Las Vgas, Nevada, November 16, 2012
By Nevada Technical- Associates, Inc.
Approval codes for C.E. units are: ASRT 30.5 units: NVZ0146001, AAIIP 32 units: 2008-00-005, ABIII:4.5 units: 08-1362
InstrUctor
• , , f_ . /1 # '
C.. 0
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COMPLIANCE Assu ANCE AssocIAT
Helping Industry Comply with Environmental Regulations
This is to acknowledge that
Garrin Palmer
BLA190806-12750
Certificate verification is available at compliance-assurance.com/certs.php using the last name and 12750
successfully participated in Visible Emissions Evaluation field training and
certification and pursuant to US EPA 40 CFR 60 Appendix A, Reference Method
9, as amended, is certified to evaluate Visible Emissions for a period of six (6)
months from the date of this certification.

Blanding, UT 08/06/2019

Anthony Ferro - Field Manager Location Date
• Compliance Assurance Associates, inc. 682 Orvil Smith Rd, Harvest, AL, 35749. 901-381-9960. compliance-assurance.com
S
ENERGY FUELS
I
and Radiation Control
DEC 2 2 2020
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DEC-2020-02.6265 www.energyfuels.com
December 21, 2020
Sent VIA OVERNIGHT DELIVERY
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4880
Re: Transmittal of the Energy Fuels Resources (USA) Inc. Standard Operating
Procedures, Radioactive Materials License UT 1900479, White Mesa Uranium Mill
Dear Mr. Howard:
The White Mesa Mill Radioactive Materials License ("RML"), Section 9.6, paragraph 2 states:
Up-to-date copies of all operational and non-operational SOPs shall be submitted
electronically to the Director by December 31st of each year.
Pursuant to the RML requirement stated above, Energy Fuels Resources (USA) Inc. ("EFRI") is
submitting a copy of the Standard Operating Procedures ("SOPs") for the White Mesa Mill.
Two CDs containing a word-searchable, electronic version of the SOPs is attached.
If you should have any questions regarding this submission please contact me.
Yours very truly,
Yeetz,/efk&-
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David Frydenlund
Logan Shumway
Scott Bakken
Terry Slade
Garrin Palmer
?:o~
IJ:!Jr;~ERGY FUELS
December 21, 2020
Sent VIA OVERNIGHT DELIVERY
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4880
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Re: Transmittal of the Energy Fuels Resources (USA) Inc. Standard Operating
Procedures, Radioactive Materials License UT 1900479, White Mesa Uranium Mill
Dear Mr. Howard:
The White Mesa Mill Radioactive Materials License ("RML"), Section 9.6, paragraph 2 states:
Up-to-date copies of all operational and non-operational SOPs shall be submitted
electronically to the Director by December 31st of each year.
Pursuant to the RML requirement stated above, Energy Fuels Resources (USA) Inc. ("EFRI") is
submitting a copy of the Standard Operating Procedures ("SOPs") for the White Mesa Mill.
Two CDs containing a word-searchable, electronic version of the SOPs is attached.
If you should have any questions regarding this submission please contact me.
Yours very truly,
-1(41(,iu«
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David Frydenlund
Logan Shumway
Scott Bakken
Terry Slade
Garrin Palmer
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 1
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date A ,I
1 Ore Receivin2 & Grind 7/30/09 A,D,N
Section 1 Introduction EFR-6 5/24/19
Section 2 Ore Receiving EFR-9 5/1/19
Section 3 Grind Circuit EFR-6 5/1/19
Section 4 Start Up Procedures for Grind EFR-6 5/1/19
Circuit
Section 5 Shut Down Procedures for Grind EFR-5 5/24/19
Circuit
Section 6 Emergency Shut Down EFR-4 12/1/12
Procedures for Grind Circuit
Section 7 Shift Inspection -Grind Operator EFR-5 5/1/19
Section 8 Chemicals and Reagents EFR-6 5/1/19
Section 9 Soill/Disoosal Procedures EFR-7 5/1/19
Section 10 Hazards -Ore Receiving, Feed, EFR-5 5/1/19
and Grind Cfrcuit
Section 11 Safety Rules and Procedures EFR-6 5/1/19
Section 12 Radiation Safety Procedures EFR-4 12/1/12
Section 13 Ooerator's Resoonsibilities EFR-4 12/1/12
1 PBL-7 Debris Leach and Trommel Operation RETIRED as of 12/2019 7/30/09 A.D,N
2 Pre-Leach & Leach 7/30/09 A,D,N
Section 1 Introduction EFR-6 5/1/19
Section 2 Pre-Leach Circuit EFR-6 5/1/19
Section 3 Leach Circuit EFR-5 5/1/19
Section 4 Pre-Leach and Leach Start Up EFR-5 5/1/19
Procedures
Section 5 Pre-Leach and Leach Shut Down EFR-4 5/1/19
Procedures
Section 6 Emergency Shut Down EFR-3 5/1/16
Procedures
Section 7 Shift Inspection EFR-4 5/1/19
Section 8 Chemicals and Reagents EFR-5 5/1/19
Section 9 Spill/Disoosal Procedures EFR-5 5/1/16
Section 10 Hazards in Pre-Leach and EFR-4 5/1/19
Leach
Section 11 Safe Job Procedures EFR-3 5/1/19
Section 12 Safety Rules and Procedures EFR-3 5/1/16
Section 13 Radiation Safety Procedures EFR-1 11/1/17
3 CCD 7/30/09 A.D,N
Section 1 Introduction EFR-5 12/4/19
Section 2 CCD Thickeners EFR-4 12/4/19
Section 3 CCD Start Uo Procedures EFR-4 12/4/19
Section 4 CCD Shut Down Procedures EFR-4 12/4/19
Section 5 CCD Emergency Shut Down EFR-3 6/1/16
Procedures
Section 6 CCD Operator -Shift Inspection EFR-4 12/4/19
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 2
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date A.~~~~ ..... ,
Section 7 Chemicals and Reagents EFR-4 5/1/16
Section 8 Spill/Disposal Procedures EFR-5 5/1/16
Section 9 Hazards in CCD Circuit EFR-2 12/1/12
Section 10 Job Procedures EFR-2 12/1/12
Section 11 Safety Rules and Procedures EFR-3 12/1/12
Section 12 Radiation Safety Procedures EFR-3 12/1/12
Section 13 Operator's Responsibilities EFR-3 3/1/14
4 UraniumSX 1/25/12 A.D.N
Section 1 Introduction EFR-5 12/4/19
Section 2 Uranium Solvent Extraction EFR-7 12/4/19
Section 3 Uranium Solvent Extraction Start EFR-5 12/4/19
Uo Procedures
Section 4 Uranium Solvent Extraction Shut EFR-5 12/4/19
Down Procedures
Section 5 Uranium Solvent Extraction EFR-4 5/1/16
Emergency Shut Down Procedures
Section 6 Uranium Solvent Extraction -EFR-3 3/1/14
Shift lnsoection
Section 7 Chemicals and Reagents EFR-4 5/1/16
Section 8 Spill/Disposal Procedures EFR-5 5/1/16
Section 9 Hazards in SX Building EFR-4 12/4/19
Section 10 Reserved
Section 11 Safety Rules and Procedures EFR-5 12/4/19
Section 12 Radiation Safety Procedures EFR-4 12/4/19
Section 13 Operator's Responsibilities EFR-3 12/1/12
4 PBL-8 Eluex EFR-4 5/4/16 9/29/08 A.D.N
5 Yellowcake Precipitation 7/30/09 A,D,N
Section 1 Introduction EFR-5 12/6/19
Section 2 Yellowcake Precipitation -Drying EFR-6 12/6/19
and Packaging Procedures
Section 3 Yellowcake Precipitation Start EFR-6 12/6/19
Up Procedures
Section 4 Yellowcake Precipitation Shut EFR-5 12/6/19
Down Procedures
Section 5 Yellowcake Precipitation and EFR-3 12/6/19
Drying Emergency Shut Down Procedures
Section 6 Yellowcake Precipitation and EFR-5 12/6/19
Drving -Shift Insoection
Section 7 Chemicals and Reagents EFR-6 12/6/19
Section 8 Spill/Disposal Procedures EFR-5 5/1/16
Section 9 Hazards in the Yellowcake EFR-2 12/6/19
Circuit
Section 10 Job Procedures EFR-4 5/1/16
Section 11 Safety Rules and Procedures EFR-3 12/1/12
Section 12 Radiation Safety Procedures EFR-3 12/1/12
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 3
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date A .
Section 13 Operator's Responsibilities EFR-2 12/1/12
6 VanadiumSX 7/30/09 A.D,N
Section 1 Introduction EFR-5 12/9/19
Section 2 Vanadium Solvent Extraction EFR-4 12/9/19
Section 3 Vanadium Solvent Extraction EFR-5 12/9/19
Start Up Procedures
Section 4 Vanadium Solvent Extraction EFR-3 12/1/12
Shutdown Procedures
Section 5 Vanadium Solvent Extraction EFR-3 12/1/12
Emergency Shutdown Procedures
Section 6 Vanadium Solvent Extraction EFR-3 12/1/12
Shift Inspection -Operators Only
Section 7 Chemicals and Reagents EFR-5 5/1/16
Section 8 Hazards in Solvent Extraction EFR-5 12/9/19
Building Uranium and Vanadium SX
Section 9 Job Procedures EFR-3 12/1/12
Section 10 Safety Rules and Procedures EFR-3 12/1/12
Section 11 Radaition Safety Procedures EFR-4 12/1/12
Section 12 Operators Responsibilities EFR-4 12/9/19
7 Vanadium Precipitation 7/30/09 A.D,N
Section I Introduction EFR-3 12/11/19
Section 2 Vanadium Precipitation, EFR-6 12/11/19
Filtering, and Ammonium Metavanadate
Orvin!!
Section 3 Vanadium Precipitation Start Up EFR-4 12/11/19
Procedures
Section 4 Vanadium Precipitation Shut EFR-4 12/11/19
Down Procedures
Section 5 Vanadium Precipitation and EFR-4 12/11/19
Filtering -Emergency Shut Down
Procedures
Section 6 Vanadium Precipitation -Shift EFR-5 12/11/19
Inspections
Section 7 Chemicals and Reagents EFR-5 5/1/16
Section 8 Hazards -Vanadium EFR-3 12/1/12
Precioitation
Section 9 Job Procedures EFR-3 12/1/12
Section 10 Safety Rules and Procedures EFR-3 12/1/12
Section 11 Radaition Safety Procedures EFR-4 12/1/12
Section 12 Ooerators Responsibilities EFR-3 12/1/12
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 4
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date A .
8 Vanadium Fusin2 & Packa2in2 7/30/09 A.D,N
Section 1 Introduction EFR-5 12/17/19
Section 2 Vanadium De-Ammoniating, EFR-5 2/1/16
Fusing and Packaging
Section 3 Vanadium De-Ammoniating, EFR-3 12/1/12
Fusing and Packaging Start Up Procedures
Section 4 Vanadium De-Ammoniating, EFR-3 12/1/12
Fusing and Packaging Shut Down
Procedures
Section 5 De-Ammoniator Fusing Furnace EFR-3 12/1/12
Shut Down Procedures
Section 6 Shift Inspection -Vanadium De-EFR-4 4/1/14
Ammoniating, Fusing and Packaging
Section 7 Chemicals and Reagents EFR-5 5/1/16
Section 8 Hazards -Vanadium Fusing and EFR-4 2/1/16
Packaging
Section 9 Job Procedures EFR-3 12/1/12
Section l O Safety Rules and Procedures EFR-4 4/1/14
Section 11 Radaition Safety Procedures EFR-4 12/1/12
Section 12 Operators Responsibilities EFR-4 2/1/16
9 Radiation Protection Manual
PBL-RP-1 Section 1 -Radiation Monitoring -EFR-15 3/9/20 12/16/10 A,N
Personnel
PBL-RP-2 Section 2 Radiation Monitoring -Area EFR-11 3/6/20 10/1/10 A.N
PBL-RP-3 Section 3 Equipment Calibration EFR-11 12/1/19 12/16/10 A,N
PBL-RP-4 Section 4 -Exposure Calculations and EFR-3 8/1/20 2/25/07 A,N
Record Maintenance
PBL-RP-5 Section 5 -Radiation Work Permits EFR-2 12/6/12 2/25/07 A.N
PBL-RP-6 Section 6 Release Surveys EFR-4 10/1/19 9/14/09 A,N
PBL-RP-7 Section 7 Training and Documentation EFR-1 11/10/20 A,N
10 Performance Based Manual
PBL-1 SERP Procedure R-6 4/1/14 2/25/07 A.N
PBL-2 Intermodal Container Acceptance, R-8 12/12/18 7/24/02 A,D,N
Handling & Release
PBL-3 Tailings Caoacitv Evaluation R-3 12/17/18 A,N
PBL-4 High Thorium Content Ore Management R-1 7/8/20 Rev 1 A,N
8/17/20
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 5
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date A~~ .. ,...,,.1
PBL-5 Potassium Fluoride (KF) Processing 7/1/13 A,D,N
Node 1 R-1 11/18/15
Node 2 R-1 11/18/15
Node 3 R-3 7 /1/13
Node5 R-3 6/17/13
Node 6 R-3 6/17/13
PBL-6 Retired
PBL-7 Mill Waste Disposal R-3 4/1/14 10/28/08 A,D,N
PBL-9 End Dump Acceptance, Handling & R-4 12/18/18 10/2/02 A,D,N
Release
PBL-10 l le.(2) Bvoroduct Disposal R-3.4 2/1/18 A,N
PBL-11 FMRI and Cabot Processing 10/7/11 A,D,N
Node 1 R-1 12/18/12
Node2 R-1 12/18/12
Node 3 R-1 12/18/12
Node4 R-1 12/18/12
Node 5 R-1 12/18/12
PBL-12 Drum Shred R-0 11/1/13 11/1/13 A,D,N
PBL-13 CaF2 Processing 3/11/11 A,D,N
Node 1 R-2 12/18/12
Node 2 R-2 12/18/12
Node 3 R-2 12/18/12
Node4 R-2 12/18/12
Node 5 R-2 12/18/12
Node6 R-2 12/18/12
Node? R-2 12/18/12
Node 8 R-2 12/18/12
PBL-14 KOH R-1 12/10/14 12/10/14 A,D,N
Node 1 R-1 12/10/14
Node2 R-1 12/10/14
Node 3 R-1 12/10/14
PBL-15 Release and Shipping of Vanadium R-3 4/19/13 7/29/04 A,N
Blacktlake
PBL-16 Dawn Mining R-1 2/2/16 2/19/16 A,N
Node 1 R-1 2/1/16
PBL-17 Calcine Material R-2 12/18/12 2/9/12 A,D,N
Node 1 R-2 12/18/12
Node2 R-2 12/18/12
Node 3 R-2 12/18/12
Calcine Block Flow
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 6
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date Annrov<>I
PBL-18 Re-Gen R-1 12/18/12 4/30/07 A.D,N
Process of Re-Gen Material Flow Diagram 5/9/07
Node 1 R-1 12/18/12
Node2 R-1 12/18/12
Node 3 R-1 12/18/12
Node4 R-1 12/18/12
Node5 R-1 12/18/12
Node6 R-1 12/18/12
Node7 R-1 12/18/12
Node 8 R-1 12/18/12
Node9 R-1 12/18/12
Node 10 R-1 12/18/12
Node 11 R-1 12/18/12
PBL-19 Containerized Alternate Feedstock Material R-3 2/10/17 6/19/18 A,N
Storage
PBL-20 SX Organic Reconditioning R-1 12/18/12 3/3/08 A,D,N
Node 1 R-2 12/18/12
Node2 R-3 12/18/12
PBL-21 UF4 R-2 12/18/12 7/1/09 A,D,N
Node 1 R-2 12/18/12
Node2 R-2 12/18/12
Node 3 R-2 12/18/12
Node4 R-2 12/18/12
Node 5 R-2 12/18/12
Node6 R-2 12/18/12
Node7 R-2 12/18/12
PBL-22 Securitv R-3 12/1/13 2/25/07 A,D,N
PBL-23 SFC Alternate Feed Management R-0 9/25/13 A,D,N
PBL-24 DEHPA SX Process R-1 7/29/20 8/17/20 A,D,N
11 Environmental Protection Manual
Section 1.1 Air Monitoring -Particulate EFR-5 11/18/14 2/25/07 A,N
Radionuclides
Section 1.2 Air Monioring -Radon EFR-5 12/11/18 2/25/07 A,N
Section 1.3 Meteorological Data EFR-4 8/1/14 10/12/10 A,N
Monitoring Plan
Section 1.4 Stack Emission Monitoring EFR-5 12/1/16 10/12/10 A,N
Procedures
Section 2.1 Surface Water Monitoring Plan EFR-3 4/1/14 2/25/07 A,N
& Standard Ooerating Procedures
Section 3.1 White Mesa Mill Tailings EFR2.5 3/31/17 2/25/07 A,N
Management Svstem
Rev. No.: R-61 Energy Fuels Resources (USA) Inc. 7
SOP Master Control List White Mesa Mill
Date of Location of SOP
Book Revision SERP
No. SOP No. DOCUMENT TITLE No. Revision Date A .
Section 3.2 White Mesa Mill Discharge 12.4 12/12/16 A,N
Minimization Technology (DMT)
Monitorinir Plan
Section 3.3 White Mesa Mill Tailings EFR-4 4/1/14 2/25/17 A,N
Management System Dust Minimization
Section 3.4 White Mesa Mill Tailings EFR4 4/1/14 2/25/17 A,N
Management System Tailings Line
Detection
Section 4.1 Surface Soil Monitoring EFR-5 5/1/16 2/25/17 A,N
Section 4.2 Ve,e:etation Monitorinir EFR-3 11/18/14 2/25/17 A,N
Section 4.3 External Gamma Monitoring EFR-3 8/6/14 2/25/17 A,N
Plan and Standard Operating Procedures
Section 5.0 Settlement Monitoring DUSA-2 6/1/11 A,N
Standard Ooeratinir Procedure
Section 5.1 Movement (Displacement) EFR-4 12/1/13 A,N
Monitoring Standard Operating Procedure
PBL-EP-12 Specific Conductivity, pH Meter, and EFR-2 12/1/12 A,N
Temperature Field Instrument Calibration
Standard Operating Procedures
12 ALARA Pro2ram
ALARA Program EFR-4 9/25/19 7/30/09 A,N
13 Trainine: Proe:ram
Training Program EFR 3.5 12/11/19 7/30/09 A,N
14 Resoiratorv Protection Proe:ram
RPP-1 Respiratory Protection Proirram EFR-7 12/4/19 7/30/09 A.N
15 Reserved
16 Emere:encv Response Plan
Emergency Response Plan EFR6.0 5/21/19 A,D,N
17 Retired
18 Retired
19 GWDP Plans and Procedures
GWDP Groundwater Monitoring Quality EFR 7.6 8/22/19 A,N
Assurance Plan (OAP)
S&S Sampling Plan for Seeps and Springs In the EFR2 7/8/16 A,N
Vicinity of the White Mesa Uranium Mill
Rev. No.: R-61 Energy Fuels Resources (USA) Inc.
SOP Master Control List White Mesa Mill
Book
No. SOP No. DOCUMENT TITLE
BAT Cell 4a and 4b BAT Monitoring,
Ooerations and Maintenance Plan
Cont Plan Contingency Plan
BMP Stormwater Best Management Practices
Plan
O&M Operations and Maintenance Plan Nitrate
Pumoin11. Svstem
O&M Operations and Maintenance Plan
Chloroform Pumoing Svstem
TSAP Tailings SAP
SPCC SPCC
Book No. Reference
1. Ore Receiving & Grind
2. Pre-Leach & Leach
3. CCD
4. Uranium Solvent Extraction
5. Yellowcake Precipitation
6. Vanadium Solvent Extraction
7. Vanadium Precipitation
8. Vanadium Fusing & Packaging
9. Radiation Protection Manual
10. Performance Based Manual
11. Environmental Protection Manual
12. ALARA Program
13. Training Program
14. Respiratory Protection Program
15. Reserved
16. Emergency Response Plan
17. Retired
18. Retired
19. GWDP Plans and Procedures
Date of Location of SOP
Revision SERP
No. Revision Date Annrnv<>I
DUSA 2.3 7 /1/11 A,N
DUSA-4 12/1/11 A.N
EFR 1.6 10/14/19 A,N
EFR 2.0 3/21/13 A,N
EFR 2.2 3/21/13 A,N
EFR3 7/8/16 A.N
n/a 10/14/19 A.N
Location Reference
A. White Mesa Mill Central Files
B. White Mesa Mill Manager's Office
C. White Mesa Radiation Safety Officer's Office
D. White Mesa Mill Control Room
E. White Mesa Mill Radiation Technician Office
F. White Mesa Mill Scalehouse
G. Blank
H. White Mesa Mill Process Engineer's Office
I. Blank
J. Blank
K. Mill 1991 License Application
L. Denver 1991 License Application
M. NRC Public Document Room
N. White Mesa Mill (W:) Drive -SOPs Folder-PDF
8
White Mesa Mill -Standard Operating Procedures
Book 1 Section 1
INTRODUCTION
Mill Process
Date: 05/19 Revision: EFR-6
Page 1 of2
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a slurry in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium is recovered from the barren uranium raffinate also utilizing a solvent extraction
circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered, dried,
melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent
extraction control room, vanadium control room, grind circuit below the derrick screens
and in the upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined and implements a personnel
radiation protection program to ensure that operations at the plant are conducted in a safe
and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
Ore Receiving
Date: 5/19 Revision: EFR 9
Page 1 of9
1. Uranium and vanadium ores are received at the White Mesa Mill by truck and trailers.
Truck scales are checked for zero balance at beginning of each shift and during the shift
as needed. Incoming trucks loaded with ore are weighed at the scale house for gross
weight. After the truck has dumped its load of ore, the empty truck and trailers are re-
weighed for a tare weight or an average of previous tare weights is used. Gross weight
minus (-) tare weight equals ( =) net weight of ore received. A weight ticket is made
for each load of ore which records:
a. Gross weight
b. Tare weight
c. Net weight
d. Mine from which ore is shipped
e. Truck and trailer numbers
f. Mill control numbers
g. Stockpile numbers
h. Transportation delivery number (BOL) or tag number
1. Date
2. In addition to the scale weight ticket, an Ore Receipt Slip record is kept recording:
a. Gross weight
b. Tare weight
C. Net weight
d. Truck and trailer numbers
e. Scale ticket number
f. Tag number as needed or required
g. Mine owner
h. Mine name
I. Date
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
Date: 5/19 Revision: EFR 9
Page 2 of 9
3. After a load of ore is dumped, the Scalehouse Operator will take a hand sample of ore
from two different places and put it into a sample bucket. The lid is to be placed tightly
on the sample bucket after each sample is taken to prevent losing moisture from the
ore. Information about the mine, date, and shipment is written on the sample bucket
for each truck load of ore contained in the sample bucket.
After the ore is sampled, the ore can be pushed up into designated stockpiles. The
sample buck is taken to the mill lab to determine moisture content. Percent of moisture
will be calculated and recorded.
4. Procedure to prepare ore sample for moisture calculation:
a. Contents of the ore sample bucket is crushed to approximately minus 3/8 inch.
b. Place an empty five gallon bucket under the jaw crusher. Pour contents of ore
sample bucket through the jaw crusher. The crushed sample will be transferred
from the bucket to an empty drying pan. Put on the scales, tare the empty scale
and then weigh and record the gross weight of the pan and sample. Record on
a Moisture Certificate:
1. Wet weight
2. Pan tare weight
3. Date
4. Sample ID information
5. Lot number
6. Mine from which the ore was received
e. Place the weighted pan of sample in the oven, dry the sample up to 150° C for
approximately 24 hours (no less than 16 hours).
f. After 24 hours, the dried sample is removed from the oven and allowed to cool
for 30 minutes.
g. The cooled sample is then weighed and the percent of moisture calculated as
follows: Wet weight minus(-) dry weight equals(=) moisture loss in grams.
Calculation is as follows: Loss grams divided ( 7) by original weight times (x)
100 = the percent of moisture.
White Mesa Mill -Standard Operating Procedures
Book I Section 2
Date: 5/19 Revision: EFR 9
Page 3 of9
All copies of the Moisture Certificate are turned in with the Ore Receipt Slip for
further distribution. Make sure all information on the Moisture Certificate is correct
and legible. The ore samples are kept for future assay and amenability samples if
needed.
5. When each ore truck driver and reagent truck driver enter the mill area for the first time,
the Scalehouse Operator on duty will give Hazard Training for Ore Delivery Personnel
and Reagent Delivery Personnel. This procedure involves providing the driver with a
typed form. All drivers will be required to read the form and sign and date the
procedure form indicating that they understand and agree to follow Energy Fuels
Resources (USA) Inc. safety rules and procedures while on Company property. The
Scalehouse operator will sign the procedure form as the instructor for Energy Fuels
Resources (USA) Inc. Completed procedure forms are turned in to the Safety
Department for future reference.
Ore Receiving Safety
1. Do not operate loaders near ore trucks dumping ore.
2. Be aware of heavy truck and equipment traffic.
3. Use caution when operating loader on slick and muddy ore pads.
4. Wear eye protection when crushing ore sample.
5. Practice and observe all Energy Fuels Resources (USA) Inc. safety rules.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
Date: 5/19 Revision: EFR 9
Page 4 of9
HAZARD TRAINING FOR ORE DELIVERY PERSONNEL
Revised: May 2019
Welcome to Energy Fuels Resources (USA) Inc.'s White Mesa Mill. In order to assure
your safety while on our property, we would like to acquaint you with the safety rules and
procedures, which you will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking allowed on the property. Eating, drinking, chewing
candy, gum, or tobacco is not allowed in the Mill Restricted Area, which encompasses the
fenced and posted portions of the Mill, due to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is15 mph. Energy Fuels Resources (USA) Inc.'s equipment has the right of way
on the ore pad and Mill roadways.
4. Personnel other than direct employees of the trucking company are not allowed in the Mill
Restricted Area. If the driver has animals or pets, those animals must remain in the cab of the
truck while in the Restricted Area.
5. No person under 18 years of age is allowed in the Mill Restricted Area.
6. Check for potential overhead hazards prior to dumping.
7. Use caution when entering or exiting equipment.
8. At no time are individuals allowed to access the tops of their trailers for any reason while on
EFR's company property.
9. Be aware of the possibility of a truck turning over while dumping. Keep yourself and your
truck clear of this possibility at all times and ensure brakes are set prior to dumping.
10. If ore is hung up in the truck bed, it is not permissible to work in the bed while it is in the dump
position. If it is necessary to get in the bed of the truck to free a hang up, the bed must be
lowered.
11. If the ore is frozen in the truck, it is not permissible to build fires under the bed in an attempt
to thaw it out. Do not use diesel fuel, antifreeze, or other petroleum-based products to prevent
ore from freezing to the trailer.
12. Be aware of slippery conditions on the ore pad during periods of inclement weather.
13. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
Wliite Mesa Mill -Standard Operating Procedures
Book I Section 2
Date: 5/19 Revision: EFR 9
Page 5 of9
14. Do not drink water from any source other than standard drinking fountains.
15. In the event of an incident, notify Mill personnel immediately. Those involved in the incident,
or who witness the incident, need to provide a written statement. Those involved may be
required to give a drug screen sample.
2.0 Radiation Safety
1. All drivers will be required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
These standards will be strictly enforced, and we expect your full cooperation in their
implementation. Failure to abide by these standards may result in denial of entry to the property
or the removal from the property.
Instructor: ____________ _ Date: ___________ _
I have been fully informed of the above standards and agree to abide by them at all times while on
Energy Fuels Resources (USA) Inc. property.
Name: ______________ _ Date: __________ _
Company: ____________ _
Signature: ____________ _
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
Date: 5/19 Revision: EFR 9
Page 6 of9
HAZARD TRAINING FOR SULFURIC ACID DELIVERY PERSONNEL
Revised: May 2019
Welcome to Energy Fuels Resources (USA) Inc.'s White Mesa Mill. In order to assure
your safety while on our property, we would like to acquaint you with the safety rules and
procedures, which you will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck. Approved safety shoes or boots may be required for certain activities.
2. This is a smoke free facility. No smoking allowed on the property. Eating, drinking, chewing
candy, gum, or tobacco is not allowed in the Mill Restricted Area, which encompasses the
fenced and posted portions of the Mill, due to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is 15 mph. Energy Fuels Resources (USA) Inc.'s equipment has the right of way
on the ore pad and Mill roadways.
4. Use caution when entering or exiting equipment.
5. At no time are individuals allowed to access the tops of their trailers for any reason while on
EFR's company property, unless approved fall protection and supporting devices are in place.
6. Respirators should be worn in dusty areas or where posted with signs.
7. Hearing protection should be worn when working around high noise levels.
8. Do not drink water from any source other than standard drinking fountains.
9. Do not look at the flash from welding operations.
10. Personnel other than direct employees of the trucking company are not allowed in the Mill
Restricted Area. If the driver has animals or pets, those animals must remain in the cab of the
truck while in the Restricted Area.
11. No person under 18 years of age is allowed in the Mill Restricted Area.
12. Be aware of slippery conditions on the ore pad during periods of inclement weather.
13. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
14. In the event of an incident, notify Mill personnel immediately. Those involved in the incident,
or who witness the incident, need to provide a written statement. Those involved may be
required to give a drug screen sample.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
15. When unloading corrosive chemicals:
Date: 5/19 Revision: EFR 9
Page 7 of9
a. Full protective equipment is required when working with corrosive chemicals. This
includes protective clothing, gloves, boots, chemical splash goggles, and face shields in
addition to the hard hat.
b. Prior to hooking up to unload, check the emergency eye-wash and shower to assure that
water is available in case of emergency.
c. Ensure that either a member of the Mill staff or another qualified delivery person is present
during the unloading of the shipment.
d. Never exceed 30 psi working pressure when using air pressure to unload trucks.
e. In case of accidents, never remove your protective equipment until it has been thoroughly
washed off under the emergency shower. All incidents must be reported to the Shift
Foreman on duty as soon as possible.
2.0 Radiation Safety
1. All drivers will be required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
These standards will be strictly enforced, and we expect your full cooperation in their
implementation. Failure to abide by these standards may result in denial of entry to the property
or the removal from the property.
Instructor: ____________ _ Date: ___________ _
I have been fully informed of the above standards and agree to abide by them at all times while on
Energy Fuels Resources (USA) Inc. property.
Name: ______________ _ Date: __________ _
Company: _____________ _
Signature: ____________ _
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
Date: 5/19 Revision: EFR 9
Page 8 of9
HAZARD TRAINING FOR REAGENT DELIVERY PERSONNEL
Revised: May 2019
Welcome to Energy Fuels Resources (USA) Inc.'s White Mesa Mill. In order to assure
your safety while on our property, we would like to acquaint you with the safety rules and
procedures, which you will be required to follow while on our property.
General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab
of your truck. Approved safety shoes or boots may be required for certain activities.
2. This is a smoke free facility. No smoking allowed on the property. Eating, drinking,
chewing candy, gum, or tobacco is not allowed in the Mill Restricted Area, which
encompasses the fenced and posted portions of the Mill, due to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is 15 mph. Energy Fuels Resources (USA) Inc.'s equipment has the right of
way on the ore pad and Mill roadways.
4. Use caution when entering or exiting equipment.
5. At no time are individuals allowed to access the tops of their trailers for any reason while
on EFR' s company property, unless approved fall protection and supporting devices are in
place.
6. Respirators should be worn in dusty areas or where posted with signs.
7. Hearing protection should be worn when working around high noise levels.
8. Do not drink water from any source other than standard drinking fountains.
9. Do not look at the flash from welding operations.
10. Personnel other than direct employees of the trucking company are not allowed in the Mill
Restricted Area. If the driver has animals or pets, those animals must remain in the cab of
the truck while in the Restricted Area.
11. No person under 18 years of age is allowed in the Mill Restricted Area.
12. Be aware of slippery conditions on the ore pad during periods of inclement weather.
13. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
14. In the event of an incident, notify Mill personnel immediately. Those involved in the
incident, or who witness the incident, need to provide a written statement. Those involved
may be required to give a drug screen sample.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 2
15. When unloading corrosive chemicals:
Date: 5/19 Revision: EFR 9
Page 9 of9
a. Full protective equipment is required when working with corrosive chemicals. This
includes protective clothing, gloves, boots, chemical splash goggles, and face shields
in addition to the hard hat.
b. Prior to hooking up to unload, check the emergency eye-wash and shower to assure
that water is available in case of emergency.
c. Ensure that either a member of the Mill staff or another qualified delivery person is
present during the unloading of the shipment.
d. Never exceed 30 psi working pressure when using air pressure to unload trucks.
e. In case of accidents, never remove your protective equipment until it has been
thoroughly washed off under the emergency shower. All incidents must be reported to
the Shift Foreman on duty as soon as possible.
Radiation Safety
1. All drivers will be required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
These standards will be strictly enforced, and we expect your full cooperation in their
implementation. Failure to abide by these standards may result in denial of entry to the property
or the removal from the property.
Instructor: ____________ _ Date: __________ _
I have been fully informed of the above standards and agree to abide by them at all times while on
Energy Fuels Resources (USA) Inc. property.
Name: ______________ _ Date: __________ _
Company: ____________ _
Signature: ____________ _
White Mesa Mill -Standard Operating Procedures
Book 1 Section 3
Grind Circuit
Date: 05/19 Revision: EFR 6
Page 1 of 5
The purpose of the grind circuit is to grind ores to the proper size for maximum
leaching, recovery, and accountability of the uranium and vanadium in the ores.
Ore from the ore pad is fed to the grizzly by the feed loader operator. The grizzly
has 20"x20" openings to prevent rocks that are too big from falling into the ore hopper and
plugging the apron feeder. As the ore is dumped on the grizzly, it falls through the 20"
opening into the ore hopper.
The ore hopper has a capacity of 50 tons. From the ore hopper, the ore is fed by a
hydraulic variable speed drive apron feeder to a 54" conveyor belt. The speed of the apron
feeder drive controls the ore feed rate to the 54" conveyor. The conveyor belt drops the
ore on to a vibrating feeder at the intake of the SAG mill. The vibrating feeder feeds the
ore into the semi-autogenous grinding (SAG) mill.
The SAG mill is run by a 700 H.P. electric motor through a gear box and air clutch.
The bearings on the SAG mill are fed a steady flow of oil from a hydrostatic recirculating
oil pump. The oil recirculates through a cooling water jacket. The water flows through
the cooling jacket and discharges into the SAG mill intake. There are sensors on all
bearings to monitor the bearing temperatures and flow of oil to the bearing. The SAG mill
drive clutch will not engage if oil flow is not going through the bearings. If the temperature
gets too high or oil flow to the bearings stop, an alarm on the control panel will sound and
the air clutch will disengage. If the alarm sounds, check the oil pump to be sure it is
running. Shut off ore feed to the mill. Shut down the SAG mill and notify your foreman
immediate I y.
Grease for the ring gear and pinion is pumped by an automatic grease system at the
north side of the SAG mill. Proper function of the grease system can be verified through
a visual inspection port.
All the lubrication to the SAG mill ( oil to bearings and grease to the ring gear and
pinion) is very critical. Do not operate the SAG mill iflubrication is not operating properly.
Notify your supervisor immediately if there are any questions or doubts about the mill
getting proper lubrication.
White Mesa Mill -Standard Operating Procedures
Book I Section 3
Date: 05/19 Revision: EFR 6
Page 2 of5
The SAG mill has lifter plates around the inside and is charged with grinding balls.
The mill rotates, lifting the balls and ore inside the mill with the lifter plates. As the balls
and ore inside the mill rotate to the top of the mill, they fall from the lifter plates back to
the bottom of the mill. When the balls and ore hit the bottom of the mill, the ore is broken
into smaller pieces. The mill continues to rotate breaking up the ore into smaller and
smaller pieces. Water is added to the ball mill at the intake and discharge ends continuously
while the ore is being crushed.
The slurry overflows the discharge end of the mill through grates and a reject
trammel screen, and into the mill discharge sump. If the overflowed slurry has any
oversized ore in it, the oversized ore (rock) is caught in an ore return chute and a stream of
water on the discharge end of the mill washes the oversized ore back into the mill to re-
grind. If the oversized ore is too big for the water stream to wash back into the mill, it will
discharge into a reject hopper. The amount of oversized ore is controlled by the density of
the slurry; if the density is too light or too heavy, there will be an excessive amount of
rejects from the mill. The density of the slurry should run approximately 60% to 70%.
The overflow slurry from the SAG mill discharge sump is pumped through a direct
drive pump to a splitter head tank. The splitter head tank splits the slurry evenly on to
Derrick screens. The Derrick screens have wire type mesh screens that vibrates. As the
slurry is vibrated down the screens, the properly ground slurry drops through the screens.
Any oversized material in the slurry will not drop through the screens and is vibrated down
the screens to a launder and is washed back to the intake of the SAG mill to be reground.
The slurry that drops through the screens flows through a launder and a composite sample
is taken by an auto-sampler. The slurry from the screen underflow sump is pumped to a
head tank and slurry can be diverted to pulp storage tanks by manually controlled valves.
The slurry cut by the grind auto-sampler goes to a sample bucket. Sample buckets
are to be properly tagged with mine name, stockpile number, mill lot number, and date
on the side of the bucket, not the lid. Completed sample buckets are to be tightly lidded.
It is very important that mill lot samples are properly taken. The finished mill lot sample
is sent to the lab for analysis and is used for accountability and ore recovery. After each
White Mesa Mill -Standard Operating Procedures
Book I Section 3
Date: 05/19 Revision: EFR 6
Page 3 of 5
sample has been taken and put in a bucket, the sampler should be washed with water before
starting a new sample.
Mill Lot Sample Equipment
Grind Sampler -Outotec slurry sampler
Variable -the frequency and speed of the cutter can be varied to give an appropriate
volume of sample. The sampler is actuated by compressed air and has an automatic wash
system. The cutter moves through the entire slurry stream at specified time intervals. The
slurry is then directed to a second splitter (stationary grates) to give a final sample.
The pulp tanks are located outside at the east side of the leach and grind building.
Each tank is 35 feet in diameter and 34 feet high and holds approximately 1,000 dry tons
of ore. Each tank has an agitator in it. The agitators are used to keep the slurry mixed so
the sand will not separate from the water. The agitator must be running when slurry is in
the tank or the sand will settle to the bottom and stop the agitator and plug the pre-leach
feed pumps. Minimum free board level on pulp storage tanks is 18".
There is a bag house located northwest of the ore grizzly. The purpose of the
baghouse is to collect dust from the apron feeder area and the 54" conveyor belt. Dust is
sucked through the bag house by a fan on top of the baghouse. The bags inside the
baghouse collect the dust. The bags are shaken periodically to drop the dust they contain.
As the dust drops to the bottom of the bag house, an auger carries it to the 54" conveyor
belt going to the SAG mill.
Do not feed the grizzly or run the apron feed unless the baghouse is operating
properly.
Switches for the baghouse fan and auger are located at the east side of the baghouse.
There is a fan located in the roof above the apron feeder to control radon in the
apron feeder area. This fan is to be running when the SAG mill is operating. The start/stop
switch is located below the baghouse.
Also, there are two (2) wall fans on the bottom floor of the SAG mill. One of the
fans is located at the northeast side of the SAG mill and the other is located on the southeast
side of the SAG mill. There are two (2) exhaust fans: one is located above the vibrating
White Mesa Mill -Standard Operating Procedures
Book 1 Section 3
Date: 05/19 Revision: EFR 6
Page 4 of 5
feeder and one is above the trommel reject screen. These fans are to be run when the SAG
mill is operating. The start/stop switches are located at the fans.
All controls, indicators, readouts, alarms, and start/stop switches for operating the
apron feeder, 54" feed belt, SAG mill, and related pumps are located on the computer in
the control room. The main electrical disconnect panels are located in the MCC room.
Mill Feed Operating Procedure
1. Before operating the loader or haul truck, do your pre-shift inspection.
2. Lubricate the loader and haul truck at the beginning of each shift.
3. Fill out Mobile Equipment Checklist sheet. Any defects must be corrected before
equipment can be used.
4. Obtain ore stockpile name and stockpile number from your shift foreman.
a. Check ore stockpile identification sign to be sure ore stockpile name and
stockpile number correspond with the stockpile name and number obtained
from your shift foreman.
5. Start baghouse dust control equipment, screw conveyor rotary valve and fan.
6. Start apron feeder area exhaust fan.
7. Clean up ore pad at the end of each stockpile. Do not mix ore stockpiles.
8. Clean up grizzly area after each mill lot.
a. Use safety cables and safety belts when cleaning the grizzly.
9. Keep the SAG mill rejects dumped north of the mill building, scraped up and piled
north of the grizzly.
10. Always be cautious of traffic congestion, ore delivery trucks, reagent trucks, mill
vehicles, etc.
11. Good housekeeping is part of your job.
12. Observe safety rules and wear safety equipment at all times.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 3
Gland Seal Water
Date: 05/19 Revision: EFR 6
Page 5 of 5
All ore handling slurry pumps used in the grind, pre-leach, leach, and CCD circuits
require gland seal water to protect the pump drive shaft from abrasive materials being
pumped into the packing gland and damaging the pump drive shaft.
Water is injected under pressure into the packing gland of the pump drive shaft.
The amount of water injected is regulated by a pre-set Dole valve.
Vibrating Feeder
The vibrating feeder feeds ore from the conveyor belt to the SAG mill intake. Any
ore buildup on the vibrating feeder unit will cause the timing of the feeder to be off and not
operate properly.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 4
Start Up Procedure for Grind Circuit
1. Get ore stockpile name and number from Shift Foreman.
2. Record starting belt scale reading on log sheet.
3. Check control computer for alarms.
Date: 05/19 Revision: EFR 6
Pagel of2
4. Start SAG mill motor (motor will warm up to operating temperature while making
circuit checks).
5. Check vibrating screens and vibrating screen lubrication system.
a. Check oil supply bottles for adequate supply of lubrication oil.
6. Check pulp tank levels and the valve settings from pulp head tank to pulp storage tanks.
7. Check ring and pinion gear lubrication barrel to be sure there is an adequate supply of
grease.
8. Check the grind sampler. It should be cleaned with the air and water valves turned to
the on position.
9. Before starting any equipment, make sure all safety guards are in place and area is clear
of personnel.
10. Start grind mill oil circulating and hydrostatic oil pumps, turn on and check water flow
through oil tank heat exchanger. May need to start a few hours before grinding to allow
to heat up.
11. Turn on gland seal water to mill discharge and screen underflow pumps.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 4
12. Turn on air supply valve.
Date: 05/19 Revision: EFR 6
Page 2 of2
13. Turn ring and pinion gear lubrication system switch to automatic position.
14. Start the vibrating "Derrick" screens.
15. Start direct drive pump.
16. Start screen underflow pump.
17. Pump up any water in floor sumps.
18. Turn main mill feed water valve on. If recycle grind water is used, start recycle grind
water feed pump.
19. Engage mill air clutch which will start the SAG mill.
20. Start vibrating feeder.
21. Start apron feeder.
22. Adjust grind water to obtain as high a density as the mill discharge and screen
underflow pumps will pump (typically 67%-70% ).
23. After SAG mill has been running for 15 minutes, put the mill lot sample bucket under
the sampler and start sampler.
24. Good housekeeping is part of your job.
25. Observe all safety rules and wear safety equipment at all times.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 5
Date: 5/19 Revision: EFR 5
Page 1 of 1
Shut Down Procedure for Grind Circuit
1. Clean up all ore around grizzly walls and grate.
2. Empty grizzly and run all the ore off the 54" belt and vibrating feeder.
3. Stop apron feeder, 54" conveyor belt and vibrating feeder.
4. Grind out SAG mill until the SAG mill motor drops to 50 amps.
5. Stop the SAG mill motor.
6. Turn off the ring and pinion gear lubrication.
7. Turn off air supply valve.
8. Stop the SAG mill oil circulating and hydrostatic oil pumps; turn off the oil heat
exchanger cooling water.
9. Turn off the SAG mill grind water.
10. Stop the mill direct drive pump.
11. Stop the screen underflow pump.
12. Turn off the gland seal water to all pumps.
13. Stop the vibrating "Derrick" screens.
a. Check the "Derrick" screens for holes.
15. Stop the grind samplers.
16. Record the ending belt scale reading on the log sheet.
White Mesa Mill -Standard Operating Procedures
Book I Section 6
Emergency Shut Down Procedures for Grind Circuit
1. Stop the apron feeder.
2. Stop the conveyor belt.
3. Stop the vibrating feeder.
4. Stop the SAG mill.
5. Stop the mill discharge pump.
6. Stop the "Derrick" screens.
7. Stop the screen underflow pump.
8. Close all water valves.
Power Outage
1. Close water valves.
Date: 12/12 Revision: EFR 4
Page I of 1
White Mesa Mill -Standard Operating Procedures
Book 1 Section 7
Date: 5/19 Revision: EFR 5
Page 1 of 2
Shift Inspection -Grind Operator
1. Inspect all moving equipment for proper guards and that th~ guards are in place once
per shift.
a. Shut off equipment, lock out, and replace guard if not in place.
2. Inspect eye wash fountain for proper operation once per shift.
a. Repair immediately, if needed.
3. Inspect 54" feed belt condition during the first hour of the shift.
a. Immediately report to your supervisor if a tear is noted or splices are bad.
4. Inspect 54" feed belt tail pulley clearance during the first hour of the shift -ore spillage
around the tail pulley can damage the belt.
a. Notify your supervisor and shut off the belt, lock out, and clean up ore spillage.
5. Inspect the trammel screen and rock return chute every four (4) hours for holes.
a. Notify your supervisor if any are noted.
6. Inspect the "Derrick" screens for holes and leaks at the beginning of the shift.
a. Replace screens as necessary and repair leaks.
7. Inspect the density scales during the first hour of the shift. Calibrations will be done
by the metallurgical department.
8. Inspect vibrating feeder every four (4) hours for ore build up or rocks jammed around
moving parts.
9. Inspect and test 54" feed belt emergency stop cable and switch at the beginning of the
shift.
a. Do Not operate the belt if the emergency stop is not operating properly.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 7
Date: 5/19 Revision: EFR 5
10. Inspect the pulp tank agitators for proper running conditions once a shift.
a. Notify your supervisor if any problems are noted.
Page 2 of2
11. Inspect sulfuric acid lines and valves on top of pre-leach tanks for leaks or seeps every
four (4) hours.
a. Notify your supervisor immediately if any are noted.
12. Inspect roof fans every four (4) hours for proper operation.
a. Notify your supervisor immediately if problems are noted.
13. Inspect all wall and ventilating fans every four (4) hours for proper operation.
a. Notify your foreman if problems are noted.
14. Inspect agitator shafts and props in the pulp tanks for rubber damage each time the ore
slurry is below prop.
a. Notify your supervisor if damage is noted.
15. Inspect the grind sampler every one (1) hour for plugs and proper operating conditions.
a. Unplug immediately if necessary.
b. If the sampler is not operating properly, notify your supervisor immediately.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 8
Date: 05/19 Revision: EFR 6
Page 1 of 6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance break room
and central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the hazards,
spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 8
Date: 05/19 Revision: EFR 6
Page 2 of6
Information Contained on Safety Data Sheets
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Physical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by the
Department of Transportation; also includes the prefix "UN" or "NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal volume
of water; if the specific gravity is less than 1, the material is lighter than
water and will float; if the specific gravity is greater than 1, the material is
heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will stay
low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 8
Date: 05/19 Revision: EFR 6
Page 3 of 6
Vapor Pressure The pressure exerted by the vapor within the container against the sides of
a container. This pressure is temperature dependent; as the temperature
increases, so does the vapor pressure, thus, more of the liquid evaporates
or vaporizes. The lower the boiling point of a liquid, the greater the vapor
pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V.rr.w.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week, without
suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within 30
minutes of exposure, death or irreversible health implications to the person
exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration or
ceiling, not to be exceeded during a 15-minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
White Mesa Mill -Standard Operating Procedures
Book I Section 8
Date: 05/19 Revision: EFR 6
Page 4 of 6
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over but will not continue to burn without the addition of
more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is present.
Limiting concentrations are commonly called the "L.E.L." (Lower
Flammable Explosive Limit) and the "U.E.L." (Upper Flammable
Explosive Limit). Below the lower flammable limit, the mixture is too
lean to burn; above the upper flammable limit, the mixture is too rich to
burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the materi~l react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 8
Date: 05/19 Revision: EFR 6
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the solution.
Strong acids have low pH values and strong bases have high pH values;
the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 8
Date: 05/19 Revision: EFR 6
Page 6 of6
Forthe
Environment
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials are
knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Hazardous Material Data Sheet can be used to collect additional
information of a more specific nature.
Feed and Grind
Some of the major chemicals used in the Feed and Grind process areas are listed as examples:
1. Sulfuric Acid --93 to 95% strength
2. Gear Grease Compound-Surett Fluid 4K
3. Petroleum Lubricating Oil-Spartan EP220
4. Petroleum Lubricating Grease -Ronex MP
White Mesa Mill -Standard Operating Procedures
Book 1 Section 9
Spill/Disposal Procedures
Date: 05/19 Revision: EFR 7
Pagel of l
All spills, no matter the size, shall be reported on an Orange Card and submitted to the
Environmental Coordinator as soon as possible. The Orange Card is in response to a
Stormwater Inspection from October 2011.
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The SDS forms for all chemicals used in Uranium Recovery Operations are
listed, along with an indication of which chemicals have reporting obligations. The
following is an explanation of the actions required of the Mill Operator when dealing with
these chemicals. Without exception, your supervisor will make any required reports. Refer
to Emergency Response Plan for specific details regarding spill procedures.
Resource Conservation and Recovery Act (RCRA)
RCRA regulates the manner in which hazardous materials can be disposed. The specific
requirements will be overseen by the Environmental Department. If you need to dispose
of any chemicals, contact your supervisor for instructions. The containers that held these
products may be disposed of in any trash receptacle if the container has less than 5% left
in the bottom.
Spill Reporting
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity .. A reportable spi'll occurs when the chemical is spilled
on the ground ( earth), as opposed to a spill to a concrete pad, asphalt pad, sump, etc. If a
spill occurs, immediately notify your supervisor. Your supervisor will determine if a report
to an agency is necessary. Your supervisor will make the report, if needed. Do not attempt
to make a report yourself. If there is any doubt, contact your supervisor for advice and
direction.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 10
Haza1·ds -Ore Receiving, Feed, and Grind Circuit
1. Moving Mobile Equipment
a. Ore delivery truck
b. Front end loaders
C. Dump trucks
d. Pickup trucks
e. Water wagon
f. Forklifts
g. Delivery and shipping vehicles
2. Uneven Ground
3. Cleaning Ore Grizzly
4. Moving Conveyor Belts
5. Falling Rocks
6. Dust
7. Noise
8. Cleaning Plugged Feeders and Chutes
9. High Pressure Air Lines -100 psi
10. Overhead Crane
11. Rotating SAG Mill
12. High Pressure Oil Lines
13. Slick Ore Pad Area When Wet
Date: 05/19 Revision: EFR 5
Page 1 of 5
Items listed above can be hazards if not controlled properly. If controlled properly
and to operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book I Section I 0
Hazard Recognition -Scalehouse
1. Hazards
a. Delivery Trucks
b. Ore Haulers
c. Product Haulers
1. Must read and sign Hazard Training Sheet
Date: 05/19 Revision: EFR 5
Page 2 of5
2. Must be issued a hard hat and safety glasses
d. Loaders -Haulage Trucks (Energy Fuels Resources (USA) Inc.)
e. Jaw Crusher and Drying Unit in Bucking Room-Pinch Points -Heat
f. Stockpile Hazards
1. Falling rocks on stockpiles
2. Tripping hazards during sampling operation
3. Radiation hazards from stockpiles
4. Lifting of sample buckets
5. Weather condition considerations
White Mesa Mill -Standard Operating Procedures
Book 1 Section 10
Hazard Recognition -Mill Feed and Stockpiles
1. Hazards
a. Delivery Trucks -Speed Limit of 15 mph.
b. Ore Haulers -Speed Limit of 15 mph.
c. Product Haulers -Speed Limit of 15 mph.
Date: 05/19 Revision: EFR 5
Page 3 of 5
d. Energy Fuels Resources (USA) Inc. equipment has the right of way. BE
A WARE OF ALL PERSONNEL AND TRUCKS IN YOUR AREA.
e. Grizzly
1. Safety belt must be used during work on the grizzly
2. Safety chain must be installed during maintenance work
f. Dust Collection
1. System must be started before ore 1s fed to SAG mill -possible
electrical shock
g. Cleaning of Tunnel
1. Conveyor must be locked out to clean underneath
2. Respirator required -radiation and silica dust
3. Hearing protection must be worn when the dust collection system is
operating
4. Replace guards when finished cleaning
5. The biggest hazard in the tunnel is the moving conveyor
6. Radiation Work Permit will be required if it is determined that there is
a potential for elevated radiation exposure based on an assessment of
the work environment.
h. SAG Mill Area
1. Rotating mill
2. Moving conveyor
3. Vibrating feeder
4. Guards must be in place
5. Falling rocks from the SAG mill feed chute -above vibrating feeder
6. Hot oil system
White Mesa Mill -Standard Operating Procedures
Book 1 Section 10
7. Foaming of #1 pre-leach tank
8. Traffic in north door of mill building
Date: 05/19 Revision: EFR 5
Page 4 of 5
a. Using a forklift to remove rejects -BEWARE OF TRAFFIC
AND PERSONNEL
9. Lifting of sample buckets -using proper lifting techniques
2. Health Hazards
a. Silica and Nuisance Dusts and Mists
b. Hearing Protection
c. Radiation
1. Airborne uranium
2. Radon progeny
3. Beta gamma
White Mesa Mill -Standard Operating Procedures
Book 1 Section 10
Hazard Recognition -SAG Mill Operator
1. Hazards
a. Conveyor
b. Rotating Mill
c. Vibrating Feeder -Apron Feeder
d. Hot Oil System
Date: 05/19 Revision: EFR 5
Page 5 of 5
e. Falling Rock and grinding media from SAG Mill Feed Chute Above Vibrating
Feeder
f. Foaming of #1 Pre-leach Tank
g. Using Forklift to Empty Reject Bin-BE AWARE OF PERSONNEL AND
TRAFFIC in north door of the mill building
h. Acid Lines
1. Steam Lines
j. High Pressure Air Lines
k. Pinch Points
1. Idlers and rollers
2. Head and tail pulley
3. All guards must be in place before running
4. Cleaning up around pumps
1. Overhead Crane During Loading Balls into SAG Mill
m. Overhead Crane During Relining SAG Mill (must be roped off)
n. Overhead Crane Must Not be Used when SAG Mill is Rotating
o. CAUTION -Wet Decks are Slick and Fall Hazard
2. Health Hazards
a. Radiation
1. Radon progeny
2. Airborne uranium
3. Beta gamma
b. Silica and Nuisance Dusts, Mists and Fumes
c. Hearing Protection
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 1 of 13
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages are
general safety rules and safety rules for Ore Receiving, Feed Operator, and Grind.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White Me a
Mill Safety Rules manual.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
GENERAL RULES
Introduction
Date: 05/19 Revision: EFR 6
Page 2 of 13
All safety rules are listed in the White Mesa Mill Safety Manual. However, several
general rules applicable to this process area are described below.
Reporting Unsafe Conditions and Injuries
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor and safety dept. before seeing the doctor.
Personal Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmet&, goggles, gloves and rubber boots. Face shields
and safety belts are required in designated areas and/or while performing certain jobs.
If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 3 of 13
5. The following equipment is required when working on pipelines or vessels when there
is a potential of coming in contact with acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Hair that extends below the T-shirt collar or extends two inches laterally from the head
(on a natural lay) must be contained by a net of other adequate means.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted lifeline is required where there is a danger
of falling four feet or more, except while performing work under the Ladder and
Scaffold section of this manual. This rule applies when going beyond the handrails of
walkways and on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge, for
any of the following safety offenses:
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
1. Violation of any safety rule.
Date: 05/19 Revision: EFR 6
Page 4 of 13
2. Entering the plant while under the influence of alcoholic beverage or drugs or having
them in your possession while in the plant area.
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
5. Removal of company property without specific written authorization.
6. Carrying firearms into the plant area without specific written permission.
7. Giving false information or testimony during an investigation of incidents.
8. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 5 of 13
OPERA TIO NS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical equipment repairs are to be completed by an EFR
approved electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Safety Data Sheets (SDS)
are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected to
determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area. Even
though the respective valve may not be in the operator's area, he or she must know how
to shut off each line in case of an emergency.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
8. Safe operation of conveyors requires that you shall:
Date: 05/19 Revision: EFR 6
Page 6 of 13
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 7 of 13
ORE RECEIVING AND GRIND -SAFETY RULES
Ore Receiving and Sampling
1. Personnel shall stand well clear of trucks when the bed is inclined. Trucks can turn
over and there is always danger from falling rocks. When the dump trucks are
unloading, stand at least 50 feet away.
2. Loader and truck operators should be aware of personnel and equipment entering their
area, but people should be aware that the operator may not see them and, therefore,
should stay clear of the equipment.
3. Axle high berms shall be maintained on all stockpiles driven upon.
4. A Safe Work Permit and a confined space entry permit must be obtained before
entering any bin or hopper. A Radiation Work Permit will be required if it is
determined that there is a potential for elevated radiation exposure.
5. Safety belts and lines must be worn and tied off while working on the grizzly.
6. When sampling loads of ore, be careful not to step on rocks and turn your ankle or fall.
Grind
1. No one shall go into the SAG mill until a Safe Work Permit and Confined Space Entry
Permit have been completed to cover the work to be done. The person entering the mill
must comply with these permits. A radiation work permit will be required if it has been
determined that there is a potential for elevated radiation exposure.
2. If the dust collector is inoperative, notify your supervisor at once.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 8 of 13
3. Spills (i.e., ore, water, grease) must be cleaned up at once and the cause corrected as
soon as possible.
4. All safety guards, including dust hoods, must be replaced before a piece of equipment
is started.
5. A careful inspection shall be made before starting equipment to ensure that all
personnel and obstructions are clear.
6. Entry into the slurry storage tanks shall be covered by a Safe Work Permit and a
Radiation Work Permit.
7. Do not unplug the apron feeder or vibrating feeder by getting in chutes or inside feeders.
If plugs or rocks cannot be removed without getting inside feeders, notify your foreman
before continuing.
Conveyor Belts
1. Conveyor belts are sometimes called "silent killers." Be aware and alert at all times
when working around them.
2. Never attempt to clean conveyor idlers, head, or tail pulleys while the belt is in motion.
Never attempt any work on a conveyor unless the motor is shut off and the lockout
procedure has been followed.
3. Never ride on, cross over or under a moving conveyor. Use walkways and crossovers
that are provided.
4. Know the location of emergency stop cords and how to use them.
White Mesa Mill -Standard Operating Procedures
Book l Section 11
Date: 05/19 Revision: EFR 6
Page 9 of 13
5. Emergency stop cords on all conveyors must be tested for proper operation by the
operator on each shift and a notation entered on the log sheet that the test was
completed. All malfunctions must be reported and repaired before belt is operated.
Never operate the conveyor if the emergency stop cord is not working properly.
6. All guards must be kept in place, except when the conveyor is properly locked out.
7. Remember that a tool can be caught in a pulley or idler so quickly that you will not
have time to let go before it catches you. Be extremely cautious when working around
conveyors.
8. Always wear close fitting clothing that cannot become caught in moving parts.
9. When shoveling clean up material onto a moving conveyor, always face in the direction
of conveyor travel. Never shovel onto a conveyor that is moving toward you.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 10 of 13
MOBILE EQUIPMENT -SAFETY RULES
General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. This needs to be documented on the forms
provided. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no one
is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at the
controls of the equipment.
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Date: 05/19 Revision: EFR 6
Page 11 of 13
11. Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your supervisor
has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required.
Dump Tt·ucks
1. Do not move the truck until the air pressure is built up to normal.
2. Do not overload the truck.
3. Release the parking brake before moving the truck. Use a low enough gear to start the
truck without slipping the clutch.
4. Except to shake out the load, no truck shall be driven until the bed is in the full down
position.
5. Never work under a raised bed of a truck unless it is securely blocked.
6. Park the truck in its designated parking place with the brakes set and engine off.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 11
Front End Loaders
1. No one but the operator is permitted to ride on the loader.
Date: 05/19 Revision: EFR 6
Page 12 of 13
2. Never leave the loader without dropping the bucket to the ground.
3. Do not jump off loaders. Use handrails and steps when getting on or off equipment.
4. When stepping from the loader to the ground, be sure there are no rocks that you could
step on and turn your ankle.
5. Do not strike the dump truck with the loader bucket or wheels.
6. A void spinning or slipping the drive wheels of the loader as much as possible.
7. Do not move loaders equipped with air brakes until the air pressure is built up to
normal.
8. Park the loader out of the way or in the designated parking place with the brakes set
and engine off.
9. Always keep the bucket as low as possible when traveling.
10. When lubricating front end loaders, park the loader on flat ground, bucket down,
parking brake set, and the engine off.
White Mesa Mill -Standard Operating Procedures
Book l Section 11
Operator Procedure for Cleaning Ore Grizzly
Date: 05/19 Revision: EFR 6
Page 13 of 13
1. Safety cables are installed at the north and south sides of the grizzly.
a. One end of the cable is attached to the bin.
b. The other end of the cable is looped so that a safety belt can be attached.
2. Do not work in grizzly area without a properly secured safety belt.
3. Before entering the grizzly area:
a. Park loader approximately 10 feet east of the ore bin with the brake set, bucket
down, and the engine off.
b. Inspect the safety cable to be sure it is attached securely to the grizzly wall.
c. Inspect the safety cable for defects. If defects are seen, do not use the cable -
notify your foreman. Do not work in the grizzly area.
d. Inspect the safety belt and tie rope for defects. Do not use if defects are noted.
e. Put on the safety belt.
f. Attach tie rope on the safety belt to looped end of the safety cable.
g. Check length of the safety cable and tie rope so that if you slip or fall, you will
not fall between the grizzly bars.
4. Clean the grizzly as needed.
5. After cleaning is completed, move out of the ore bin and away from the grizzly and
remove the safety belt.
6. Hang cable away from the area so that the loader will not catch the cable when dumping
ore.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 12
Date: 12/12 Revision: EFR 4
Page 1 of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for ore receiving and grind which,
when followed, will maintain your exposures AL.AR.A. Remember, you are the person
most responsible for controlling your radiation exposure. If the Radiation Safety
Procedures are followed and protective equipment is utilized correctly, your exposure
will be maintained AL.AR.A.
Ore Receiving and Grind Radiation Safety Procedures
1. A.L.A.R.A. Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the AL.AR.A. program shall result in radiation exposures being
maintained to levels as far below any applicable limits of the N.R.C. regulations as is
reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
radiation safety personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as low as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
and continuous reviews of radiation, environmental, and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
White Mesa Mill -Standard Operating Procedures
Book 1 Section 12
Date: 12/12 Revision: EFR 4
Page 2 of 5
initial assessment of the work environment and associated work tasks as related to
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at ore receiving and grind will require a Radiation
Work Permit if is determined that there is a potential for elevated exposure
based on an assessment of the work environment.
1. Ore Receiving
a. Entry into the ore receiving bin for any repairs.
b. Clean up of ore spills in the SAG mill tunnel.
2. Grind
a. Entry into the SAG mill.
b. Any repairs to the discharge or screen underflow sumps.
c. Entry into the pulp storage tanks.
d. Clean up of spills around the pulp storage tanks.
This is not an all-inclusive list of jobs at ore receiving and grind that could require a
Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
White Mesa Mill -Standard Operating Procedures
Book 1 Section 12
Date: 12/12 Revision: EFR 4
Page 3 of 5
As a part of A.LA.RA. practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon progeny concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% D.A.C. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon progeny concentrations above 25%
D.A.C.:
a. SAG Mill Tunnel
b. SAG Mill
c. Pre-leach Area
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Our primary means of control for gamma or beta is limiting time spent in the
radiation area.
b. The ore stockpiles are the only current location within this circuit where
gamma radiation levels have been identified as being at 5 mr/hr.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. At the White Mesa Mill facility, we use only one type of respirator cartridge
for the full-face respirators. The combination cartridge is acceptable for
nuisance dusts, chemical mists and radiological dusts.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 12
5. Radiation Safety Procedures
Date: 12/12 Revision: EFR 4
Page 4 of 5
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of ore spills in the tunnel and
around the SAG mill.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your dosimetry badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while the SAG mill is operating (full-
face respirator).
f. If any of the equipment listed below is not operating, or if there is evidence of
excessive dusting, notify your shift foreman.
1. Baghouse at Grizzly
2. Tunnel Mine Fan
3. Conveyor Drop Fan
4. North Wall Fan
White Mesa Mill -Standard Operating Procedures
Book 1 Section 12
5. East Wall Fan
Date: 12/12 Revision: EFR 4
Page 5 of 5
6. Electrostatic Precipitator in the SAG Mill Control Room
7. RoofFan
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at ore rece1vmg and grind will be taken
every two weeks. Urinalysis samples are utilized to determine the uranium content
contained in the urine of the operator. The frequency of sampling is dependent on the
airborne concentrations and will be changed if airborne levels exceed 25% of the
airborne standards.
To minimize the chance of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing
into your work clothes or reporting to your work location. The samples can
then be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 1 Section 13
Date: 12/12 Revision: EFR 4
Page 1 of 3
OPERATOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate equipment within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
1. If a sample is contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
White Mesa Mill -Standard Operating Procedures
Book I Section 13
Date: 12/12 Revision: EFR 4
Page 2 of3
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building bioassay laboratory.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid ½ hour of
overtime to shower.
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
White Mesa Mill -Standard Operating Procedures
Book 1 Section 13
Date: 12/12 Revision: EFR 4
Page 3 of 3
survey. If the alarm sounds again, contact the Shift Radiation Technician, Radiation
Safety Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and maintained with each piece of equipment. Any
equipment defects must be corrected before equipment is operated. The Mobile
Equipment Check List must be available for inspection at all times.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 1
INTRODUCTION
Mill Process
Date: 05/19 Revision: EFR 6
Page 1 of 1
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, will be fed to the semi-autogenous grinding (SAG) mill. The ground
ore will be stored as a wet pulp in three agitated tanks. The processing stages will
include two-stage acid leaching, followed by the recovery of uranium and vanadium
bearing pregnant solution in a counter-current decantation (CCD) system.
The uranium is recovered from the leach pregnant solution utilizing a
conventional solvent extraction system. Vanadium (when present) will be recovered
from the barren uranium raffinate also utilizing a solvent extraction circuit.
The pregnant uranium strip solution is precipitated with anhydrous ammonia and
the resultant yellowcake is dewatered, dried, and packaged.
The pregnant vanadium strip solution is precipitated with ammonium sulfate,
filtered, dried, and melted to produce a concentrated vanadium black flake for packaging.
Process Controls
A process control panel is provided in the grinding area. Other process control
computers are located in the central control room, SX control room and vanadium control
room.
Energy Fuels Resources (USA) Inc. has outlined, and will implement, an on-
going personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in Code of Federal Regulations Title
10 Energy and the State of Utah regulations.
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 2
PRE-LEACH CIRCUIT
Date: 05/19 Revision: EFR 6
Page 1 of2
The pre-leach circuit is an acid kill circuit. Its purpose is to use the acid in the
acid bearing solution from CCD to leach the uranium and vanadium from the fresh ore.
The pre-leach circuit consists of two pre-leach tanks, cyclone, pre-leach thickener,
clarifier, and pumps and lines for moving solids and solutions between the
aforementioned equipment.
There are two pre-leach tanks with an agitator. The CCD overflow solution is
pumped into the pre-leach tank and is mixed with the ore. The purpose for this is to
neutralize (kill) as much acid as possible and raise the pH in the overflow solution from
CCD. After the pre-leach tank is filled, it overflows into a common pipe that feeds the
cyclone feed pump. The slurry is then pumped through the cyclone separator.
The purpose of the cyclone is to separate the heavy sand from the fines (light,
slimy ore) and the solution in the slurry. As the slurry is pumped into the cyclone, the
centrifugal action causes the heavy sands to drop out the bottom of the cyclone into the
number one leach tank. The fines and solution are spun off the top of the cyclone and
gravity feeds to the head tank of the pre-leach thickener. From the head tank, the fines
and solution gravity feed to the center well of the pre-leach thickener.
At the pre-leach thickener, the fines and solution are treated with a flocculent.
When the flocculent is mixed with the fines and solution, the fines adhere to each other,
which allows the solids to settle faster.
As the fines sink to the bottom of the pre-leach thickener, a rake in the thickener
moves the fines to a cone in the center of the thickener. As the fines are raked to the
cone, they adhere to more fines and get heavier and become thicker. As the fines are
raked to the bottom of the cone, they are pumped to the number one leach tank.
The underflow slurry is weighed before entering the number one leach tank for
density. Density is the ratio of acid solution to ore. If the density of the fines gets too
high (thick due to lack of acid solution), the pump will not move the fines to the number
one leach tank. If the density is too light (too much acid solution), it will dilute the slurry
in the number one leach tank and, if not corrected, dilute the slurry in all seven leach
White Mesa Mill -Standard Operating Procedures
Book 2 Section 2
Date: 05/19 Revision: EFR 6
Page 2 of2
tanks. This, in turn, will cause the use of more acid, steam, and chlorate (which will be
discussed later) to leach the ore. Good density ranges from 53% to 58% with 58%
becoming quite thick. A density scale is located at the number one leach tank feed line to
help determine the pre-leach underflow density.
The translucent green or blue solution then overflows the pre-leach thickener to
the overflow tank and is pumped to the clarifier head tank.
This overflow solution is relatively clear, but still carries some fines. For this
reason, flocculent is added to the clarifier head tank. After the overflow solution and
flocculent are mixed in the head tank, the solution gravity feeds to the center well of the
clarifier.
The clarifier is a thickener like the pre-leach thickener. Any solids that settled to
the bottom of the clarifier are raked into the cone and pumped back to the clarifier head
tank.
The overflow solution from the clarifier now should be free of any particulate or
solid matter. It is then pumped to the SX building.
All pumps and agitators have local start/stop switches. All start/stop controls,
indicator readout, and alarms are located on a control pan on the platform below the
derrick screens, as well as in the Central Control Room. All main electrical disconnect
panels for these pumps and agitators are located in the master control center under the
shift office.
Safety Procedures
The pre-leach circuit is a safe circuit to run. However, as in all circuits in the
mill, no pumps or agitators should be run unless all safety guards are in place. If a safety
guard is missing, do not start the equipment. Call the Shift Foreman. Also, be aware that
there are charged acid and steam lines in the pre-leach area. Check these periodically for
leaks. Report the problem immediately to the Shift Foreman. There are numerous
stairways and steps in the pre-leach area. Care is to be used at all times to avoid tripping
and stumbling on the stairs and steps. Keep walkways clear.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 3
LEACH CIRCUIT
Date: 05/19 Revision: EFR 5
Page 1 of 4
The purpose of the leach circuit is to leach the uranium and vanadium from the
ore by use of acid, heat, and oxidant, as required. This circuit leaches the uranium and
vanadium from the ores that are not leached in the pre-leach circuit.
The leach circuit is made up of seven leach tanks. Each tank has its own agitator,
upcomer, and bypass upcomer. Number seven is the exception and will be discussed
later.
The heavy sands from the cyclone and the underflow solids pumped from the pre-
leach thickener (see "Pre-leach Operating Procedure) go into the top of the number one
leach tank. The slurry is agitated, goes through an upcomer, and then overflows into the
number two leach tank. The slurry is agitated in the number two leach tank, goes through
the upcomer, then overflows to number three. The slurry then goes from number three to
number four and from number four to number five, and so on until it overflows into
number seven. From number seven, it goes to the number one or two CCD mix tank
where it becomes feed for the CCD circuit.
The purpose of the upcomers in the leach tanks is to get the best recovery of the
uranium and/or vanadium by having the longest retention time possible for the slurry in
each leach tank. The upcomer consists of a pipe that connects the bottom of one leach
tank to the top of the subsequent leach tank. As feed slurry is added to the leach tank, the
slurry is forced through the upcomer by the agitator pushing the slurry to the floor and up
the wall of the tank. As the slurry is forced up the upcomer, it overflows the outlet at the
top of the upcomer into the overflow line to the next leach tank where the process is
repeated. This process is completed in each leach tank until the slurry has passed through
all seven tanks and to the CCD circuit.
For optimum leach recovery, certain conditions must exist. The parameters to
achieve these conditions are set by the Mill Metallurgist and/or the Mill Foreman. These
parameters include temperature, free acid, and oxidation or E.M.F.
To maintain the required temperature, which normally runs 80° to 90°C., steam
addition sparges are located in leach tanks one, two, three and five.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 3
Date: 05/19 Revision: EFR 5
Page 2 of 4
The free acid parameter is the parameter that is changed and adjusted more often
than the others. Free acid is maintained by controlled addition of acid to a leach tank. To
maintain the free acid, acid sparges are located in tanks one, two and three. There is a
flow meter on the main acid line to monitor total acid flow in gallons. Normally, the free
acid (measured in grams per liter), is maintained between 80 to 90 grams per liter.
The oxidation parameter (or E.M.F.) is maintained by the use of sodium chlorate.
The oxidation is maintained by controlled addition of chlorate to a leach tank. Sodium
chlorate can also be added to tanks one, two or three. E.M.F. is usually read in milli-volts
and kept between 410 to 460 mv.
If a leach tank needs to by bypassed, it is easily accomplished by using the bypass
upcomer and lines. For example, if number three is to be bypassed, the overflow line
from number two leach tank to number three leach tank is plugged with a blind flange.
The plug (blind flange) is then pulled from the bypass line between the number two leach
tank and number four leach tank. This bypass line is attached to the bypass upcomer and
works the same as the regular upcomer. This lets the slurry flow from the number two
leach tank to number four leach tank. It must be noted that no two leach tanks in
succession can be bypassed at the same time. For example, the number two and number
three leach tanks cannot be bypassed at the same time. The piping does not exist to
bypass two leach tanks at the same time.
As stated earlier, the number seven leach tank is the exception for bypassing leach
tanks. If number seven is to be bypassed, the overflow line from number six to number
seven is plugged. The number six leach tank bypass line is then unplugged, and the
slurry will flow to the number one or two CCD mix tank.
There are no pumps in the leach circuit except for two floor sump pumps ( one is
behind the number one leach tank and one is by the number four leach tank). Each tank
has an agitator. There are local start/stop switches at each agitator and start/stop switches
for the sump pumps and agitators on the pre-leach control panel. Main electrical
disconnects to the lock out these agitators and sump pumps are located in the master
control center under the shift office. The agitators are not to be run if the safety guards
White Mesa Mill -Standard Operating Procedures
Book 2 Section 3
Date: 05/19 Revision: EFR 5
Page 3 of 4
are not in place or if the safety guards need to be repaired. Notify the Shift Foreman if
there is a problem.
Safety Procedures
The leach circuit is a safe area in which to work. There are lines charged with
steam, acid, and sodium chlorate which should be checked regularly. The leach slurry is
typically hot and acidic and needs to be handled with appropriate PPE with guards in
place. Any leaks are to be reported immediately to the Shift Foreman. Keep all
walkways clear of obstructions to avoid tripping hazards.
Gland Seal Water
All ore handling slurry pumps used in the grind, pre-leach, leach, and CCD
circuits require gland seal water to protect the pump drive shaft from abrasive materials
being pumped into packing gland and damaging the pump drive shaft.
Water is injected under pressure into the packing gland of the pump drive draft.
The amount of water injected is regulated by a pre-set dole valve.
Mill Demister System
Gaseous effluents from the pre-leach tanks, leach tanks, yellowcake precip tanks,
and vanadium precip tanks is vented through a fume scrubber demister by means of an
exhaust fan and related duct piping to the atmosphere.
The demister vessel is equipped with a polypropylene mist pad (four inches
thick), C.P.V.C. spray headers, and Teflon spray nozzles. Effluent gaseous are washed
with water being pumped through the sprays by a recycle pump and related piping.
Washing the effluent gases removes 97% to 99% of sulfuric and ammonia mist from the
venting gases before being released to the atmosphere.
Wash water level is maintained in the demister vessel by means of an automatic
water addition system. Contaminated wash water is automatically dumped from the
demister vessel by means of a timer which dumps contaminated water two to three
minutes every one-half hour. If the recycle wash water becomes excessively saturated
White Mesa Mill -Standard Operating Procedures
Book 2 Section 3
Date: 05/19 Revision: EFR 5
Page 4 of 4
with sulfuric and ammonia, fresh water is automatically added and overflows from the
demister vessel until the sulfuric and ammonia in the wash water have dropped to an
acceptable level.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 4
Pre-Leach and Leach Start Up Procedures
1. Get approval from your supervisor to start circuits.
2. Start demister recirculation pump and exhaust fan.
3. Make a safety inspection of all lines and equipment.
a. Inspect acid lines for leaks or seeps.
b. Inspect feed lines for leaks or seeps.
c. Check that agitators are running.
Date: 05/19 Revision: EFR 5
Page 1 of3
d. Inspect agitator drive guards to assure that they are in place and in good
condition.
e. Inspect safety showers and eyewash fountains to be sure they are working
properly.
4. Check levels in all tanks and thickeners for proper operating levels.
a. SX may need to start up and pull levels down before pre-leach feed or CCD
overflow solutions are started.
5. Check temperature, free acid, and E.M.F. of leach tank for proper operating
parameters.
a. If conditions are not at operating parameters, notify your foreman before
starting up.
6. Notify the CCD Operator that you are starting feed.
7. Notify the SX Operator that you want to start feed.
8. When the SX Operator is ready to start up the SX circuit, start solution flow from
clarifier thickener to the SX.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 4
Date: 05/19 Revision: EFR 5
Page 2 of3
Caution: If uranium SX Operator does not start SX when feed solution is pumped
from the clarifier, the extractor will run over and cause a loss of organic and uranium.
9. When the SX Operator is ready to start up, start solution to the pre-leach tanks.
10. Start cyclone feed pump.
11. Start rakes in pre-leach thickener and lower rakes.
12. Start pre-leach thickener underflow pump.
13. Start pre-leach thickener overflow pump to clarifier.
14. Start clarifier overflow pump to SX Feed Tank
15. Start steam to leach tanks.
16. Turn on acid pump and start acid to leach tanks.
Caution: After turning on acid pump, check the acid lines and pump for leaks.
17. Turn on chlorate feed pump and start chlorate.
18. Start feed to pre-leach.
19. After startup is completed, check all lines for leaks.
20. Check that all equipment is operating properly.
a. Agitator drives are not noisy.
b. Agitator drives are not wobbling.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 4
c. Guards are in place and in good condition.
Date: 05/19 Revision: EFR 5
Page 3 of3
21. Check temperature, E.M.F. and free acid parameters, and adjust as necessary.
a. When starting acid to leach tanks, check lines for leaks.
b. If leaks are noted, shut off acid immediately and notify your foreman.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 5
Pre-Leach and Leach Shut Down Procedures
1. Shut off pre-leach feed pump.
2. Shut off acid to number one and number two pre-leach tanks.
Date: 05/19 Revision: EFR 4
Page 1 of 3
3. Bypass CCD overflow solution from pre-leach tanks to pre-leach thickener.
4. Leave agitator running on pre-leach tank.
5. Wash out cyclone feed line to pump. Shut off cyclone feed pump.
6. Pump density in pre-leach thickener down to 1.40 SG or pump pre-leach thickener
underflow until torque is down to O with rakes all the way down.
a. Raise rake and leave rakes turning.
b. Shut off underflow pump.
c. Shut off flocculant.
7. Acid pump should remain on if yellowcake precipitation is still operating.
a. If yellowcake precipitation is shut down, turn acid feed pump off.
8. Close acid valves to all leach tanks.
9. Shut off chlorate to all leach tanks.
a. If vanadium SX is shut down, shut off chlorate pump, wash and drain chlorate
line from leach to pump.
b. If vanadium SX is running, do not shut off chlorate pump -close chlorate
valves to all leach tanks.
10. Shut off steam to all leach tanks.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 5
11. Leave agitators running on all leach tanks.
Date: 05/19 Revision: EFR 4
Page 2 of3
a. Tanks will sand up and agitators will become stuck if they are shut off.
12. Notify CCD Operator that leach is shut down.
13. After overflow has stopped on pre-leach thickener, shut off overflow pump.
14. After clarifier solution level is down two feet from the top of the clarifier, shut off
clarifier overflow pump.
15. Notify uranium SX Operator that flows are shut off.
Pre-Leach and Leach Long-Term Shut Down Procedures
1. Pump all slurry in pulp tanks to leach.
2. If necessary, open man doors to pulp tanks and wash out remaining contents.
3. Close the pulp storage valves and flush the intake of the leach feed pump with water.
4. Run the density out pre-leach thickener while pushing the rakes down. Once the
density is gone then shut the rakes off and close the cone valve on the pre-leach
thickener and flush the pump with water. Be careful as to not use to much water as a
low density in leach will stop the flow from leach #1 to leach #2.
5. Begin to air lift leach tank #1 by putting a 20-foot air lance down the upcomer of the
#1 leach tank. As you open the air up the air pressure will push the leach slurry to the
next tank. Continue this process for all leach tanks. Any residual slurry will be
pumped from the bottom outlet of the leach tank. It is possible to empty leach tanks
by pumping all of the slurry but using air usually makes the process faster.
6. If necessary, each leach door will be pulled, and the inside of the tanks will be
washed out.
7. Pull all the air lances out and wash them off and place them on the 3rd level of the
catwalk to the very north east side of the leach building.
8. Wash all the leach lids off very well. Wash the sides of the leach tanks if needed.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 5
9. Wash the pre-leach tunnel and remove any sands and debris.
Date: 05/19 Revision: EFR 4
Page 3 of3
10. Roll up any air and water hoses and put them away. Wash all the density cups and
put them away.
11. Any rope, trash or other items that no longer have any need should be removed and
thrown away.
12. Remember that any tank you enter will need the appropriate permits and a safety
watch.
13. A total inspection of leach will be done by the Mill Forman and Shifter.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 6
Emergency S.but Down Procedures
1. Shut off pre-leach feed pump.
Date: 05/16 Revision: EFR 3
Page 1 of 1
2. Shut off leach feed pump (pre-leach thickener underflow pump).
3. Shut off acid feed pump.
4. Bypass number one CCD thickener overflow pump.
5. Shut off chlorate feed valves.
6. Shut off steam valves to leach tanks if valves can be shut off safely.
7. Shut off pre-leach thickener floe feed pump.
8. Notify CCD Operator that leach is shut down.
a. If SX feed is to be shut off, notify SX Operator.
b. During shut down, boilers should be operated as conditions require.
9. Raise pre-leach thickener rakes and shut rake drive off.
a. After emergency shut down is completed, continue to stop leach tank flows as
directed by Shift Foreman.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 7
Sbift Inspections
Date: 05/19 Revision: EFR 4
Page 1 of2
1. Check all panel alarms at the beginning of a shift to be sure they are operating
properly. Notify your foreman if all are not working properly.
2. Inspect leach tanks once a shift for seeps or leaks.
a. Report to your foreman immediately if a wet spot, seep, or leak is noted.
3. Inspect safety showers and eyewash fountains during the first hour of each shift for
proper working order.
a. Report to your foreman immedi ately if safety showers or eyewash fountains
are not working properly.
4. Inspect acid lines on a continuous basis for leaks or seeps.
a. If leaks or seeps are noted, shut off acid and report seeps or leaks
immediately.
5. Inspect solution lines on a continuous basis for seeps or leaks.
a. Notify your foreman at once if any are noted.
6. Inspect clarifier thickener once a shift for broken bands and leaks.
a. Notify your foreman at once if any are noted.
7. Inspect pre-leach tanks once a shift for seeps or leaks.
a. Notify your foreman at once if any are noted.
8. Inspect agitator drives each time control samples are taken for irregular operating
conditions such as wobbling, shaking catwalk, etc.
9. Inspect agitators each time control samples are taken to be sure they are running.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 7
Date: 05/19 Revision: EFR 4
Page 2 of2
10. Inspect roof fans for operation twice per shift. If they are not operating and will not
restart, contact your supervisor.
11. Ensure that density scales have been calibrated ( calibration usually will be performed
by metallurgical department).
12. Check the leach demister twice a shift for proper water flow and operating
conditions.
a. Notify your foreman if conditions are not in proper parameters.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 8
Date: 05/19 Revision: EFR 5
Page 1 of6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance office and
central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
Information Contained on Safety Data Sheets
Hazardous Material
White Mesa Mill -Standard Operating Procedures
Book 2 Section 8
Date: 05/19 Revision: EFR 5
Page 2 of6
Shipping Name
DOT Hazard Class
Chemical Name
I.D.Number
S.T.C.C. Number
Physical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
Vapor Pressure
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
White Mesa Mill -Standard Operating Procedures
Book 2 Section 8
Date: 05/19 Revision: EFR 5
Page 3 of 6
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V.ff .W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Other
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15-minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 8
Date: 05/19 Revision: EFR 5
Page 4 of6
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over but will not continue to bum without the addition of
more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 8
Date: 05/19 Revision: EFR 5
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
White Mesa Mill -Standard Operating Procedures
Book 2 Section 8
Date: 05/19 Revision: EFR 5
Page 6 of6
For the
Environment
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Leach and Pre-leach
Some of the major chemicals used in the Leach and Pre-leach process areas are listed as
examples:
1. Sulfuric Acid --93 to 95% strength
2. Chlorate
3. Steam
4. Flocculents
White Mesa Mill -Standard Operating Procedures
Book 2 Section 9
Spill/Disposal Procedures
Date: 05/16 Revision: EFR 5
Page 1 of2
All spills, no matter the size, shall be reported on an Orange Card and submitted to the
Environmental Coordinator as soon as possible. The Orange Card is in response to a
Stormwater Inspection from October 2011.
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The SDS forms for all chemicals used in Uranium Recovery Operations are
listed, along with an indication of which chemicals have reporting obligations. The
following is an explanation of the actions required of the Mill Operator when dealing
with these chemicals. Without exception, your supervisor will make any required
reports. Refer to Emergency Response Plan for specific details regarding spill
procedures.
Resource Conservation and Recovery Act (R.C.R.A.)
R.C.R.A. regulates the manner in which hazardous materials can be disposed. The
specific requirements will be delineated with by the Environmental Department. If you
need to dispose of any chemicals, contact your supervisor for instructions. The
containers that held these products may be disposed of in any trash receptacle if:
1. The container has less than 5% left in the bottom, or
2. The container has been triple rinsed into any mill sump.
Spill Reporting
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity and type of chemical spilled. A reportable spill is
basically when the chemical hits the ground (earth), as opposed to a spill to a concrete
pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your supervisor. Your
supervisor will determine if a report to an agency is necessary. Your supervisor will
make the report, if needed. Do not attempt to make a report yourself. If there is any
doubt, contact your supervisor for advice and direction.
State of Utah Division of Waste Management and Radiation Control (DWMRC)
White Mesa Mill -Standard Operating Procedures
Book 2 Section 9
Date: 05/16 Revision: EFR 5
Page 2 of2
1. The DWMRC must be notified if a spill and/or accident causes more than
$2,000.00 worth of damage or 24 hours of down time. If either of these conditions
exist and is unknown by your supervisor, contact your supervisor immediately. Your
supervisor will make any required reports.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 10
Hazards in Pre-Leach and Leach
1. Concentrated sulfuric acid -93 to 95%
2. Sodium chlorate solution
3. High slurry temperatures -80 to 95° C
4. Concentrated acid solutions
5. High pressure air lines -100 psi
6. High pressure steam lines -100 psi
7. Acid fumes
8. Chlorate fumes
9. Dust
10. Excessive noise when SAG mill is operating
11. Elevated walkways
12. Slippery walkways and stairs
a. Ice and snow during the winter
b. Polyox spill
c. Floe spills
d. Defoamer reagent spills
13. Operation of overhead crane
Date: 05/19 Revision: EFR 4
Page 1 of3
White Mesa Mill -Standard Operating Procedures
Book 2 Section 10
14. High pressure ammonia
15. Ammonia fumes
Date: 05/19 Revision: EFR 4
Page 2 of 3
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
Hazard Recognition -Leach
1. Hazards
a. Sulfuric Acid
1. Hot liquor in tanks
2. Leak detection of tanks
3. Leak detection of lines and valves
b. Steam Lines
1. Insulated
2. Opening and closing valves
3. Valves hot -use of gloves
C. High Pressure Air Lines
1. Caution of valves
2. Whip checks on connections
3. Do not use to blow off clothing
d. Water Lines
1. Open slowly -100 psi
2. Do not use for water fights
e. Safety Belts
1. Leach tank tops
2. Beyond handrail requires safety belt
f. Obstructions in Walkways
1. Hoses
White Mesa Mill -Standard Operating Procedures
Book 2 Section 10
2. Monawet or Mackanate drums
3. Maintenance tools
4. Sample cup -long-handled
g. Overhead Crane
1. Always in use
2. Needs roped off during use
3. Look up when entering mill building
4. Rope off area and check safety latch on hook
h. Ladders
1. Claricone
2. Claricone underflow tunnel
1. Guards
1. Drive units
2. Pumps
j. Health Hazards
Date: 05/19 Revision: EFR 4
Page 3 of3
1. Radon in numbers one and two Pre-leach area -when SAG mill is
running
2. Number seven leach overflow line to CCD
3. Gamma Radiation in SX feed line
4. Acid fumes above leach and pulp storage tanks when adding acid
5. Ear plugs needed when SAG mill is running in numbers one and two
Pre-leach area
6. Respirators
a. "Derrick" screen area
b. When dumping calcium fluoride
k. Decks and Walkways
1. Slippery when wet
2. Slippery when reagents are spilled on walkways and decks
White Mesa Mill -Standard Operating Procedures
Book 2 Section 11
Safe Job Procedures
Date: 05/19 Revision: EFR 3
Page 1 of5
This section covers job procedures for non-daily routine jobs that are performed
in Pre-leach and Leach.
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 11
.Job Procedure for Pumping Out Leach Tanks
Date: 05/19 Revision: EFR 3
Page 2 of5
1. Wear protective equipment: rubber suit, rubber boots, rubber gloves, and splash
goggles.
2. Safe access (ladder or scaffolding) to tank is required.
3. Check drain valve on the leach tank to be sure the valve on the drain is closed.
4. Remove blind flange on the drain valve slowly, loosen each bolt a quarter of a turn
each starting with the bolts on the opposite side of where you are standing. Watch for
any slurry that might come out around the blind flange.
a. If slurry comes out when you loosen the bolts, stop loosening the bolts and let
the slurry drain out. Move away from the blind flange until slurry has stopped
draining.
b. If slurry continues to leak over one minute after it starts draining, notify your
supervisor. Do not attempt to work around the blind flange.
5. If you do not get any slurry when first loosening bolts on the blind flange, continue to
loosen bolts slowly working each bolt a quarter of a turn each time.
a. Be sure the blind flange is coming loose from the valve as you loosen the
bolts so that any slurry can drain out before the bolts are taken completely out.
6. After the blind flange is off the drain valve, hook the pump hose to the drain line.
7. Put bolts in all flange holes and tighten the bolts completely.
8. Remove the blind flange on the leach tank that you will be pumping into using
procedures one through seven above.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 11
Date: 05/19 Revision: EFR 3
Page 3 of5
9. After the pump and lines are hooked to the leach tanks and all hose flange bolts are
checked to be sure they are tight, open valves on the leach tanks slowly while
checking for any leaks at the flanges.
10. Start gland seal water to pump and turn on the pump.
Hazards of the Job
1. Pressure behind the blank due to drain valve leaking.
2. Leaks when taking blanks off of the drains.
3. Acid and heated slurry getting into eyes or on skin.
4. Leaks in hose flanges.
5. Leak at pump glad seal causing spray.
Caution: If you get a splash in your eyes, wash immediately with water for 20
minutes and notify your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 11
Job Procedure for Cleaning Leach Tanks
1. Lock out leach tank agitator.
Date: 05/19 Revision: EFR 3
Page 4 of5
2. Blank off acid, steam, chlorate, and feed lines going into the tank.
3. Bottom man door must be removed before installing the copus blower.
4. Install the copus blower at the top opening with the horn down to put air into the tank.
5. Acquire Radiation Work Permit from the Radiation Department.
6. Acquire Safe Entry Permit from your foreman.
a. Safe Entry Permit is to be administered by you and your foreman.
b. Air in the tank must be checked for fumes and sufficient oxygen.
7. Wear personal protective equipment: splash goggles, rubber suit, rubber gloves, and
rubber boots.
8. Safe access (ladder or scaffolding) to the bottom side door is required.
9. Before entering the tank, check the walls for any build up that could come loose and
fall.
a. If build up is found, clean off build up before entering the tank -clean from
the top of the tank.
10. The foreman will designate a qualified "Safety Watch." No one is to enter the tank
unless a "Safety Watch" is present.
11. Enter the tank through the side man door.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 11
Hazards of the Job
1. Slurry splashing on skin or into eyes.
2. Slipping on slime slurry while standing or walking.
Date: 05/19 Revision: EFR 3
Page 5 of5
Caution: If you get a splash in your eyes, wash immediately with water for 20
minutes and notify your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
Date: 05/16 Revision: EFR 3
Page 1 of 8
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Ore Receiving, Feed Operator, and Grind.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Me a Mill Safety Rule manual
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
GENERAL RULES
Reporting Unsafe Conditions and Injuries
Date: 05/16 Revision: EFR 3
Page 2 of8
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Persona.I Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
c. Rubber gloves and rubber boots
Date: 05/16 Revision: EFR 3
Page 3 of 8
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs, or having them in
your possession while in the plant area.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
Date: 05/16 Revision: EFR 3
Page 4 of 8
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
Date: 05/16 Revision: EFR 3
Page 5 of 8
OPERATIONS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Safety Data Sheets
(SDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
8. Safe operation of conveyors requires that you shall:
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
Date: 05/16 Revision: EFR 3
Page 6 of 8
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
Date: 05/16 Revision: EFR 3
Page 7 of 8
PRE-LEACH AND LEACH -SAFETY RULES
Leach and Thickeners
1. No one shall enter any tank in these circuits without using and complying with a Safe
Work Permit.
2. Protective equipment must be worn when working on acid lines. A Safe Work Permit
is required.
3. Flocculent spills are very slippery and, therefore, a hazard. Spills should be promptly
cleaned up, sanded, or the area blocked off until it is cleaned.
4. Care should be used in opening or closing valves. Valves are to be properly anchored
so that undue strain is not placed on the pipes.
5. Check and log the condition of the eye wash fountains and safety showers during
each shift. Notify your supervisor immediately if they are not working properly.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 12
SAFE WORK PERMIT
Date: 05/16 Revision: EFR 3
Page 8 of 8
Issued by: ___________ Date: ________ Time: ____ _
For Dept.: ___________ In area: ______________ _
Task to be performed: ______________________ _
Permit good until: _________________________ _
Confined space hazard evaluation completed by : ______________ _
REQUIRED PRECAUTIONS
Safety Dept. approval for confined space entry
Relieve vac/pressure
Equipment & lines drained, washed out, and
ventilated
Atmosphere checked for explosion, toxicity, and
oxygen (see Safety Department)
Continuous air monitor
Radiation work permit
Shower and eye wash checked
Drive mechanisms locked out
Chemical and gas inlets locked and blanked
Steam, air, and high volume lines locked
and disconnected
Special zero energy considerations
Openings roped off or guarded
Proper ladder tied off
Ground fault interrupter
Disconnect level indicators, etc.
Class 1 Division 1 explosion proof lights
Proper bonding and grounding of equipment and
material will be verified for permissible OHMS
resistance by a qualified electrician
Fire extinguisher and/or charged hose
Test welding hose for leaks
Qualified safety watch
Stay clear when lifting materials overhead
PERSONAL PROTECTIVE EQUIPMENT
Splash goggles D Face shield D Rubber suit D
Rubber boots O SCBA O F.F. respirator 0
Safety belt & line D Hearing protection D
COMPLETED BY
Latex nitril gloves D
Cartridge type D
Other equipment ____________________________ _
Special instructions
Job completed: Date __________ _ Supervisor __________ _
Reviewed by: Dept. Head ________ _ Safety Department ______ _
White Mesa Mill -Standard Operating Procedures
Book 2 Section 13
Date: 11/17 Revision: EFR 1
Page 1 of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for ore receiving and grind which,
when followed, will maintain your exposures ALARA. Remember, you are the person
most responsible for controlling your radiation exposure. If the Radiation Safety
Procedures are followed and protective equipment is utilized correctly, your exposure
will be maintained ALARA.
Pre-Leach & Leach Radiation Safety Procedures
1. ALARA Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the ALARA program shall result in radiation exposures being maintained
to levels as far below any applicable limits of the NRC regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
radiation safety personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as low as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
and continuous reviews of radiation, environmental, and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
initial assessment of the work environment and associated work tasks as related to
White Mesa Mill -Standard Operating Procedures
Book 2 Section 13
Date: 11/17 Revision: EFR 1
Page 2 of5
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at ore receiving and grind will require a Radiation
Work Permit if is determined that there is a potential for elevated exposure
based on an assessment of the work environment.
1. Pre-Leach
a. Entry into the tanks for any repairs.
b. Clean up of spills in and around the tanks.
2. Leach
a. Entry into any of the Leach tanks.
b. Clean up of spills in and around the seven Leach tanks.
This is not an all-inclusive list of jobs at Pre-Leach and Leach that could require a
Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
As a part of ALARA practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon progeny concentrations are, or at above 25% of
White Mesa Mill -Standard Operating Procedures
Book 2 Section 13
Date: l l/17 Revision: EFR I
Page 3 of 5
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% D.A.C. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon progeny concentrations above 25%
D.A.C.:
a. Pre-leach Area (during grinding operations)
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Our primary means of control for gamma or beta is limiting time spent in the
radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. At the White Mesa Mill facility, we use only one type of respirator cartridge
for the full-face respirators. The combination cartridge is acceptable for
nuisance dusts, chemical mists and radiological dusts.
5. Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of solids in and around the
various tanks of Pre-Leach and Leach.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
White Mesa Mill -Standard Operating Procedures
Book 2 Section 13
Date: I 1/17 Revision: EFR 1
Page 4 of 5
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your dosimetry badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while the Pre-Leach and Leach area if
it has been required for these areas (full-face respirator).
f. If any of the equipment listed below is not operating, or if there is evidence of
excessive dusting, notify your shift foreman.
1. Roof fans
2. Demister
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at Pre-Leach and Leach will be taken every
two weeks. Urinalysis samples are utilized to determine the uranium content
contained in the urine of the operator. The frequency of sampling is dependent on the
airborne concentrations and will be changed if airborne levels exceed 25% of the
airborne standards.
To minimize the chance of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off (two and four days). The sample
White Mesa Mill -Standard Operating Procedures
Book 2 Section 13
Date: 11/17 Revision: EFR 1
Page 5 of 5
containers should be filled after washing your hands and prior to changing
into your work clothes or reporting to your work location. The samples can
then be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 1
INTRODUCTION
Mill Process
Date: 12/19 Revision: EFR 5
Page 1 of2
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a slurry in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium (when present) is recovered from the barren uranium raffinate also utilizing a
solvent extraction circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered,
dried, melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent extraction
control room, vanadium control room, grind circuit below the derrick screens and in the
upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined, and now implements, a
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 1
Date: 12/19 Revision: EFR 5
Page 2 of2
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 2
CCD Thickeners
Date: 12/19 Revision: EFR 4
Page 1 of 3
The purpose of the CCD (Counter-Current Decantation) thickeners is to wash and
separate the uranium, vanadium, and acid solutions from the leached solids before
sending the solids to tailings.
The CCD circuit consists of eight thickeners in series and a tailings pumping
system. Each thickener is equipped with a mix tank, rakes, rake drive with lifting device,
overflow and underflow pumps and piping and flocculent adjustment valve and dilution
box. The pumps and rakes are operated from any of the control computers. The tailings
system consists of the tails box (sump), two tailings pumps (one serves as a backup), and
piping to pump solids to the tailings cells.
To wash and separate the solids, a series of eight thickeners are used. Tailings
return water, SX raffinate or fresh water is used as wash solution for the thickeners. The
CCD thickeners operate with the solids being pumped in series down the circuit from the
number one thickener through the number eight thickener, into a tailings sump, and to
tails. The wash solution is pumped to the number eight thickener and then sequentially to
number seven, and then number six and so forth. The leach solids flow from the
number seven leach tank into the number one or number two thickener mix tank.
Overflow solution from the number two thickener is pumped into the number one mix
tank. As the solids and solution mix together, the solids are washed, and a slurry is
formed in the mix tank. From the mix tank, the slurry overflows into an overflow pipe
and flows to the centerwell of the number one thickener. Flocculent is added to the slurry
as it either enters into the centerwell. The flocculent causes the light solids, called slimes,
to stick to the heavier solids. The solids drop to the bottom of the thickener leaving the
solution on top. The solution overflows a launder into an overflow pump and is pumped
to the pre-leach tank or pre-leach thickener.
Rakes are located at the bottom of the thickeners and, as they turn, the solids are
pushed to the center of the thickener into the thickener cone and are pumped to the
number two thickener mix tank. As the solids are pumped from the bottom of the
thickener, some of the solution is pumped with it. It is important that as little an amount
of the solution is pumped with the solids as possible as the solution contains the uranium,
White Mesa Mill -Standard Operating Procedures
Book 3 Section 2
Date: 12/19 Revision: EFR 4
Page 2 of 3
vanadium, and acid and will be pumped to tails with the solids. Therefore, it is
important to keep the density of the underflow as high as possible to increase CCD
recovery .. Density of the solids should be 45% to 55%, depending on the types of ore
being fed. The density in the thickener underflow is measured by a density scale.
Density is controlled by variable speed pumps on the underflows of the thickeners.
Slowing the pumps down will increase the density in the thickener and speeding the
pumps up will decrease the density.
The solids pumped from the number one thickener underflow to the number two
mix tank is mixed with the overflow solution pumped from the number three thickener,
washing the solids as was done in the number one thickener mix tank. Flocculent is
mixed with the slurry, which overflows into the centerwell of number two thickener
where additional flocculent is added to separate the solids from the solution. The
solution overflows into a launder and is pumped to the number one thickener mix tank
and is used for washing the solids in the number one mix tank. The solids in the number
two thickener are pumped to the number three thickener mix tank where solution from
the number four thickener overflow mixes and washes it.
The solids continue to be pumped down the series of thickeners and is washed in
each thickener mix tank with overflow solution being pumped up the circuit. When the
solids reach the number eight thickener, most of the uranium, vanadium, and acid are
washed out. A sample of the underflow solids from the number eight thickener is taken
every hour as it is pumped to the tailings sump and the composite sample is sent to the
lab for analysis. From the tailing sump, the solids are pumped through the north or south
tailings pumps to tails.
A balanced circuit must be maintained to give maximum washing of the solids
before they are pumped to tails. Ore slurry must move through the eight thickeners at the
same rate as the feed from the number seven leach tank to prevent loading the thickeners
with solids and plugging underflows. Rakes in each thickener have a torque indicator
which indicates if the solids are building up too much. As the solids build up in the
thickener, the torque will raise. Wash solution must be added at a rate to keep solutions
White Mesa Mill -Standard Operating Procedures
Book 3 Section 2
Date: 12/19 Revision: EFR 4
Page 3 of3
moving up the circuit for a good wash and supply the leach clarifier with enough solution
as to maintain proper solution levels.
Each CCD thickener is piped and valved so that any one thickener can be
bypassed for repairs to pumps, rakes, rake drives, etc., without shutting the CCD circuit
down.
Start/stop switches for all pumps and rake drives are located on all of the process
control computers. Main electrical disconnects for all equipment are located in the
Master Control Center located next to the Central Control Room.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 3
CCD -Start Up Procedures
Date: 12/19 Revision: EFR 4
Page 1 of 3
1. Start pond return pump to the number eight thickener mix tank.
2. Start the number eight thickener rake drive and lower the thickener rakes.
3. Fill the number eight thickener with wash solution. When the solution level starts to
overflow the number eight thickener overflow launder, start the number eight
thickener overflow pump. The number eight thickener overflow pumps into the
number seven thickener mix tank.
4. Follow the above procedure to fill thickeners number one through eight with wash
solution.
5. The overflow from number one thickener is pumped to the pre-leach tank and
overflows to the pre-leach thickener and the clarifier thickener. Adjust the pond
return solution flow to maintain a two-foot freeboard level in the clarifier thickener.
6. When the number one thickener is filled with wash solution, start CCD feed from the
number seven leach tank.
a. Open the flocculant feed valve and adjust the flocculant flow to achieve
optimal setting rate.
b. Open the number one thickener cone valve.
c. Turn on the number one thickener underflow pump gland seal water.
d. Continue to fill the number one CCD thickener with the ore slurry from the
number seven leach tank until the number one CCD thickener rakes show
torque in the fully down position.
e. Start the flocculant feed and adjust the flocculant to the number one CCD
thickener.
f. Check the number one thickener underflow density. The density will
normally be maintained at 45% to 55% solids.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 3
Date: 12/19 Revision: EFR 4
Page 2 of3
g. Thickener underflow density can be controlled by speeding up or slowing
down the underflow pump.
7. Continue to advance the ore slurry from the number one thickener through the
number eight thickener in the aforementioned procedure.
8. Start the number eight thickener underflow pump.
9. Turn on the gland seal to the tails pumps.
a. Start the CCD tails pumps. All CCD thickener controls are located on all of
the process control computers. The control computer has a recording chart for
each thickener that records rake torque The control computer has controls for
the overflow and underflow pumps, flocculent pumps, and rake drive controls.
High rake drive torque, high thickener level, and high tails sump level alarms
are also located on the control panel. Numbers one through eight thickeners
have local start/stop controls for the rake drive and rake lift.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 3
Gland Seal Water
Date: 12/19 Revision: EFR 4
Page 3 of 3
All ore handling slurry pumps used in the grind, pre-leach, leach, and CCD
circuits require gland seal water to protect the pump drive shaft from abrasive materials
being pumped into the packing gland and damaging the pump drive shaft.
Water is injected under pressure into the packing gland of the pump drive shaft.
The amount of water injected is regulated by a pre-set dole valve; two to five gallons per
minute is normally required.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 4
CCD -Shut Down Procedures
Date: 12/19 Revision: EFR 4
Page I of2
1. The Leach Operator will shut off the leach feed pump. Ore slurry will continue to
feed the number one thickener until all leach tank levels are down below the overflow
levels.
2. Pump the number one thickener underflow until there is no density with the rakes all
the way down, then:
a. Shut off the flocculant feed pump and blow air through the flocculant lines.
b. Shut off the number one thickener underflow pump.
c. Turn off the underflow pump gland seal water.
d. Raise the thickener rakes.
3. Follow the above procedure until solids are pumped out of the numbers one through
eight thickeners.
4. When the underflow of the number eight thickener is pumped out, bypass the wash
solution to the tails sump. Wash the solids from the tails lines, then:
a. Shut off the wash solution.
b. Shut off the tails pumps.
c. Turn off the gland seal water to the tails pumps.
d. Make a walk-around inspection to make sure all the necessary valves are
closed, and all flows have stopped.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 4
CCD Long-term Shut Down Procedures
After the normal shut down procedures have been followed:
Date: 12/19 Revision: EFR 4
Page 2 of2
1. Continue to run wash solution until sufficient uranium bearing solution has been
purged from the circuit and fed to solvent extraction. Your supervisor will
determine when the circuit is thoroughly purged.
2. Start at #1 CCD thickener and pump the underflows to the tails box until only the
bed remains. Repeat for all thickeners.
3. Beginning in #1 CCD thickener, begin washing the solids to the cone with water
and pump to the tails box. Once the bed is removed from #1, continue to #2, #3,
etc.
a. Make sure to get all proper permits to enter the thickener.
4. Once the beds have been removed from all thickeners, fill each thickener with
water to protect the rubber.
5. Disconnect all gland seal water lines.
6. Make sure none of the thickeners are leaking and all valves are closed.
7. Wash and remove any sands that have accumulated in the CCD impound.
8. A total inspection of CCD will be done by the Mill Foreman and Shifter.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 5
CCD -Emergency Shut Down Procedures
1. Shut off the pond return solution.
Date: 06/16 Revision: EFR 3
Page 1 of 1
2. Shut off the numbers one through eight CCD thickener underflow pumps.
3. Shut off the numbers one through eight CCD thickener overflow pumps.
4. Shut off tailings pumps.
5. Shut off the flocculent pump. Flocculent lines should be blown out during cold
weather, if shut down is to be over 3-4 hours.
6. Shut off the gland seal water to numbers one through eight CCD thickener underflow
pumps.
7. Shut off gland seal water to tailings pumps.
8. Close all underflow and overflow valves on numbers one through eight CCD
thickeners.
9. Raise the rakes in number one through eight CCD thickeners.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 6
CCD Operator -Shift Inspections
Date: 12/19 Revision: EFR 4
Page 1 of2
1. Inspect and calibrate the density scale at the beginning of the shift.
2. Inspect underflow and overflow lines every four hours for leaks.
a. Immediately report to your supervisor if any leaks are noted.
3. Inspect underflow and overflow pumps every two hours for proper operating
conditions and leaks.
a. Report any problems noted to your supervisor.
4. Inspect metal thickeners and head tanks once per shift for leaks.
a. Immediately report to your supervisor if any are noted.
5. Inspect centerwells of all thickeners every four hours for leaks.
a. Immediately report to your supervisor if any are noted.
6. Inspect tailings pumps every two hours for proper operation or leaks.
a. If problems are noted, change to standby tailings pumps and notify your
supervisor.
7. Inspect catwalks and stairs at the beginning of the shift for trip hazards.
a. Clean up if any are noted.
8. Inspect the area once per shift for housekeeping.
a. Clean up areas as needed.
9. Inspect flocculent lines and pumps every two hours for leaks.
a. Notify your supervisor if any are noted.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 6
Date: 12/19 Revision: EFR4
Page 2 of2
10. Inspect safety showers and eye wash fountains at the beginning of each shift for
proper operating conditions.
a. Immediately repair if they are not in good operating order.
b. Do not operate your circuit with faulty safety showers or eye wash fountains -
they could save your eyesight and prevent burns.
c. Immediately notify your supervisor if the showers or eye washes are not
operating properly.
11. Inspect guards on all moving equipment once per shift for condition and if in place.
a. If guards are not in place, shut off the equipment, lock out, and install the
guard(s).
b. Immediately notify your supervisor if a guard cannot be installed or is in bad
condition.
12. Inspect the panel alarm system at the beginning of a shift for proper operating
conditions.
a. Notify your supervisor if the alarms are not operating properly.
13. Check tails sumps every four hours for seeps or leaks.
a. Immediately notify your supervisor if problems are noted.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 7
Date: 05/16 Revision: EFR 4
Page 1 of 6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SOS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance office and
central control room.
The SOS supplies a description of the chemicals and reagents. The SOS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SOS of all chemicals and reagents used in his/her
department, and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
Information Contained on Safety Data Sheets
Hazardous Material
White Mesa Mill -Standard Operating Procedures
Book 3 Section 7
Date: 05/16 Revision: EFR 4
Page 2 of 6
Shipping Name
DOT Hazard Class
Chemical Name
I.D.Number
S.T.C.C. Number
Phv ical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Ch mical Properties
Specific Gravity
Vapor Density
Boiling Point
Mdting Point
Vapor Pressure
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
White Mesa Mill -Standard Operating Procedures
Book 3 Section 7
Date: 05/16 Revision: EFR 4
Page 3 of 6
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V./T.W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Other
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 7
Date: 05/16 Revision: EFR 4
Page 4 of 6
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to burn without the addition
of more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 7
Date: 05/16 Revision: EFR 4
Page 5 of6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
White Mesa Mill -Standard Operating Procedures
Book 3 Section 7
Date: 05/16 Revision: EFR 4
Page 6 of6
Forthe
Environment
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Some of the major chemicals used in the CCD process areas are listed as examples:
1. Flocculents
2. Monowet
3. Gear Grease Compound-Surett Fluid 4K
4. Petroleum Lubricating Oil -Spartan EP220
5. Petroleum Lubricating Grease -Ronex MP
White Mesa Mill -Standard Operating Procedures
Book 3 Section 8
Spill/Disposal Procedures
Date: 05/16 Revision: EFR 5
Page 1 of2
All spills, no matter the size, shall be reported on an Orange Card and submitted to the
Environmental Coordinator as soon as possible. The Orange Card is in response to a
Stormwater Inspection from October 2011.
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The SDS forms for all chemicals used in Uranium Recovery Operations are
listed, along with an indication of which chemicals have reporting obligations. The
following is an explanation of the actions required of the Mill Operator when dealing
with these chemicals. Without exception, your supervisor will make any required
reports. Refer to Emergency Response Plan for specific details regarding spill
procedures.
Resource Conservation and Recovery Act (R.C.R.A.)
R.C.R.A. regulates the manner in which hazardous materials can be disposed. The
specific requirements will be delineated with by the Environmental Department. If you
need to dispose of any chemicals, contact your supervisor for instructions. The
containers that held these products may be disposed of in any trash receptacle if:
1. The container has less than 5% left in the bottom, or
2. The container has been triple rinsed into any mill sump.
Spill Reporting
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity and type of chemical spilled. A reportable spill is
basically when the chemical hits the ground (earth), as opposed to a spill to a concrete
pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your supervisor. Your
supervisor will determine if a report to an agency is necessary. Your supervisor will
make the report, if needed. Do not attempt to make a report yourself. If there is any
doubt, contact your supervisor for advice and direction.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 8
Date: 05/16 Revision: EFR 5
Page 2 of2
State of Utab Division of Waste Management and Radiation Control (DWMRC)
1. The DWMRC must be notified if a spill and/or accident causes more than
$2,000.00 worth of damage or 24 hours of down time. If either of these conditions
exist and is unknown by your supervisor, contact your supervisor immediately. Your
supervisor will make any required reports.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 9
Hazards in CCD Circuit
1. Solutions with high concentration of sulfuric acid
2. Hot solutions and slurries -90°C.
3. Slippery catwalks and steps from flocculent spillage
4. High pressure air lines
5. Elevated walkways
6. Icy walkways, floors, and steps during inclement weather
Date: 12/12 Revision: EFR 2
Page 1 of3
Items above can be hazards if not controlled properly. If controlled properly and to
operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 9
Hazard Recognition -CCD Circuit
1. Hazards
a. Sulfuric Acid Lines
1. Hot solutions in number one CCD
2. Detection of leaks in area
b. Air Lines
1. Open valve slowly
2. Whip checks on hose connections
3. Do not use to blow off clothing
c. Ladders
1. East tails system
Date: 12/12 Revision: EFR 2
Page 2 of3
2. Ladders used on number eight CCD must be tied off
d. Safety Belts
1. Must be worn when outside of handrails
e. Trip and Fall Hazards
1. Hoses in walkway (air and water)
2. Spilled floe
3. Maintenance tools
4. Clean up bottom floor
5. Deck and walkways slippery when wet
6. Matting under control panels
f. Guards
1. Guards must be in place before starting any equipment
2. Do not remove guard on floe mix device during mixing
White Mesa Mill -Standard Operating Procedures
Book 3 Section 9
g. Overhead Crane
1. Lifting of floe
2. Lifting of drums
3. Look up when entering mill building
4. Safety off area -check safety latch on hook
h. Health Hazards
1. Sulfuric acid solutions
Date: 12/12 Revision: EFR 2
Page 3 of3
a. Goggles, rubber suit, and gloves are required when cleaning up
under CCD tanks
2. Density gauges
a. Numbers one through eight CCD underflow lines
b. Density gauge on number seven leach overflow line
3. Gamma radiation in SX feed line
4. All raffinate lines
5. Airborne uranium
6. Radon daughters
7. Silica
White Mesa Mill -Standard Operating Procedures
Book 3 Section 10
JOB PROCEDURES
Date: 12/12 Revision: EFR 2
Page 1 of 1
This section covers job procedures for non-daily routine jobs that are performed
in:
COUNTER-CURRENT DECANTATION (CCD)
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 11
Date: 12/12 Revision: EFR 3
Page 1 of 6
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Counter-Current Decantation (CCD).
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 11
GENERAL RULES
Introduction
Date: 12/12 Revision: EFR 3
Page 2 of 6
All safety rules are listed in the White Mesa Mill Safety Manual. However, several
general rules applicable to this process area are delineated below.
Reporting Unsafe Conditions and Injuries
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 11
Date: 12/12 Revision: EFR 3
Page 3 of 6
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 11
Date: 12/12 Revision: EFR 3
Page4 of6
2. Entering the plant while under the influence of liquor or drugs, or having them in
your possession while in the plant area.
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 11
Date: 12/12 Revision: EFR 3
Page 5 of 6
OPERA TIO NS -SAFETY RULES
General
Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical equipment repairs are to be completed by a Qualified
Electrician.
1. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
2. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
3. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
4. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
5. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
6. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
7. Safe operation of conveyors requires that you shall:
White Mesa Mill -Standard Operating Procedures
Book 3 Section 11
Date: 12/12 Revision: EFR 3
Page 6 of6
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 12
Date: 12/12 Revision: EFR 3
Page 1 of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for pre-leach and leach which, when
followed, will maintain your exposures A.L.A.R.A. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained A.L.A.R.A.
CCD Radiation Safety Procedures
1. A.L.A.R.A. Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the A.L.A.R.A. program shall result in radiation exposures being
maintained to levels far below any applicable limits of the N.R.C. regulations as is
reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
continuous reviews of radiation, environmental and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
White Mesa Mill -Standard Operating Procedures
Book 3 Section 12
Date: 12/12 Revision: EFR 3
Page 2 of 5
initial assessment of the work environment and associated work tasks as related to
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at CCD may require a Radiation Work Permit if
the initial radiological assessment indicates a potential for elevated radiation
exposure:
1. CCD
a. Entry into thickener or head tanks.
b. Cleaning out the sumps.
c. Clean up of spills around and under the thickeners.
This is not an all-inclusive list of jobs at CCD that could require a Radiation Work
Permit, but is intended as a guide.
3. Posting of Specific Areas
As a part of AL.A.RA. practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon daughter concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% D.A.C. The following areas
White Mesa Mill -Standard Operating Procedures
Book 3 Section 12
Date: 12/12 Revision: EFR 3
Page 3 of 5
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon daughter concentrations above 25%
D.A.C.:
a. CCDArea
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. If you are using a respirator with combo cartridges for protection against
nuisance fumes or mists, the chemical concentration of the contaminants must
be less than the limit set by the manufacturer and the oxygen concentration
must be at or above 19.5%.
d. If you are detecting an odor or changing combo cartridges frequently, it is an
indication that the chemical concentration exceeds the chemical cartridge
limits and you should leave the area and notify your supervisor immediately.
5. Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
White Mesa Mill -Standard Operating Procedures
Book 3 Section 12
Date: 12/12 Revision: EFR 3
Page 4 of 5
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your OSL badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas, if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions.
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at CCD will be taken monthly. Urinalysis
samples are utilized to determine the uranium content contained in the urine of the
operator. The frequency of sampling is dependent on the airborne concentrations and
will be changed if airborne levels exceed 25% of the airborne standards.
To minimize the change of contaminating a urine sample, the following practices
should be followed:
White Mesa Mill -Standard Operating Procedures
Book 3 Section 12
Date: 12/12 Revision: EFR 3
Page 5 of5
a. Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing
into your work clothes or reporting to your work location. The samples can
then be placed in the administration building bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 13
Date: 03/14 Revision: EFR 3
Page I of3
OPERA TOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate departments within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
1. If a sample is contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
White Mesa Mill -Standard Operating Procedures
Book 3 Section 13
Date: 03/14 Revision: EFR 3
Page 2 of 3
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be available in the Administration Building.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid ½ hour of
overtime to shower.
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
White Mesa Mill -Standard Operating Procedures
Book 3 Section 13
Date: 03/14 Revision: EFR 3
Page 3 of3
survey. If the alarm sounds again, contact the Shift Foreman, Radiation Safety
Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 1
INTRODUCTION
Mill Process
Date: 12/19 Revision: EFR 5
Page 1 of2
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a sluny in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium (when present) is recovered from the barren uranium raffinate also utilizing a
solvent extraction circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered,
dried, melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent extraction
control room, vanadium control room, grind circuit below the derrick screens and in the
upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined, and now implements, a
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 1
Date: 12/19 Revision: EFR 5
Page 2 of 2
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 2
Date: 12/19 Revision: EFR 7
Page 1 of 4
URANIUM SOLVENT EXTRACTION
The purpose of the uranium solvent extraction circuit is to extract the uranium
from the uranium bearing acid solution produced while leaching ore.
The uranium SX circuit consists of four extractor mixer-settlers: one acid wash
mixer-settler, four strip mixer-settlers, one barren organic tank, one soda ash day tank,
two brine make-up tank, one organic regeneration mixer-settler, one loaded strip tank,
and all associated pumps and piping.
Organic is used in the settlers to extract the uranium from the uranium bearing
acid solution from leach. The organic is a mixture of amine, isodeconal, and kerosene.
Each of the four extractors is designed with an overflow weir, an underflow weir,
a mix tank, and is operated in a counter-current operation. Each extractor has an organic
recycle line with a manually operated control valve. The valves are generally run in a
full open position with the purpose of getting as much organic as possible to contact the
uranium bearing solution. The mixer pulls the organic from the overflow weir of its own
extractor, through the recycle line, and back into the mixer.
Barren organic is pumped from the barren organic tank to the number four
extractor mixer and flows in a reverse order of four, three, two, and one. While the
uranium bearing solution from leach is pumped to the number one extractor and moves in
a forward order of one, two, three, and four. The mixer of each extractor works as a
pump, pulling the organic from one extractor and pulling the uranium bearing solution
from the opposite extractor.
Example: The mixer of the number two extractor pulls organic from the overflow
of the number three extractor and, at the same time, pulls uranium solution from the
underflow of the number one extractor and also pulls extra organic back through the
recycle line.
The mixing process allows the organic to contact the uranium solution, thus
extracting the uranium from the uranium bearing solution and loading it onto the organic.
The uranium bearing acid leach solution pumped from the leach process is
pumped to the mixer of the number one extractor and mixed with the organic. The mixed
White Mesa Mill -Standard Operating Procedures
Book 4 Section 2
Date: 12/19 Revision: EFR 7
Page 2 of 4
material overflows into the main body of the extractor where the organic and the acid
solution are allowed to separate. The organic rises to the top and overflows the overflow
weir to the acid wash settler and the acid solution stays on the bottom and flows through
the underflow weir to the opposite extractor. After the acid solution has flowed through
the four extractors, it will be virtually free of all uranium and becomes barren solution.
The barren solution is then pumped to tailings unless the vanadium circuit is running.
Barren solution that went through the uranium SX that contains vanadium is
pumped to the vanadium solvent extraction circuit to extract the vanadium from the acid
solution.
Organic which has traveled through all four extractors is now loaded with
uranium. The organic is then pulled to the acid wash where it is mixed with water. The
water is maintained at a specified pH and contacted with the loaded organic and washes
out impurities that are considered waste, such as arsenic and iron. The loaded organic
then moves into the stripping circuit.
The brine solution is introduced to the mixer of the number four stripper and
flows in a reverse order of four, three and then to two. When the brine solution reaches
the underflow of the number one stripper, it is loaded with the uranium. The loaded strip
solution is then pumped into the loaded strip holding tank where it is later pumped to the
uranium precipitation circuit.
Each stripper also has a recycle line but, unlike the extractors which recycle the
organic, the strippers recycle the strip solution with the same purpose of more contact
with the organic for maximum stripping of the organic. Each recycle line has a manually
operated valve for control of the strip loading.
The stripped organic coming off of the overflow of the number four stripper can
then be sent to the barren organic holding tank or can be sent into the regeneration vessel.
Periodically, the organic becomes contaminated with minerals and/or properties
which inhibit the extraction process. To clean the organic, it is regenerated by using a
high pH soda ash solution with a small amount of caustic soda. The spent regeneration
solution can be sent to tails or, if the spent solution has a sizable amount of uranium, it
can be pumped back into the extraction circuit. The clean (barren) organic is then
White Mesa Mill -Standard Operating Procedures
Book 4 Section 2
Date: 12/19 Revision: EFR 7
Page 3 of 4
pumped into the barren organic holding tank. The organic can then be pumped back to
the number four extractor and the process can start again.
The caustic soda used in this process is stored in a bulk holding tank outside the
north end of the SX building.
The soda ash is stored in a dry holding bin on the north side of the SX. The dry
soda ash is augured into the mix tank. Then the saturated solution from the mix tank
overflows into the dilution tank. The liquid soda ash is then pumped inside the building
from the dilution tank to be used when needed in the regeneration tank.
The salt is also stored in a holding tank on the north end of the SX building.
Water is added to this tank to make a saturated solution of brine. The saturated brine is
pumped to the barren strip make up tank where it is diluted to a specified gravity with the
overflow solution from the number one yellowcake thickener. Sulfuric acid is added to
the diluted brine solution until a pH of 1.4 is obtained.
Spills in the SX building flow to a sump at the west end of the building and are
pumped back to the circuit.
The controls, start/stop switches, indicators, readouts, and alarms which are
located in both the central and SX control rooms. The power supply, main electrical
disconnects, overhead light switches, and overhead fan switches for all associated
equipment are located in the MCC room on the north side of the SX building.
Safety Procedures
Because of the flash point of the kerosene used in the SX building, the following
rules normally apply:
1. No gasoline driven engines are allowed in the building at any time.
2. No matches, lighters, or any spark producing items are allowed in the building.
3. No cutting, welding, or grinding is allowed in the building.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 2
4. All electric motors used in the SX have to be explosion proof.
Date: 12/19 Revision: EFR 7
Page 4 of 4
5. Should maintenance activities require the use of cutting, welding or grinding devices,
the atmosphere must be monitored for the appropriate hazard and work must proceed
after a safety analysis has been performed.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 3
Uranium Solvent Extraction Start Up Procedures
Date: 12/19 Revision: EFR 5
Page 1 of2
When both of the uranium and vanadium solvent extraction circuits are operating,
both circuits will have to be started up simultaneously to avoid overflowing extractors,
strippers, solution tanks, etc.
1. Notify your supervisor you are ready to start the circuit.
2. Notify the Vanadium SX Operator you are ready to start the feed.
a. Do not start the uranium SX until the Vanadium SX Operator has notified you
he/she is ready to start up.
3. Open the manual and automatic valves and set the SX feed flow on the computer.
4. Start the uranium raffinate pump.
5. Open the automatic lean organic valve, set the flow rate, and start the pump.
6. Start numbers one through four extractor mix tank agitators.
7. Start the acid wash mixer agitator and bleed pump.
8. Start the numbers one through four strip mixer agitators.
9. If the organic regeneration circuit is to be operated, start the organic return pump at
the regeneration settler.
10. Start the barren organic feed pump to the number four extractor mixer.
11. Start the barren strip pump to the number four strip mixer.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 3
12. Start the acid and add water to the acid wash.
13. Start the feed solution from the clarifier to the SX feed tank.
Date: 12/19 Revision: EFR 5
Page 2 of2
If the organic regeneration circuit is operated, start the soda ash pump to the regeneration
settler mixer.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 4
Uranium Solvent Extraction Shutdown Procedures
Date: 12/19 Revision: EFR 5
Page 1 of 2
When both of the uranium and vanadium solvent extraction circuits are operating,
both circuits will have to be shutdown simultaneously to avoid overflowing extractors,
strippers, solution tanks, etc.
1. Shut off the uranium feed pump (clarifier overflow pump).
2. Shut off the organic feed and return pumps.
3. Shut off the extractor, acid wash, stripper, and regen mixer agitators.
4. Shut off the uranium raffinate pump.
5. Shut off the brine strip feed pump.
6. Shut off the acid wash spent solution pump.
7. Shut off the loaded strip pumps (yellowcake precip feed).
a. Loaded strip pumps may have to keep pumping if the loaded strip tank is at a
high level.
8. Close all organic and aqueous advance valves.
9. Close the manual valves upstream of the feed pumps.
10. Flush loaded and barren strip lines with water; drain water from the lines.
a. See step 7a above.
11. Flush soda ash and caustic lines to regen with water; drain water from the lines.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 4
Date: 12/19 Revision: EFR 5
Page 2 of2
12. Make a walk-around inspection to ensure that all valves are shut and the solutions
have stopped flowing.
Power Outages
1. All electrical equipment will shut down.
2. Automatic feed valves will close when the mill air is spent.
3. If the power outage lasts for more than five minutes, close all manual upstream feed
valves and wash out all solution lines as outlined in the shutdown procedures.
SX Long-term Shut Down Procedures
1. Completely empty the clarifier.
2. Completely empty the strip make-up tanks.
3. Completely empty the SX feed tank.
4. Pump all aqueous solution from stripper #1 and #2 to the loaded strip tank.
5. After pumping all of the loaded strip solution to precipitation, flush line with water and drain.
6. Wash the sides and edges of all mixer settlers.
7. Wash and store all sample cups, tubs and graduated cylinders.
8. Make sure all trash, rope and miscellaneous items have been thrown away or stored properly.
9. A total inspection of SX will be done by the Mill Forman and Shifter.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 5
Date: 05/16 Revision: EFR 4
Page 1 of 1
Uranium Solvent Extraction Emergency Shut Down Procedures
1. Shut off the clarifier overflow pump.
2. Shut off the barren organic feed pump.
3. Shut off the organic return pump.
4. Shut off the strip feed pump.
5. Shut off the strip mixer agitators.
6. Shut off water and acid to Acid Wash.
7. Shut off the extractor mixer agitators.
8. Shut off the uranium raffinate pump.
9. Shut off the spent regeneration pump.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 6
Uranium Solvent Extraction Shift Inspection
Date: 03/14 Revision: EFR 3
Page 1 of 1
1. Inspect safety showers and eye wash fountains during the first hour of the shift for
proper operating conditions.
a. Immediately notify your supervisor if they are not working properly.
2. Inspect the area for good housekeeping during the first hour of the shift.
a. Clean up any spills, wood, paper, etc., as noted.
3. Inspect caustic, sulfuric acid, and ammonia lines every four hours for leaks.
a. Immediately notify your supervisor if any leaks are noted.
4. Inspect organic lines, feed lines, and solution lines every four hours for leaks.
a. Notify your supervisor if any are noted.
5. Inspect motors on pumps every four hours to be sure they are not running hot.
a. Immediately notify your supervisor if a motor is found to be running hot.
6. Inspect all equipment for proper guards and guards in place once per shift.
a. Shut off equipment, lock out, and replace a guard if the guard is not in place.
7. Inspect roof fans every four hours for proper operation.
a. Immediately notify your supervisor if any problems are noted.
8. All information should be documented on the Operating Foreman's Daily Inspection
form.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 7
Date: 05/16 Revision: EFR 4
Page I of 6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance office and
central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department, and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
Information Contained on Safety Data Sheets
White Mesa Mill -Standard Operating Procedures
Book 4 Section 7
Date: 05/16 Revision: EFR 4
Page 2 of6
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Physical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 7
Date: 05/16 Revision: EFR 4
Page 3 of 6
Vapor Pressure The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
So]ubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of SoJubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
HeaJth Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V./T.W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
White Mesa Mill -Standard Operating Procedures
Book 4 Section 7
Date: 05/16 Revision: EFR 4
Page 4 of 6
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to burn without the addition
of more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found .
White Mesa Mill -Standard Operating Procedures
Book 4 Section 7
Date: 05/16 Revision: EFR 4
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 7
Date: 05/16 Revision: EFR 4
Page 6 of 6
For the
Environment
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Uranium SX
Some of the major chemicals used in the SX process areas are listed as examples:
1. Kerosene
2. Sulfuric Acid
3. Sodium Hydroxide
4. Organic Amines
5. Petroleum Lubricating Greases
6. Sodium Chlorate
7. Soda Ash
White Mesa Mill -Standard Operating Procedures
Book 4 Section 8
Spill/Disposal Procedures
Date: 05/16 Revision: EFR 5
Pagel of2
All spills, no matter the size, shall be reported on an Orange Card and submitted to the
Environmental Coordinator as soon as possible. The Orange Card is in response to a
Storm water Inspection from October 2011.
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The SDS forms for all chemicals used in Uranium Recovery Operations are
listed, along with an indication of which chemicals have reporting obligations. The
following is an explanation of the actions required of the Mill Operator when dealing
with these chemicals. Without exception, your supervisor will make any required
reports. Refer to Emergency Response Plan for specific details regarding spill
procedures.
Resource Conservation and Recovery Act (R.C.R.A.)
R.C.R.A. regulates the manner in which hazardous materials can be disposed. The
specific requirements will be delineated with by the Environmental Department. If you
need to dispose of any chemicals, contact your supervisor for instructions. The
containers that held these products may be disposed of in any trash receptacle if:
1. The container has less than 5 % left in the bottom, or
2. The container has been triple rinsed into any mill sump.
Spill Reporting
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity and type of chemical spilled. A reportable spill is
basically when the chemical hits the ground (earth), as opposed to a spill to a concrete
pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your supervisor. Your
supervisor will determine if a report to an agency is necessary. Your supervisor will
make the report, if needed. Do not attempt to make a report yourself. If there is any
doubt, contact your supervisor for advice and direction.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 8
Date: 05/16 Revision: EFR 5
Page 2 of2
State of Utah Division of Waste Management and Radiation Control (DWMRC)
The DWMRC must be notified if a spill and/or accident causes more than $2,000.00
worth of damage or 24 hours of down time. If either of these conditions exist and is unknown by
your supervisor, contact your supervisor immediately. Your supervisor will make any required
reports.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
Hazards in the Solvent Extraction BuiJding
Uranium and Vanadium SX
Date: 12/19 Revision: EFR 4
Page 1 of7
1. Fire -There are approximately 200,000 gallons of kerosene in the SX extractors
2. Sulfuric acid -93% to 95% strength
3. Ammonia
4. High pressure steam lines -100 psi
5. High pressure air lines -100 psi
6. Chlorate
7. Caustic
8. Slippery floors if organic is spilled on them
9. Acid solutions
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
Fire Potential in the Solvent Extraction Building
Date: 12/19 Revision: EFR 4
Page 2 of7
Potential for fires in the SX building is present due to the 200,000 gallons of
kerosene used in the extractors. One of the primary jobs of the SX operator is to ensure
that no fire hazards exist in the SX building. The kerosene has a flashpoint of 180 °F.
Operators must always be on the alert for:
1. Motors on pumps running hot.
2. Motors on settler mixers running hot.
3. Spills of chlorate -chlorate and kerosene together is a very dangerous combination.
A fire could start by the two materials coming in contact with each other.
4. Wood or paper in the SX circuit could cause a fire if they become saturated with
kerosene.
5. Sulfuric acid spills -spills of sulfuric acid on the floor will generate enough heat to
cause kerosene to ignite.
6. Any welding or cutting in the building -sparks from cutting or welding could cause a
fire.
7. Any open flames such as cigarettes or cigarette lighters -these items are prohibited in
the SX building.
8. Any gasoline mobile equipment in the SX building -gasoline mobile equipment is
prohibited in the SX building as the sparks from the ignition system could cause a
fire.
All uranium and vanadium SX operators must always practice good operating
procedures to prevent spills in the SX building and good housekeeping practices to be
sure no flammable materials are lying around in the area of the SX building. Operators
are to know and understand the operation of the automatic foam fire system in the SX
building and know and understand how to operate and effectively use the chemical fire
extinguisher also in the SX building.
You, as operators, have the responsibility to help prevent potentials for fire. You
have the responsibility and authority to prevent any person from entering or working in
the SX building if they do not follow all rules and regulations required for fire
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
Date: 12/19 Revision: EFR 4
Page 3 of7
prevention. If at any time you have a question or doubt about a situation that you think
might be a fire hazard, notify your supervisor immediately.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
Hazard Recognition -SX Circuit
1. Hazards
a. Sulfuric Acid Lines
1. Open slowly
2. Use personal protective equipment
b. Caustic Tank and Lines
1. Open valve slowly
2. Use personal protective equipment
Date: 12/19 Revision: EFR 4
Page 4 of7
3. Air pressure during unloading is to be no more than 30 psi
c. Ammonia Tanks and Lines
1. Open valves slowly
2. User personal protective equipment
3. Report leaks promptly
d. Kerosene Tanks and Lines
1. Open valves slowly
2. Use caution around pumps and guards
3. Use personal protective equipment
e. Soda Ash Bins and Tanks
1. Use caution around the pumps and feed auger
2. Personal protective equipment
3. Open valve slowly
4. Open steam lines slowly
f. Sodium Chlorate Tanks and Lines
1. Open valves slowly
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
2. Caution around pumps
3. Use personal protective equipment
g. Amines
1. Burning and/or itching
2. Caution when dumping drums
h. Air Lines
1. Open valves slowly
2. Whip checks on hose connections
3. Do not use to blow off clothing
1. Steam Lines
1. Open valves slowly
2. Valves are hot
J. Fire Systems
1. Overhead sprinkler system (FDAM)
2. Fire extinguishers
Date: 12/19 Revision: EFR 4
Page 5 of7
3. Three five-minute escape bottles in the SX control room
4. Four SCBA units -two are located at each end of the building
5. Know where the exits are
k. Health Hazards
1. Sulfuric acid
a. Burns -flush with water for at least 15 minutes
b. Fumes -a respirator is required
2. Caustic Soda
a. Burns -flush with water for at least 15 minutes
3. Ammonia
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
a. Fumes -a respirator is required
Date: 12/19 Revision: EFR 4
Page 6 of7
b. Large spill or fire requires an SCBA unit
c. Burning -flush with water for at least 15 minutes
4. Kerosene
a. Burning and/or itching -wash with soap and water
5. Amines
a. Burning and/or itching -wash with soap and water
6. SodaAsh
a. Burning and/or itching -flush with water for at least 15
minutes
7. Sodium Chlorate
a. Fire hazard
1. Rubber gear, boots, gloves, goggles, or face shield
2. Discard clothing if contamination with chlorate shows
b. Chlorine gases
1. pH adjustment tank
2. Times when a respirator is required
1. Gamma Radiation
1. Posted for gamma on the SX uranium extractor mix tanks
2. Uranium SX feed line
m. Ladders
1. Ladder on the caustic tank
2. Ladders on the soda ash tanks
3. Ladders on the salt tanks
4. Ladder to the sump -chain must be in place
5. SX VPL feed tank
6. Strip make up tanks
n. Decks and Grating
1. Slippery when wet
o. Airborne Uranium
White Mesa Mill -Standard Operating Procedures
Book 4 Section 9
p. Radon Daughters
Date: 12/19 Revision: EFR 4
Page 7 of7
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Date: 12/19 Revision: EFR 5
Page 1 of9
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Uranium SX.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
GENERAL RULES
Reporting Unsafe Conditions and Injuries
Date: 12/19 Revision: EFR 5
Page 2 of9
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
c. Rubber gloves and rubber boots
Date: 12/19 Revision: EFR 5
Page 3 of9
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted lifeline is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs or having them in your
possession while in the plant area.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Date: 12/19 Revision: EFR 5
Page 4 of9
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Date: 12/19 Revision: EFR 5
Page 5 of9
MOBILE EQUIPMENT -SAFETY RULES
General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be driven
to the shop for repairs. Otherwise, the equipment must be towed or repaired at the
location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Date: 12/19 Revision: EFR 5
Page 6 of9
11. Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Date: 12/19 Revision: EFR 5
Page 7 of9
OPERA TIO NS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Safety Data Sheets
(SDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
8. Safe operation of conveyors requires that you shall:
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Date: 12/19 Revision: EFR 5
Page 8 of9
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 11
Safety Rules -Solvent Extraction
Date: 12/19 Revision: EFR 5
Page 9 of9
1. Welding or open flames are not normally permitted in these areas.
2. Smoking or the carrying of matches, lighters, etc., is not allowed in the SX building.
This includes the control room.
3. Chemical or solvent splashes must be washed from skin and clothing to prevent
irritation. Know the effects of all materials you handle and wear protective
equipment to keep them from coming in contact with you.
4. Know how to use the fire extinguishers and how the foam fire extinguishing system
works.
5. Should maintenance activities require the use of cutting, welding or grinding devices,
the atmosphere must be monitored for the appropriate hazard and work must proceed
after a safety analysis has been conducted.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 12
Date: 12/19 Revision: EFR 4
Page 1 of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for pre-leach and leach which, when
followed, will maintain your exposures A.L.A.R.A. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained A.L.A.R.A.
Uranium SX Radiation Safety Procedures
1. A.L.A.R.A. Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the A.L.A.R.A. program shall result in radiation exposures being
maintained to levels far below any applicable limits of the N.R.C. regulations as is
reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
continuous reviews of radiation, environmental and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
White Mesa Mill -Standard Operating Procedures
Book 4 Section 12
Date: 12/19 Revision: EFR 4
Page 2 of 5
initial assessment of the work environment and associated work tasks as related to
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at the uranium SX may require a Radiation Work
Permit if the initial radiological assessment indicates a potential for elevated
radiation exposure:
1. Uranium SX
a. Entry into extractors, settlers, or enclosed tanks.
b. Cleaning out the sumps.
c. Clean up of spills around the tanks.
This is not an all-inclusive list of jobs at Uranium SX that could require a Radiation
Work Permit but is intended as a guide.
3. Posting of Specific Areas
As a part of A.L.A.R.A. practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon daughter concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% D.A.C. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
White Mesa Mill -Standard Operating Procedures
Book 4 Section 12
Date: 12/19 Revision: EFR 4
Page 3 of 5
of full-face respirators due to airborne or radon daughter concentrations above 25%
D.A.C.:
a. Uranium SX
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. If you are using a respirator with combo cartridges for protection against
nuisance fumes or mists, the chemical concentration of the contaminants must
be less than the limit set by the manufacturer and the oxygen concentration
must be at or above 19.5%.
d. If you are detecting an odor or changing combo cartridges frequently, it is an
indication that the chemical concentration exceeds the chemical cartridge
limits and you should leave the area and notify your supervisor immediately.
5. Radiation Safety Procedures
White Mesa Mill -Standard Operating Procedures
Book 4 Section 12
Date: 12/19 Revision: EFR 4
Page 4 of 5
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your OSL badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas, if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions. Check the following equipment:
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at Uranium SX will be taken monthly.
Urinalysis samples are utilized to determine the uranium content contained in the
urine of the operator. The frequency of sampling is dependent on the airborne
White Mesa Mill -Standard Operating Procedures
Book 4 Section 12
Date: 12/19 Revision: EFR 4
Page 5 of 5
concentrations and will be changed if airborne levels exceed 25% of the airborne
standards.
To minimize the change of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing
into your work clothes or reporting to your work location. The samples can
then be placed in the administration building bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 13
Date: 12/12 Revision: EFR 3
Page 1 of 3
OPERA TOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate departments within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
1. If a sample is contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
White Mesa Mill -Standard Operating Procedures
Book 4 Section 13
Date: 12/12 Revision: EFR 3
Page 2 of 3
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building bioassay laboratory.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid ½ hour of
overtime to shower.
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
White Mesa Mill -Standard Operating Procedures
Book 4 Section 13
Date: 12/12 Revision: EFR 3
Page 3 of 3
survey. If the alarm sounds again, contact the Shift Foreman, Radiation Safety
Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
(
No.: PBL-8 Energy Fuels Resources (USA) Inc.
Rev. No.: EFR 4 STANDARD OPERATING PROCEDURES Page 1 of 22
Date: May 4, 2016 Title: Eluex
1.0 PURPOSE
Ion exchange is used to recover values from solutions. Ion exchange is the tr~ding of one
ion for another and from one medium to another. At the White Mesa Mill, ion exchange
is used to recover uranium from low grade uranium bearing acidic solutions. For higher
grade uranium bearing solutions, solvent extraction is used to recover uranium, and
vanadium. When the initial recovery of uranium from solution is by resin ion exchange
and the solution from stripping the resin is further concentrated and purified by solvent
extraction, the two stage ion exchange process is called an Eluex system, which is used at
the White Mesa Mill for the processing of low grade solutions from feed material, such as
FUSRAP material.
Alternate feed materials having relatively low uranium content will result in acid leach
solutions of low uranium content. Each of the IX columns contains resin beads to
recover uranium from the solutions generated in the leach circuit and diluted in the CCD
circuit. The resin beads are added to each column, additional resin beads may be added
when sufficient beads are broken and/or lost through use. The resin has the same type of
exchange properties as the amine of the organic used in the solvent extraction process.
The uranium in solution is recovered by chemical exchange onto the resin. As the
solution contacts the resin, uranium is loaded onto the resin.
The loading cycle consists of the feed solution being fed in an up flow manner, and in so
doing the resin bead volume is expanded. The flow partially lifts the beads. The amount
of lift or expansion of the resin bed is dependent on the velocity of the solution flow
through the column or the volumetric flow of solution (gpm). The contact of the values
in solution with the resin beads will allow the transfer of the values from the solution
onto the beads. The quantity of values transferred is dependent on many things,
including the condition of the solution, concentration in solution, the contact time, and
the quantity contacted. Once the beads are loaded, they are stripped of their values and
used again to recover values from solution.
The loaded resin is contacted with a separate solution, which removes the uranium from
the resin beads. This is termed "stripping." The feed to the column is stopped, the
solution drained, then the acidic strip solution is added. The strip solution addition and
removal are controlled to obtain the desired contact time. The strip solution is pumped
from the column to the solvent extraction ("SX") feed tank.
The use of ion exchange resin for extracting the uranium and the stripping of the uranium
from the resin will concentrate and purify the uranium. The uranium concentration
and/or purity can be improved by utilizing solvent extraction on the resin strip solution.
The resin strip solution is the feed to the extraction mixer-settler in the solvent extraction
circuit. The intimate contact of the resin strip aqueous solution and the organic allows
the uranium to load onto the organic solution.
W:\Environmental\SOP\Book 4 -Uranium SX\EFR 2016\Section PBL-8 Eluex SOP Rev 4.doc
No.: PBL-8 Energy Fuels Resources (USA) Inc.
Rev. No.: EFR 4 STANDARD OPERATING PROCEDURES Page 2 of 22
Date: May 4, 2016 Title: Eluex
The loaded organic is washed and stripped to produce feed to the precipitation circuit.
The washing of the loaded organic by contacting with water will remove entrained acid
and may also strip some impurities. Once the organic is water washed, the organic is
contacted with either an ammonium sulfate or acidified brine strip solution at a pH of 4.0
to 4.4. The pH of the aqueous strip solution is controlled by the addition of anhydrous
ammonia directly into the mixer.
Each unit of the solvent extraction portion of the Eluex system will have a recycle from
the settlers to their individual mixer tank to maximize the contact of aqueous and organic.
The mixer tank of the extraction unit and the mixer tank of the wash unit are normally
operated in the organic continuous mode. The strip mixer must be operated in the
aqueous continuous mode in order that the pH meter will function to enable control of the
anhydrous ammonia addition.
The strip solution from the solvent extraction portion of the Eluex system is termed "Preg
Strip" solution and will be the feed to the precipitation circuit. The barren solution, after
precipitation of the uranium and the solid-liquid separation, is returned to the solvent
extraction strip circuit to be used again for stripping the loaded organic.
Process control is provided both locally, within the circuit, and in the central control
room in the main Mill building.
2.0
2.1
ELUEX PROCEDURES
Start-up Procedures
1. Perform a pre-operational inspection of the area and the equipment to be operated.
Assure that all maintenance has been completed, the guards reinstalled, the area
cleaned up, and the locks removed from the MCC. Assure that the walkways are
clear, hoses and tools picked up, and power to each unit is available.
2. Check the eyewash and safety shower for proper operation.
3. Assure that reagents are available for use.
4. Check that the yellowcake precipitation circuit and the yellowcake thickener are
ready to receive preg solution and precipitated yellowcake slurry.
5. Check that there is adequate feed for the IX circuit to last until the head end of the
circuit is in operation.
6. Check the valves to each IX column to assure that the column is properly piped for a
stripping cycle or a loading cycle, as determined by previous operation or by
instruction from shift foreman or Mill management.
W:\Environrnental\SOP\Book 4 -Uranium SX\EFR 2016\Section PBL-8 Eluex SOP Rev 4.doc
No.: PBL-8 Energy Fuels Resources (USA) Inc.
Rev. No.: EFR 4 STANDARD OPERATING PROCEDURES Page 3 of 22
Date: May 4, 2016 Title: Eluex
7. Assure that the Knife Gate valve on the main line is in the closed position. The
control Butterfly Valves for the control of solution to the columns should be
positioned to proportion feed to the columns in use. Initially, these valves could be in
the closed position. Notify your supervisor that you are ready to start the circuit and
start the feed solution to the head tank when the mill is ready.
8. When there is sufficient feed solution for the solvent extraction circuit, start the SX
mixers and assure that the proper recycle solution (aqueous or organic) is pumped
from the settler back to the mixer tank. Continue the internal recycle in each Mixer-
Settler.
9. Start the Barren Organic flow to the Extraction Mixer and the Barren Organic from
the Strip Settler to the Barren Organic Tank.
10. Start the Barren Strip Solution to the Strip Mixer and the Preg Solution from the Strip
Settler to the Preg Solution Tank. (Start pumping the Preg Strip Solution when the
circuits are ready to precipitate Y.C. and send Barren Strip Solution back.)
11. Open the ammonia valves to allow ammonia into the Strip Mixer as controlled by the
pH meter.
NOTES on the ELUEX SYSTEM:
1. The feed is fed directly into the IX Feed Head Tank. The pump from the
lower tank is left off and the overflow line to the IX Tails Tank is open. The
IX Feed is regulated and the flowrate indicated and totalized. Any overflow
from the Head Tank will be collected in the lower tank and will overflow to
the IX Tails Tank and be distributed.
2. The solution in the lower tank can be pumped to the Head Tank prior to
shutdown or during periods of insufficient feed solution. This pump should
not normally be run.
3. The internal recycle between the SX Mixer and Settler will dictate the
continuity of the mixer when started. A recycle of the organic is required in
the Extraction unit and in the Wash unit, whereas, a recycle of the Aqueous is
required in the Strip unit.
4. The continuity of the mixers can be checked by use of an ohm meter. When
the mixer is organic continuous, the meter will not show a reading (the needle
will not move). When the mixer is Aqueous Continuous, the needle will
move to the maximum position. The "continuity" tells what fluid is on the
outside of the droplets. Droplets of organic surrounded by Aqueous is an
aqueous continuous system which conducts current and which can be read by
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a pH meter. Droplets of aqueous solution surrounded by organic is organic
continuous and will not conduct current and pH cannot be taken.
2.2 Shut Down Procedures
1. Shut down the feed to the IX feed tank. Close the feed valves to each of the IX
columns.
2. Shut down the SX feed pump and the SX raffinate pump.
3. Shut down the SX strip solution pump and the SX Preg pump.
4. Turn off the water flow to the SX wash mixer.
5. Turn off the Barren Organic feed and return pumps.
6. Turn off the SX mixers.
7. Turn off the ammonia supply to the SX strip mixer.
2.3 Emergency Shut Down Procedures
1. Shut down all pumps and mixers.
2. Close the ammonia valve.
3. If time permits, close all valves to the IX columns.
2.4 General Inspection Procedures
The following are procedures that should be done on a regular basis throughout the shift.
1. Inspect reagent lines, organic lines, feed lines and solution lines for leaks and
immediately notify your supervisor if any leaks are noted.
2. Inspect motors on pumps to be sure they are not running hot and immediately notify
your supervisor if a motor is found to be running hot.
3. Inspect roof fans for proper operation and notify your supervisor if any problems are
noted.
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3.0 CHEMICALS AND REAGENTS
3.1 Introduction
Numerous inorganic and organic chemicals are used in the processing of uranium. These
include such items as:
• Inorganic Acids
• Organic Acids
• Petroleum Products
• Fuels
• Solvents
• Ammonia
• Inorganic Bases
• Flocculents
• Degreasing Agents
• Fiberglassing Compounds
• Oxidizing and Reducing Agents
• Other chemicals as required
3.2 ELUEX Process
Some of the major chemicals used in the Eluex process area are listed as examples:
• Kerosene
• Sulfuric Acid
• Sodium Hydroxide
• Resin
• Organic Amines
• Petroleum Lubricating Greases
• Ammonium Sulfate
• Soda Ash
• Ammonia
3.3 Material Safetv Data Sheets
All relevant safety, first aid handling procedures and physical chemical information, etc.,
is contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the
mill area. These can be found in the following locations; safety office, laboratory,
maintenance office and central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and
reagent.
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Each operator must read and understand the SDS of all chemicals and reagents used in
his/her department, along with the chemicals and reagents used in all operating
departments.
Each operator must know the location of all SDS 's for his/her operating circuit at all
times.
3.4 Information Contained on Safety Data Sheets
Hazardous Material
Shipping Name The proper shipping name or other common name for the material;
also any synonyms for the material.
DOT Hazard Class The hazard class designation for the material as found m the
Department of Transportation regulations.
Chemical Name
I.D. Number
STCCNumber
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous
material by the Department of Transportation; also includes the
prefix "UN" or "NA."
The Standard Transportation Commodity Code number used in the
rail industry; a seven-digit number assigned to a specific material
or group of materials and used in the determination of rates; for a
hazardous material, the STCC number will begin with the digits
"49."
Physical Description
Normal Physical State Physical state or form of the material at normal ambient
temperatures (68°F -77°F).
Color
Odo1·
Chemical Properties
Specific Gravity
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material
is lighter than water and will float; if the specific gravity is greater
than 1, the material is heavier than water and will sink.
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Vapor Density
Boiling Point
Melting Point
Vapor Pressure
Solubility
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The weight of a pure vapor or gas compared with the weight of an
equal volume of dry air at the same temperature and pressure; if
the vapor density is less than 1, the material is lighter than air and
may rise; if the vapor density is greater than 1, the material is
heavier than air and will stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e.,
the temperature where the pressure of the liquid equals
atmospheric pressure.
The temperature at which a solid changes to a liquid; this
temperature is also the freezing point depending on the direction of
the change.
The pressure exerted by the vapor within the container against the
sides of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of
the liquid evaporates or vaporizes. The lower the boiling point of a
liquid, the greater the vapor pressure it will exert at a given
temperature.
The ability of a solid liquid, gas, or vapor to dissolve in water; the
ability of one material to blend uniformly with another, such as a
solid in liquid, liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard Is there any hazard from breathing this material?
TLLffW A Threshold Limit Valueffime Weighted Average -concentration of
a material to which an average, healthy person may be repeatedly
exposed for eight hours per day, 40 hours per week, without
suffering adverse health effects.
LC50 The concentration in ppm that kills 50% of the laboratory animals
in a given length of time.
Ingestion Hazard Is there any hazard from ingesting (eating) this material?
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LDso Lethal Dose -the dose that kills 50% of the test animals.
Absorption Hazard Is there any hazard from absorbing this material into the body?
Skin Absorption
Eye Absorption
IDHL Value
STEL Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication
of atmospheres that are immediately dangerous to life and health.
Within 30 minutes of exposure, death or irreversible health
implications to the person exposed are expected.
Short Term Exposure Limit Value -maximum allowable
concentration or ceiling, not to be exceeded during a 15 minute
period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a
developing embryo.
Is the material harmful to aquatic life?
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is
to prevent or reduce the physical transfer of any contaminants by
people or equipment from onsite to offsite locations. List methods
available for decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
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Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Corrosive Hazards
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The minimum temperature at which a liquid gives off enough
vapors to ignite and flash over, but will not continue to burn
without the addition of more heat.
Auto-ignition Temperature -the minimum temperature required to
ignite gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration
(percentage by volume in air) that will bum or explode if an
ignition source is present. Limiting concentrations are commonly
called the "LEL'' (Lower Flammable Explosive Limit) and the
"UEL" (Upper Flammable Explosive Limit). Below the lower
flammable limit, the mixture is too lean to burn; above the upper
flammable limit, the mixture is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
Corrosive Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their
ability to dissociate in solution. Those that form the greatest
number of hydrogen ions are the strongest acids, while those that
form the hydroxide ion are the most potent bases. The
measurement of the hydrogen ion concentration in solution is
called the pH of the compound in the solution. Strong acids have
low pH values and strong bases have high pH values; the pH scale
ranges from O to 14.
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Corrosive to what? Materials with which the material is corrosive, particularly skin
and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the
corrosive material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a
lower level of skin protection. It is the minimum level
recommended on initial entries until the hazards have been further
identified and defined by complete monitoring, sampling, and
evaluation.
Level C -Requires air purifying respirators with adequate
protection factors; coveralls and other protective equipment may
be required. This level is selected when types and concentrations
of respirable materials are knows to have adequate warning
properties.
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Level D -Requires no respiratory protection; basic work clothing
should be worn when sites are positively identified as having no
toxic hazards.
For the
Environment
Potential mitigation schemes to protect the environment.
Note: The back of the Hazardous Material Data Sheet can be used to collect additional
information of a more specific nature.
3.5 SpilVDisposal Procedures
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The following is an explanation of the actions required when dealing with
these chemicals. Without exception, your supervisor will make any required reports.
Refer to Emergency Response Plan for specific details regarding spill procedures.
Resource Conservation and Recovery Act (RCRA)
RCRA regulates the manner in which hazardous materials can be disposed. The specific
requirements will be specified by the Environmental Department. If you need to dispose
of any chemicals, contact your supervisor for instructions. The containers that held these
products may be disposed of in any trash receptacle if:
a.) the container has less than 5 % left in the bottom, or
b.) the container has been triple rinsed into any mill sump.
Spill Reporting
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity and type of chemical spilled. A reportable spill is
basically when the chemical hits the ground (earth), as opposed to a spill to a concrete
pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your supervisor. Your
supervisor will determine if a report to an agency is necessary. Your supervisor will
make the report, if needed. Do not attempt to make a report yourself. If there is any
doubt, contact your supervisor for advice and direction.
4.0 HAZARDS IN THE SOLVENT EXTRACTION BUILDING
The following Items can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
1. Fire -There are approximately 200,000 gallons of kerosene in the SX extractors
2. Sulfuric acid -93% to 95% strength
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3. Ammonia
4. High pressure steam lines -100 psi
5. High pressure air lines -100 psi
6. Sodium Chlorate
7. Caustic
8. Slippery floors if organic or resin is spilled on them
9. Acid solutions
4.1 Fire Potential in the Solvent Extraction Building
Potential for fires in the SX building is present due to the 200,000 gallons of kerosene
used in the extractors. The kerosene has a flashpoint of 180°F which is higher than
normal kerosene which as a flashpoint of approximately 130°F.
The Operator is to always be on the alert for:
1. Motors on pumps running hot.
2. Motors on settler mixers running hot.
3. Wood or paper in the SX circuit could cause a fire if they become saturated with
kerosene.
4. Sulfuric acid spills -spills of sulfuric acid on the floor may generate enough heat to
cause kerosene to ignite.
5. Any welding or cutting in the building -sparks from cutting or welding could cause a
fire.
6. Any open flames such as cigarettes or cigarette lighters -these items are prohibited in
the SX building.
7. Any gasoline mobile equipment in the SX building -gasoline mobile equipment is
prohibited in the SX building, unless operated under a Safe Work Permit, as the
sparks from the ignition system could cause a fire.
All Eluex operators must always practice good operating procedures to prevent spills in
the SX building and good housekeeping practices to be sure no flammable materials are
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lying around in the area of the SX building. Operators are to know and understand the
operation of the automatic foam fire system in the SX building and know and understand
how to operate and effectively use the chemical fire extinguisher also in the SX building.
You, as operators, have the responsibility to help prevent potentials for fire. You have
the responsibility and authority to prevent any person from entering or working in the SX
building if they do not follow all rules and regulations required for fire prevention. If at
any time you have a question or doubt about a situation that you think might be a fire
hazard, notify your supervisor immediately.
4.2 Hazard Recognition -Eluex Circuit
1. Hazards
a. Sulfuric Acid Lines
1. Open slowly
2. Use personal protective equipment
b. Caustic Tank and Lines
1. Open valve slowly
2. Use personal protective equipment
3. Air pressure during unloading is to be no more than 30 psi
c. Ammonia Tanks and Lines
1. Open valves slowly
2. User personal protective equipment
3. Report leaks promptly
d. Kerosene Tanks and Lines
1. Open valves slowly
2. Use caution around pumps and guards
3. Use personal protective equipment
e. Soda Ash Bins and Tanks
1. Use caution around the pumps and feed auger
2. Personal protective equipment
3. Open valve slowly
4. Open steam lines slowly
f. Amines
1. Use personal protective equipment
2. Caution when dumping drums
g. Air Lines
1. Open valves slowly
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2. Whip checks on hose connections
3. Do not use to blow off clothing
h. Steam Lines
1. Open valves slowly
2. Valves are hot
i. Fire Systems
1. Overhead sprinkler system (FDAM)
2. Fire extinguishers
3. Three five minute escape bottles on a column in the aisle of the SX
building near the old SX control room
4. Four SCBA units -two are located at each end of the building
5. Know where the exists are
J. Health Hazards
1. Sulfuric acid
a. Burns -flush with water for at least 15 minutes
b. Fumes -a respirator is required
2. Caustic Soda
a. Burns -flush with water for at least 15 minutes
3. Ammonia
a. Fumes -a respirator is required
b. Large spill or fire requires an SCBA unit
c. Burning-flush with water for at least 15 minutes
4. Kerosene
a. Burning and/or itching -wash with soap and water
5. Amines
a. Burning and/or itching -wash with soap and water
6. SodaAsh
k. Radiation
1. Ladders
a. Burning and/or itching -flush with water for at least 15
minutes
m. Decks and Grating
1. Slippery when wet
n. Airborne Uranium
o. Radon Daughters
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5.0 JOB PROCEDURES
All non-routine jobs will be initiated by your supervisor and will not be performed unless
directed by your supervisor. For any non-routine job a Radiation Work Permit and/or a
Safe Work Permit may be required.
6.0 SAFETY RULES
Safety rules will be followed without exception. Listed in this section are general safety
rules for Eluex. These rules do not cover all the White Mesa Mill safety rules. Each
operator is to know and understand all White Mesa Mill safety rules that are described in
the Safety Manual.
6.1 SX Building Safety Rules
Because of the flash point of the kerosene used in the SX building, the following rules
apply:
1. No gasoline driven engines are allowed in the building at any time, unless the work is
being done under a Safe Work Permit.
2. Open flames are prohibited in the SX building. Do not carry smoking materials (i.e.
matches, lighters, or cigarettes) in any area within the Mill property.
3. No cutting, welding, or grinding is allowed in the building, unless the work is being
done under a Safe Work Permit.
4. All electric motors used in the SX building have to be explosion proof.
Should maintenance activities require the use of cutting, welding, or grinding devices, a
Safe Work Permit is required and the atmosphere must be monitored for the appropriate
hazard.
6.2 Gene1·al Safety Rules
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
3. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and ho to defend against them.
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4. If a valve refuses to open or close ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
5. All personnel shall know the location of all main block valves for fuel, kerosene, gas,
steam, air, water, sulfuric acid and ammonia lines which pass through their area.
Even though the respective valve may not be in your area, you must know how to
shut off each line in case of an emergency.
6. Chemical or solvent splashes must be washed from skin and clothing to prevent
irritation. Know the effects of all materials you handle and wear protective
equipment to keep them from coming in contact with you.
6.3 Mobile Equipment Safety Rules
Although gas powered mobile equipment is not prohibited in the SX building, some
maintenance work may require gas powered equipment. Any use of gas powered
equipment should be done under a Safe Work Permit and the following safety rules
should be followed.
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be driven
to the shop for repairs; otherwise, the equipment must be towed or repaired at the
location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. Never
jump from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
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10. Keep the cabs of equipment clean. Loose items, which could jam controls or create
other hazards, are not allowed.
11. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
12. All gasoline engines must be shut off when refueling.
13. Stunt driving and horseplay are strictly forbidden.
14. Keep equipment clear of edges, drop offs and unstable banks.
6.4 Reporting Unsafe Conditions and Injuries
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries to your supervisor immediately. Also, report all accidental
occurrences or conditions that may have a potential for injuring someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
6.5 Personal Protective Equipment and Clothing
1. Hard hats, safety shoes and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices and change rooms.
2. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt contact your supervisor.
3. Employees are responsible for the condition of their protective equipment. Report
any defects, etc. to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles.
b. Rubber coat, pants, gloves and boots.
c. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
5. The use of safety belt and properly adjusted life line is required where there is a
danger of falling.
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7.0 RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training, which you have
received.
Listed below are the Radiation Safety Procedures for Uranium SX which, when followed,
will maintain your exposures ALARA. Remember, you are the person most responsible
for controlling your radiation exposure. If the Radiation Safety Procedures are followed
and protective equipment is utilized correctly, your exposure will be maintained ALARA.
7.1 ALARA Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation protection
practices is the expenditure of every reasonable effort to achieve and maintain low levels
of contamination and radiation in occupational exposures. By definition, the ALARA
program shall result in radiation exposures being maintained to levels far below any
applicable limits of the NRC regulations as is reasonable.
This policy and program is to .be achieved through systematic employee monitoring and
an on-going review process between the radiation protection staff and plant operations
management with secondary audits performed by corporate environmental personnel.
Energy Fuels Resources (USA) Inc. is committed to maintaining occupational exposures
of personnel at White Mesa to levels as reasonably achievable. The training program
conducted for facility personnel supports this commitment of continuous reviews of
radiation, environmental and industrial hygiene protection policies.
It is the policy that occupational exposure records of personnel at the White Mesa Mill
are readily available for review when requested. The radiation protection staff will
review and discuss any aspect of radiation safety at any time.
7.2 Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work is to
be performed in the mill area. The procedure ensures that radiation hazards which cannot
be contained will be controlled by the use of protective equipment. An initial assessment
of the work environment and associated work tasks as related to potential radiation
exposure will be made for those non-routine work activities which may require the
issuance of a Radiation Work Permit. If it is determined, by this initial assessment, that
there is a potential for elevated radiation exposure, a Radiation Work Permit will be
issued.
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a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in the
work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at Eluex may require a Radiation Work Permit if the
initial radiological assessment indicates a potential for elevated radiation
exposure:
1. Entry into strippers, extractors, mixed tanks or confined spaces
2. Cleaning out the sumps
3. Work on uranium feed line or pumps
This is not an all-inclusive list of jobs at Eluex that could require a Radiation Work
Permit, but is intended as a guide.
7.3 Posting of Specific Areas
As a part of ALARA practices and controlling your exposures, the following signs could
be posted in your work area. It is important that you understand what these signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA -This sign is posted in an area in
which airborne uranium or radon daughter concentrations are, or at above 25% of the
specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% DAC.
CAUTION -RADIATION AREA -This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
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7.4 Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant smoke
and logged on the forms provided at the shifters office. After the initial fit-
testing, a positive-negative pressure test will be done each time the respirator is
donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to change
the filter after two to three hours. When resistance to breathing becomes
uncomfortable, it is a sign that the filters have served their useful life and need to
be replaced.
c. If you are using a respirator for protection against nuisance fumes or mists, the
oxygen concentration must be at or above 19.5%.
d. If you are detecting an odor or changing cartridges frequently, it is an indication
that the chemical concentration exceeds the cartridge limits and you should leave
the area and notify your supervisor immediately.
7.5 Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill. All
coveralls and contaminated clothing will be laundered on the property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal conditions,
tell the person doing the surveys.
d. Always wear your personnel monitoring device badge when you are assigned one.
Put it in the designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas, ifrequired.
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f. Check the equipment utilized to control the radon daughter levels, if applicable.
Take necessary precautions to reduce your radiation exposure if there is evidence
of excessive dusting and notify your shift foreman of any equipment
malfunctions.
g. If you are concerned or have any questions about the amount of radiation you are
being exposed to, contact the Radiation Safety Officer.
7.6 Urinalysis Sampling
Urinalysis samples are utilized to determine the uranium content contained in the urine of
the operator. The frequency of sampling is dependent on the airborne concentrations and
will be changed if airborne levels exceed 25% of the airborne standards.
To minimize the change of contaminating a urine sample, the following practices should
be followed:
Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off. The sample containers should be filled
after washing your hands and prior to changing into your work clothes or
reporting to your work location. The samples can then be placed in the
administration building bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner, the
worker should shower immediately prior to voiding. When a shower is not possible,
disposable plastic or rubber gloves should be worn during voiding. Take all necessary
precautions to ensure that your urine sample is not contaminated. These are practices
that, if you follow, will minimize your radiation exposure while working at the White
Mesa Mill.
8.0 GENERAL OPERATOR'S RESPONSIBILITIES
1. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate circuits within specified parameters.
c. No alarms are to blocked out or otherwise made to be inoperable at any time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
f. If a sample is contaminated, start a new sample and mark "contaminated
sample" on the item what was contaminated
g. Maintain and practice good housekeeping.
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2. All operators will be provided with a change room, shower and laundry facilities
so that they may leave their work clothes at the Mill. All coveralls and
contaminated clothing will be laundered on the property.
3. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
4. Prior to leaving the Restricted Area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house and mill administration
office. If the alarm sounds, re-survey. If the alarm sounds again contact the Shift
Foreman, Radiation Safety Officer, or a radiation staff member.
5. Operators of company vehicles must have a valid driver's license.
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White Mesa Mill -Standard Operating Procedures
Book 5 Section 1
INTRODUCTION
Mill Process
Date: 12/19 Revision: EFR 5
Page 1 of2
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a slurry in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium (when present) is recovered from the barren uranium raffinate also utilizing a
solvent extraction circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered,
dried, melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent extraction
control room, vanadium control room, grind circuit below the derrick screens and in the
upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined, and now implements, a
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 1
Date: 12/19 Revision: EFR 5
Page 2 of2
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page l of 14
YELLOWCAKE PRECIPITATION -
DRYING AND PACKAGING
Preface
Extreme care must be taken in the operation of the yellowcake precipitation,
drying, and packaging circuits to prevent spills and dust. Spills and dust can result in
over-exposure of operators and employees working in the yellowcake area. All spills
must be cleaned up immediately. Scrubber systems must be in good operational
conditions and operating at required standards.
Good personal hygiene must be practiced at all times to prevent ingestion of
yellowcake. Keep all yellowcake washed off of your hands and clothing. Coveralls,
rubber boots, and gloves must be worn when working in the yellowcake area.
Full-face respirators must be worn when in the yellowcake dryer enclosure,
yellowcake packaging enclosure, and when placing lids and rings on filled yellowcake
drums to prevent over-exposure. No exceptions.
Full-face respirators may be required at designated times and in designated areas.
For your protection, they must be worn when required.
Following are descriptions and procedures that operators must learn and
understand. Notify your supervisor if you have any questions about operating procedures
or conditions.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Yellowcake Precipitation, Drying, and Packaging Circuit
Date: 12/19 Revision: EFR 6
Page 2 of 14
The purposes of the yellowcake precipitation and drying circuits are to precipitate
the uranium solution produced in the uranium SX, remove impurities from the
precipitate, dry the precipitate, and package the dried precipitate for shipping.
The yellowcake precipitation and drying circuits consist of two precipitation
tanks, two thickeners, one re-dissolve tank, two centrifuges, two dryers with scrubber
systems, and all associated pumps and piping.
The feed solution for the yellowcake precipitation circuit is pumped from the
loaded strip tank in the uranium SX building to the number one yellowcake precipitation
tank. Ammonia is added and mixed with the loaded strip solution. As ammonia is
added, the pH is raised causing the strip solution to precipitate. The precipitate or
yellowcake overflows through an outlet pipe in the number one yellowcake precipitation
tank to the centerwell of the number one yellowcake thickener.
In the number one yellowcake thickener, the heavy precipitated yellowcake settles
to the bottom of the thickener. The clear solution that separates from the yellowcake as it
settles overflows a launder and is pumped to either the strip makeup tank in SX, or the
overflow launder in the number one CCD thickener. The bottom of the thickener is cone-
shaped with an outlet at the bottom center of the cone. Rakes in the cone of the thickener
turn and push the yellowcake to the cone outlet where it is pumped out by a parastaltic
pump to the re-dissolve tank. The parastaltic pump is of variable speed and is set at a
speed to maintain the density specified by operational parameters, in the bottom of the
yellowcake thickener. The density is obtained by letting the yellowcake build up in the
thickener.
The purpose of the re-dissolve tank is to dissolve the yellowcake back into a
solution and remove contaminates (primarily sodium) from the dissolved yellowcake.
Sulfuric acid is added to the re-dissolve tank causing the yellowcake to go into solution.
Wash water is also added to wash out contaminates. As the yellowcake, acid, and water
are added to the re-dissolve tank, the solution in the tank overflows into an overflow pipe
to the number two yellowcake precipitation tank.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 3 of 14
Ammonia is added and mixed with the solution from the re-dissolve tank raising
the pH back up. As the pH rises, the yellowcake in the solution will precipitate as it did
in the number one yellowcake precipitation tank. The precipitate, or yellowcake,
overflows the number two yellowcake precipitation tank through an overflow pipe to the
centerwell of the number two yellowcake thickener.
The number two yellowcake thickener is identical to the number one yellowcake
thickener and operates the same. The heavy precipitated yellowcake settles to the bottom
of the thickener. The clear solution that separates from the yellowcake as it settles
overflows a launder and is pumped to the number one CCD thickener overflow launder.
The bottom of the yellowcake thickener is cone-shaped with an outlet at the bottom
center of the cone. Rakes in the cone of the thickener turn and push the yellowcake to the
cone outlet where it is pumped by a parastaltic pump to one of the centrifuges. The
density of the underflow is controlled by a variable speed parastaltic pump.
The purpose of the centrifuge is to de-water the yellowcake so that it can be dried
in the yellowcake dryer. The solution accompanying the yellowcake solids contain
impurities and must be removed. Also, it is best to minimize the amount of water sent to
the yellowcake dryer.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Y elJowcake Dryer Description
Date: 12/19 Revision: EFR 6
Page 4 of 14
Two Yellowcake dryers are used. The dryers are designated as the North and
South dryers. The North dryer is 6'0" I.D. and the South dryer is 8'0" I.D. Both dryers
are Skinner dryers and the descriptions are the same, except for the size and fuel type
(north dryer uses propane, south uses natural gas). The yellowcake dryers have six
refractory lined hearths with burners on hearths two, four, and six with a rotating central
shaft with attached rabble arms and angled rabble teeth used to move the yellowcake
material down through the dryer. The arms and shaft are cooled by air forced into the
bottom of the shaft by the cooling air fan. After passing through the arms and shaft, the
cooling air will have been heated to a temperature of 300° to 450°F and is vented out
through the cooling air stack to the atmosphere.
There are two doors per hearth located 180° apart and directly in line with each
other.
The yellowcake is delivered to the top hearth of the dryer. The yellowcake
material is moved through the dryer by means of rabble arms with attached rabble teeth
which are angled so that, as the shaft rotates, the teeth distribute the cake over each
hearth, in or out as the case may be and down until it reaches the bottom hearth where the
teeth push the dried cake into the dryer outlet. From here, the dried cake drops through a
chute to the lump breaker and then to the yellowcake packaging bin.
Air is drawn through the dryer by suction created by the exhaust gas system. The
actual amount of gas flow is determined by the furnace pressure. The furnace pressure is
automatically controlled by means of a pressure transmitter and controller. The dryer
pressure (or draft) is measured at the top hearth of the dryer. The dryer pressure (or draft)
controller operates a control damper located in the ductwork at the outlet of the gas
scrubber to control the pressure.
An increase in dryer pressure will result in an opening of the damper which will
increase the flow of gasses from the dryer and a decrease in pressure will, conversely,
decrease the damper opening and reduce the gas flow.
An increase in the feed rate or moisture content of the feed will increase the rate
of gas generation and, thereby increase dryer pressure. The control system will respond
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 5 of 14
by increasing the flow to the scrubber system. Thus, the dryer pressure controller acts to
compensate for changes in the feed rate or moisture in the feed. The dryer works best
when the furnace draft (negative pressure) is between -0.1 and -0.2 inches water column,
but this is dependent on many variables.
The burner system is designed to burn the specific gas with gas pilots. There are
a total of six burners, two each on hearths two, four, and six. Both burners on each hearth
are controlled from a single set point controller and operate in unison. The installed
capacity of the six burners is approximately 1.6 million BTU/hour. The six burners are
equipped with automatic, electrically ignited interrupted gas pilots. The burner flame is
monitored by ultraviolet flame scanners. Each burner can be started or stopped
individually from the panel mounted start/stop stations.
The gas systems incorporate the necessary safety valves, regulators, and pressure
switches. The flame safety equipment is housed in the main control panel which also
contains the necessary interlocks and controls for the rest of the system.
Ideal dryer temperatures are 1,000°F to 1,200°F in the number two hearth, 1,200°F
to 1,300°F in the number four hearth, and 1,400°F in the number six hearth. Hearth
temperatures will vary due to moisture content of the centrifuged yellowcake and the feed
rate to the dryer.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Lump Breaker
Date: 12/19 Revision: EFR 6
Page 6 of 14
Both North and South dryers use a lump breaking machine to break any lumps in
the yellowcake.
Yellowcake Storage and Package Bin
The packaging bin will hold approximately 17,000 pounds ( or 20 drums) of dried
yellowcake. The packaging bin is equipped with a high-level indicating probe and
indicating high level alarm and light on the yellowcake dryer control panel. The bin is
completely sealed with a star feeder at the bottom. The star feeder is designated to keep
the dried yellowcake from sifting through the bottom opening in the bin. Barrels are
filled from the bottom of the bin. A barrel is placed on a platform scale directly under the
star feeder. An adjustable barrel hood between the star feeder and the barrel form a dust-
tight seal.
The yellowcake packaging room is a negative pressure packaging room. Negative
pressure is controlled by the dust and gas handling scrubber system.
The drying of the yellowcake material in the dryer gives rise to water vapor and
gaseous products of combustion from fuel used, which are discharged through a gas
outlet on top of the dryer and into the exhaust gas handling system.
Exhaust Gas Scrubber System
Both north and south dryers have separate exhaust gas scrubbers. The scrubbers
are not identical in configuration, but both operate in the same manner.
As the yellowcake dries, dust is formed in the dryer which follows the air and off-
gas flow out of the top of the dryer. The purpose of the scrubber system is to remove any
dust carried in the dryer exhaust stream before the gases are released to the atmosphere.
The off-gas scrubber is a large stainless-steel cylinder with three internal
compartments. Flow generated by the scrubber fan draws the exhaust gases from the
dryer. The dusty gas stream enters the scrubber near the bottom and at one side of the
circular scrubber to create a swirling pattern of the gas; a water spray dispenses a fine
spray to blend into a swirling mass. This is called the "humidification section" and
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 7 of 14
serves to wet the dust particles. The gas stream then passes upward through a stationary
air vane to amplify the swirling ( or mixing) action, then into the fan inlet. The fan is a
set-type fan and a larger volume water spray introduces water particles into the turbulent
atmosphere of the fan where they wet all the dust particles or scrub them from the gas
screen. The fan discharges the wet gas stream into the second compartment, or demister
section of the scrubber where an additional, low volume, fine water spray is again
introduced into the turbulent air stream. The second section, since it is on the discharge
of the fan, is under positive pressure while the first section on the fan intake is under
suction or negative pressure.
The second section (demister section) is equipped with a conical bottom and, at
the bottom of the cone, is located an orifice plate to discharge the dirty water (from
collecting the dust) into the modification section. The bottom of the first section (or
modification section) is also conical and is connected to a discharge pipe submerged in
the yellowcake scrubber tank to form an air seal ( or barometric leg). The scrubber gases
are passed through a demister pad to remove entrained moisture before discharging
through the stack to the atmosphere. The demister pad is a six-inch-thick pad made of a
stainless-steel material. The pad may become partially plugged and restrict air flow and
must be cleaned from the access door above the pad if this should occur. The entire
scrubber system and dryer will need to be shutdown during scrubber cleaning.
To achieve efficient scrubbing of the gases, certain conditions must be maintained
in the scrubber system, as well as meeting the normal operating conditions of the dryer
system.
Since the dryer needs to be maintained under negative pressure to prevent the exit
of dust and gas into the enclosure, a gauge is provided at the number six hearth (the point
furthest from the scrubber). This gauge is provided with an alarm that will sound, should
negative pressure drop below 0.04 inches water column. A gauge is provided that
measures differential pressure across the off-gas scrubber in inches of water column.
This gauge will sound an alarm and shut down the yellowcake dryer if the differential
pressure drops to 2.0 inches of water column. Normal differential pressure readings on
the off-gas scrubber are at three to four inches water column.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 8 of 14
Additionally, water flow measurements to the sprays are measured by a flow
meter at each spray and should be controlled at the following:
1. Venturi Inlet
2. Humidifier Spray
3. Demister Spray
28 -35 gpm
5-10 gpm
2.5 -5 gpm
Typically, 28 to 35 gpm of water are utilized through the off-gas scrubber spray
system.
If the flow rate drops below 28 gpm water, a low water alarm will sound on the
control panel. The inner lock on the off-gas scrubber will shut the dryer down if water
flow to the scrubber drops to 12 gpm.
The following operating parameters are the limits that if reached require the off-
gas scrubber system to be taken down and cleaned or inspected:
1. Negative pressure on the dryer below 0.04 inches water column.
2. Differential pressure on the yellowcake dryer off-gas scrubber manometer
readings at 2.5 inches water column.
3. If water flow drops below 28 gpm total, or if the flow rate to any spray drops
below the following settings:
a. Humidification Section
b. Scrubber Fan
c. Demister Spray
5.0 gpm
28.0 gpm
2.5 gpm
After the gas stream leaves the off-gas scrubber, it is ducted into the packed tower
demister scrubber. The purpose of the packed tower demister is to remove soluble gases
contained in the exhaust stream from the off-gas scrubber.
The exhaust from the off-gas scrubber enters the packed tower demister at the
inlet near the bottom. There is no scrubber fan with the packed tower demister, so the
exhaust gas stream moves by force through the packing section. The packing section of
the tower is packed with seven feet of polypropylene saddles which are sprayed with
water at 35 gpm. The exhaust gas stream hits the wetted surface of the packing and
transfers the contaminates in the gas stream into the water. The bottom of the packing
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 9 of 14
tower is connected to a discharge pipe submerged in the scrubber tank which serves as an
air seal ( or barometric leg) for the packing tower. The upper section of the packed tower
demister is the demister portion of the scrubber. Contained in the demister section of the
tower is a demister pad to remove any fine particulates of dust which may have passed
through the off-gas scrubber (or the packed section) of the tower and any entrained water
in the gas stream. The demister section of the tower utilizes a five gpm water flow rate of
clean water for flushing purposes. The gas stream then exits the packed tower demister
into the yellowcake stack which is released into the atmosphere.
Since the off-gas scrubber and packed tower demister are in a series, if the packed
tower becomes partially plugged and restricts air flow, this will affect the negative
pressure reading on the dryer which will then sound the panel alarm, or increase the
differential pressure reading on the off-gas scrubber.
The upper differential pressure reading on the manometer at the off-gas scrubber
is set at six inches of water column. If the differential pressure reaches six, an alarm will
sound on the panel and the packed tower will need to be cleaned.
Normal water flow to the sprays is measured by a flow meter and should be
controlled at the following:
1. Packed Section of the Tower
2. Demister Section
30-40 gpm
4-6 gpm
The yellowcake packaging and enclosure scrubbers' main function is to remove
any dust from the yellowcake packaging process and maintain a slight negative pressure
on the yellowcake dryer and packaging enclosures.
Flow generated by the scrubber fan draws the exhaust dust from the barreling
station and room atmosphere at the yellowcake enclosures. The dusty stream enters the
scrubber near the bottom in the spray section which serves to take out the large particles
from the incoming stream to cool and humidify and wash the bottom of the impingement
plate stage to minimize build up. The impingement plate stages form droplets as the air
stream passes through, which creates an interaction between the gas stream and liquid.
The gas stream then passes through the impingement plates to a stationary, fixed blade
moisture eliminator which removes the water droplets in the gas stream. The scrubber
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 10 of 14
outlet of the scrubber 1s exhausted into the yellowcake stack and released to the
atmosphere. Differential pressure is measured across the yellowcake packaging and
enclosure scrubber with the following parameters utilized. The normal operating range is
between four and six inches of water column. When the manometer reading drops below
3.0 inches water column, the yellowcake scrubber system is shut down to be cleaned.
Normal water flow to the sprays is measured by a flow meter at each spray and
should be controlled at the following:
1. Spray Section
2. Impingement Plates
Total Water Flow
9 -11 gpm
14 -16 gpm
25 gpm
If water flow levels drop below 25 gpm, a low water alarm to the yellowcake
packaging scrubber will sound on the control panel and the scrubber should be cleaned.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Yellowcake Packaging-Operating Procedures
1. Operator will wear coveralls and rubber boots.
2. Operator will wear rubber gloves when operating the circuit.
Date: 12/19 Revision: EFR 6
Page 11 of 14
3. Operator will wear a full-face respirator when in the yellowcake dryer enclosure or
the packaging enclosure.
4. Inspect and calibrate drum scales at the beginning of each shift before weighing
drums.
5. Inspect the packaging scrubber system for proper operating conditions.
6. Each drum is to be identified on two sides and the lid with the following information
and will be performed by a DOT certified shipper prior to loading of materials on the
conveyance:
a. Company name, Company symbol and address
b. Country of Origin
c. UN identification number
d. Lot number
e. Drum number
f. Gross weight (kg)
g. Tare weight (kg)
h. Net weight (kg)
i. The term "Radioactive LSA I"
J. The term "Exclusive Use Type IP-1"
7. Drums are to be inspected before each use for safe conditions.
a. No dents
b. No holes
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
c. No bungs
d. Proper lids
8. Drum lids will be fitted with a new gasket.
Date: 12/19 Revision: EFR 6
Page 12 of 14
9. Drums will be tared before filling and the tare weight marked on the drum lid, on the
side, and on the Product Log Sheet.
10. The tared drum will be placed on the roll conveyor at the west end of the packaging
room and moved through the self-closing doors into the packaging room.
11. Remove the lid from the tared drum.
a. The lid will be placed beside the drum on the scales so that the lid will be
weighed with the drum to get the gross weight of the lid and drum.
12. Position the tared drum directly below the yellowcake storage bin and in the center of
the drum scale.
13. Lower the drum hood down on the drum.
14. Fill the drum by activating the star feeder rotary valve.
15. Fill the drum to full.
a. Do not exceed 1,000 pounds gross weight.
b. Do not overfill the drum and cause spillage.
16. Take a sample of the yellowcake from the top of the drum after it has been filled.
Samples should be labeled as follows:
17.:
a. YC Sample
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
b. Date
c. Lot Number
d. Drum Numbers
18. Composite samples will be made in the lab.
a. C
Date: 12/19 Revision: EFR 6
Page 13 of 14
20. Place the lids on the filled yellowcake drums, activate the roll conveyor, and move
the filled drums through the self-closing doors at the east side of the packaging room.
21. Outside the packaging room, secure the lids on the filled yellowcake drums by
tightening the lid ring bolts.
22. After the lids have been tightened to the drums, place a wire seal on the drum lid ring
bolts.
23. Mark the gross weight, tare weights, drum number, lot number, and date on 1 side
and top of each drum.
24. Record the gross weight, net weight, lot number, drum number, and date on the
Product Log Sheet.
25. Yellowcake will be packaged in drum lots. Lot size will be determined by weight of
yellowcake being packaged.
a. A lot will consist of a designated number of drums as set by mill management.
b. After the designated number of drums in a lot has been filled, proceed to the
next lot number.
c. Each time a lot number is changed, start with drum number one and fill to the
designated drum number.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 2
Date: 12/19 Revision: EFR 6
Page 14 of 14
26. Wash down the packaging area once per shift, or as needed, to keep the area clean.
Safety
1. Extreme care must be taken during the packaging operation to prevent spills and dust.
Any spills that might occur must be washed up immediately. Do not use air hoses to
clean.
2. Coveralls, rubber boots, and rubber gloves are required when packaging yellowcake.
3. Full face respirators are required when entering the packaging enclosure and when
securing the lids on the yellowcake drums.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 3
Yellowcake Precipitation Start Up Procedures
1. Start the number one precipitation tank agitator.
Date: 12/19 Revision : EFR 6
Page 1 of6
2. Start the number one yellowcake thickener rake drive and lower the thickener rakes.
3. Set the number one precipitation tank pH controller to the specified pH parameter.
4. Open the manual ammonia valve to the number one precipitation tank.
5. Turn on the instrument air to the number one precipitation tank automatic ammonia
control valve.
6. Turn on the mill air to the number one precipitation tank ammonia spargue.
7. Start the uranium precipitation feed from the uranium solvent extraction loaded strip
tank.
a. Set the loaded strip flow to maintain a balance with the uranium solvent
extraction strip circuit.
8. Start the required wash water to the number one yellowcake thickener centerwell.
9. Maintain the specified pH in the number one precipitation tank.
10. Set the re-dissolve tank pH controller to maintain a pH of 1.8.
a. Start the re-dissolve tank agitator and air agitator.
b. Open the manual sulfuric acid valve.
c. Start the wash water and set at the flow rate specified by your supervisor.
11. When the underflow density from the number one yellowcake is of appropriate
density, start the underflow pump and pump yellowcake to the re-dissolve tank.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 3
Date: 12/19 Revision: EFR 6
Page 2 of6
Adjust the underflow to the re-dissolve tank to maintain that density in the number
one yellowcake thickener.
12. Start the number two yellowcake precipitation tank agitator.
13. Start the number two yellowcake thickener rake drive; lower the thickener rakes.
14. Start the required wash water to the number two yellowcake thickener centerwell.
15. Set the number two precipitation tank pH controller to the specified pH.
16. Open the manual ammonia valve to the number two precipitation tank.
17. Turn on the instrument air to the number two precipitation tank automatic ammonia
control valve.
18. Turn on the mill air to the number two precipitation tank ammonia sparge.
20. Start the yellowcake dryer (see the yellowcake dryer start up procedures).
21. Start the centrifuge and the yellowcake dryer feed auger (see the centrifuge start up
procedures).
22. When the underflow density from the number two yellowcake thickener is of
appropriate density, start the underflow pump and pump yellowcake to the repulp
tank and feed the centrifuge from the repulp tank, and adjust the underflow to the
centrifuge to maintain that density in the number two yellowcake thickener.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 3
Yellowcake Dryer Start Up Procedures
Date: 12/19 Revision: EFR 6
Page 3 of6
1. Push the panel power switch to the "on" position on the panel face. Alarms will light
and the alarm horn will sound. The horn can be silenced by pressing the "silence"
button, but the lights will remain on until alarm conditions are cleared (i.e.,
equipment start up).
a. Panel power will normally be on unless mill power failure has been
experienced. The alarm will have been silenced, but alarm lights will remain
on until the equipment is re-started.
2. Check and close all hearth doors, including the peep hole doors.
3. Start the dryer scrubber water flow and adjust the flow indicator to the scrubber as
required (normally 20 to 45 gpm). The flow rates are set electronically and cannot be
changed without approval. Proper water flow to the scrubber will clear the alarm
light for the "dryer-scrubber water-low flow."
Purging
1. Close the draft control damper by setting the furnace draft controller at a +0.1 setting.
2. Start the induced draft (I.D.) fan. This will start as long as the scrubber water flow is
proper, the I.D. fan inlet temperature is not high, and the draft control damper is
closed. This will cause a differential pressure switch across the scrubber to cause the
alarm light for the "I.D. fan -low flow" to go out.
3. After the I.D. fan has reached full speed, set the furnace draft controller to a -0.2
setting.
4. Start the combustion air blower. This will cause the "Combustion air blower -low
pressure" alarm light to go out.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 3
Date: 12/19 Revision: EFR 6
Page 4 of6
5. Open the temperature control valves by setting the three temperature controllers to a
temperature setting higher than that indicated on the controller. This will cause the
valves to drive to the high fire position which is necessary to supply maximum purge
air.
6. Start the lump breaker. This will cause the "Lump breaker failure" alarm light to go
out.
7. Start the shaft drive. This will cause the "Shaft drive -low speed" alarm light to go
out after the shaft rotation sensor has been passed by the rotating plate attached to the
shaft.
8. Start the cooling air fan. The "Cooling air fan -low pressure" light will then go out.
This fan should never be stopped when dryer temperatures at any hearth exceed
500°F. (Damage to arms might occur by over-heating.)
Caution: The cooling air fan control is installed utilizing a latching relay. This
means that during a power failure, the fan will naturally turn off, but when power is
restored, the fan will automatically start unless the stop button has been pushed.
9. The low-pressure switch will close and the "Fuel oil supply -low pressure" alarm
light will go out.
Note: As the equipment 1s started, the appropriate alarm lights will go out.
Equipment will not start if the appropriate interlock sequence is not made.
10. If all of the equipment is functioning properly and the temperatures on hearths two,
four, and six are not high (above the present alarm temperatures), the purge timer will
energize and the purge period will be initiated, and the amber purging light will come
on.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 3
Date: 12/19 Revision: EFR 6
Page 5 of 6
11. After the required purge time (this is set at the panel-mounted, key-operated purge
timer) has elapsed, the green "Purge complete" light will come on. The burners can
now be started.
12. Open the manual reset safety shut-off valve for the main fuel. The red fuel safety
valve "open" light will come on when the valve is manually opened.
13. Close the temperature control valves by setting the three temperature indicating
controllers to a temperature setting lower than that indicated on the controller. (This
will cause the valves to drive to the low fire position which is necessary before the
burners can be started.)
14. Light the selected burner(s) by pushing in and holding the start button(s) of those to
be turned on. The pilot must light and be proven by the ultraviolet flame scanner and
then the main fuel valve for the burner to automatically open to establish "main"
flame. When the desired burners have started, the red burner "on" indicator light will
come on and the alarm light for that burner will go out.
a. The burners will operate normally until they are shut off manually by
depressing the stop button, or until a power failure, limit action (including fan
failure), or flame failure at any burner.
b. In the event of a power failure, all lights will go out and all fuel is cut off.
With restoration of power and after the equipment has been started up again as
outlined under the purging section, the "purging" light comes on and the
system automatically repurges. At the end of the purge period, the "Purge
complete" light comes on and the system is ready for another start.
c. Set the three temperature indicating controllers to the desired hearth
temperature and the burners will automatically modulate and vary the firing
rate, as required, to maintain the set-point temperature.
d. When any one of the six burners go off, the burner can be restarted by setting
the temperature indicating controller controlling the temperature on the hearth
White Mesa Mill -Standard Operating Procedures
Book 5 Section 3
Date: 12/19 Revision: EFR 6
Page 6 of6
of the burner to be started must be set at a temperature lower than indicated on
the controller. This is required to drive the temperature controller valve to the
low fire position. Start the burner that is off and then set the temperature
indicating controller to the desired temperature.
15. After operating temperatures have been reached, feeding of the yellowcake material
may start. (Minimum operating temperature on each fired hearth is 1,200°F.)
White Mesa Mill -Standard Operating Procedures
Book 5 Section 4
Yellowcake Precipitation Shut Down Procedures
Date: 12/19 Revision: EFR 5
Page I of 4
1. Shut off the loaded strip feed pump to the number one yellowcake precipitation tank.
a. Start/stop switches and pumps are located in the uranium SX building at the
south side of the loaded strip tank.
2. Wash out the loaded strip feed line with water and drain.
3. Shut off the ammonia and air valves to the number one precipitation tank.
4. Shut off the wash water to the number one yellowcake thickener centerwell.
5. Shut off the number one yellowcake thickener underflow valve.
6. Wash out the number one yellowcake thickener underflow pump and line to the re-
dissolve tank with water.
7. Shut off the number one yellowcake thickener underflow pump.
8. Shut off the acid, and water valves to the re-dissolve tank.
9. Shut off the ammonia and air valves to the number two precipitation tank.
11. Shut off the number two yellowcake thickener underflow valve.
12. Wash out the number two yellowcake thickener underflow pump and line to the
repulp tank.
13. Wash the repulp pump line with water until all yellowcake is removed and then shut
off pump and drain the line.
14. Shut off the number two yellowcake thickener underflow pump.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 4
15. Wash out the centrifuge with water.
a. Add approximately 10 gallons per minute of water.
Date: 12/19 Revision: EFR 5
Page 2 of 4
b. Caution: If too much water is added when washing out the Bird centrifuge,
water will flood into the yellowcake dryer feed auger and put water into the
yellowcake dryer which could damage the dryer.
16. After the centrifuge has washed out, shut off the wash water to the centrifuge.
17. Shut off the bowl wash water on the centrifuge
18. Shut off the centrifuge.
19. Shut off the centrifuge discharge auger that feeds the yellowcake dryer.
20. Shut down the yellowcake dryer as per the shut down procedures as outlined above.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 4
Yellowcake Dryer Shut Down P1·ocedures
Date: 12/19 Revision: EFR 5
Page 3 of 4
1. Ensure that the product feed system has been shut down. (No additional yellowcake
can enter the dryer.)
2. Allow the equipment to operate under normal conditions until all of the yellowcake in
the dryer that can be rabbled out has been discharged into the packaging bin.
3. Lower the temperatures at a rate of 50°F per hour. This is accomplished by adjusting
the temperature indicating controllers on the control panel. Continue to decrease the
hearth temperatures at 50°F per hour until no hearth temperature is above 500°F.
4. Turn the temperature indicating controllers to a set point of 0°F.
5. Shut off all burners.
6. Propane or LNG, depending on the dryer, gas maxie valve will close automatically.
7. Shut off the combustion air blower.
8. Shut off the induce draft fan.
9. Shut off the scrubber water supply.
10. Shut off the shaft drive.
11. Shut off the lump breaker.
12. Allow the dryer heat to dissipate at its own rate.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 4
Date: 12/19 Revision: EFR 5
Page 4 of 4
13. When all of the dryer hearth temperatures are 500°F maximum, the cooling air fan
may be turned off.
Note: As equipment is shut down, the alarms will sound. Push the alarm "silence"
button.
14. Ensure the dryer is closed up (all doors, etc.) and let the heat dissipate at its own rate.
15. Note: Do not open dryer doors as this may result in thermal shock to the refractory.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 5
Date: 12/19 Revision: EFR 3
Page I of l
Yellowcake Precipitation and Drying Emergency Shut Down Procedures
1. Shut off the loaded strip feed pump.
2. Shut off the ammonia and air valves to the number one and two precipitation tanks.
3. Shut off the acid to the re-dissolve tank.
4. Shut off water to the re-dissolve tank.
5. Shut off the water to the number one and two yellowcake thickener centerwells.
6. Shut off the underflow pumps under numbers one and two yellowcake thickeners and
the repulp tank pump.
7. Shut off the centrifuge.
8. Shut off the wash water to the centrifuge.
9. Shut off the burners on the yellowcake dryer.
10. Shut off the scrubber fan on the yellowcake dryer.
11. Shut off the wash water to the yellowcake dryer scrubber.
Power Outages
1. Shut off the ammonia to the numbers one and two precipitation tanks.
2. Shut off the acid to the re-dissolve tank.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 6
Yellowcake Precipitation and Drying -Shift Inspections
Date: 12/19 Revision: EFR 5
Page 1 of2
1. Inspect acid and ammonia lines every four hours for seeps and leaks.
a. Immediately notify your supervisor if any are noted.
2. Inspect for any yellowcake spillage.
a. Clean up all spills immediately.
3. Inspect guards on all moving equipment once per shift for condition and if in place.
a. If guards are not in place, shut off the equipment, lock out, and install the
guard.
b. Notify your supervisor if the guards are not in good condition.
4. Inspect all moving equipment for proper operating condition.
a. Notify your supervisor if problems are noted.
5. Inspect and calibrate the density scales once per shift.
6. Inspect the yellowcake thickeners and precipitation tanks once per shift for leaks.
a. Immediately notify your supervisor if the fans are not operating or problems
are noted.
7. Inspect the roof fans for proper operation every four hours.
a. Immediately notify your supervisor if the fans are not operating or problems
are noted.
8. Inspect the yellowcake dryer burners every two hours for fuel leaks.
a. Immediately notify your supervisor if any leaks are noted.
9. Inspect the yellowcake dryer scrubber system every two hours for proper water flow
and draft.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 6
a. Adjust water flow as needed.
b. Adjust draft as needed.
Date: 12/19 Revision: EFR 5
Page 2 of2
c. If conditions cannot be adjusted to the proper operating conditions, shut down
the dryer circuit, and notify your supervisor immediately.
10. Inspect the yellowcake dryer arms and rabbles every four hours for breaks.
a. If any are noted, shut off the feed to the dryer, shut off the shaft drive, and
notify your supervisor immediately.
11. Inspect the area for good housekeeping every four hours.
12. Clean areas as needed.
13. Documentation of issues raised during the inspections should be indicated on the
Operating Foreman's Daily Inspection form.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 7
Date: 12/19 Revision: EFR 6
Page 1 of6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the processing of
uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance break room
and central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department, along with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 7
Date: 12/19 Revision: EFR 6
Page 2 of 6
Information Contained on Safety Data Sheets
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Phy ical De cription
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
temperatures (68°F -77°F).
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 7
Date: 12/19 Revision: EFR 6
Page 3 of 6
Vapor Pressure The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V./T.W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting ( eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15-minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
White Mesa Mill -Standard Operating Procedures
Book 5 Section 7
Date: 12/19 Revision: EFR 6
Page 4 of 6
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over but will not continue to burn without the addition of
more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 7
Date: 12/19 Revision: EFR 6
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 7
Date: 12/19 Revision: EFR 6
Page 6 of6
Forthe
Environment
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Yellowcake Precipitation and Drying
1. Sulfuric Acid --93 to 95% strength
2. Ammonia
3. Propane
4. Natural Gas
White Mesa Mill -Standard Operating Procedures
Book 5 Section 8
Spill/Disposal Procedures
Date: 05/16 Revision: EFR 5
Page 1 of2
All spills, no matter the size, shall be reported on an Orange Card and submitted to the
Environmental Coordinator as soon as possible. The Orange Card is in response to a
Stormwater Inspection from October 2011.
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The SDS forms for all chemicals used in Uranium Recovery Operations are
listed, along with an indication of which chemicals have reporting obligations. The
following is an explanation of the actions required of the Mill Operator when dealing
with these chemicals. Without exception, your supervisor will make any required
reports. Ref er to Emergency Response Plan for specific details regarding spill
procedures.
Resource Conservation and Recovery Act (R.C.R.A.)
R.C.R.A. regulates the manner in which hazardous materials can be disposed. The
specific requirements will be delineated with by the Environmental Department. If you
need to dispose of any chemicals, contact your supervisor for instructions. The
containers that held these products may be disposed of in any trash receptacle if:
1. The container has less than 5% left in the bottom, or
2. The container has been triple rinsed into any mill sump.
Spill Reporting
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity and type of chemical spilled. A reportable spill is
basically when the chemical hits the ground (earth), as opposed to a spill to a concrete
pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your supervisor. Your
supervisor will determine if a report to an agency is necessary. Your supervisor will
make the report, if needed. Do not attempt to make a report yourself. If there is any
doubt, contact your supervisor for advice and direction.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 8
Date: 05/16 Revision: EFR 5
Page 2 of2
State of Utah Division of Waste Management and Radiation Control (DW.MRC)
The DWMRC must be notified if a spill and/or accident causes more than $2,000.00 worth of
damage or 24 hours of down time. If either of these conditions exist and is unknown by your
supervisor, contact your supervisor immediately. Your supervisor will make any required
reports.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 9
Hazards in the Yellowcake Circuit
1. Sulfuric acid -93% to 95% strength
2. High pressure steam lines -100 psi
3. High pressure air lines -100 psi
4. High pressure ammonia lines -100 psi
5. Ammonia fumes
6. Elevated walkways
7. Propane and natural gas
8. Yellowcake dust
9. Yellowcake ingestion
10. High yellowcake dryer temperatures -1,400°F.
Date: 12/19 Revision: EFR 2
Page 1 of 4
11. Moving heavy yellowcake drums -1,000 pounds gross weight
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 9
Date: 12/19 Revision: EFR 2
Page 2 of 4
Hazard Recognition -Yellowcake Precipitation and Packaging
1. Hazards
a. Sulfuric Acid Lines
1. Open slowly
2. Use personal protective equipment
b. Ammonia
1. Open valve slowly
2. Use personal protective equipment
3. Report leaks promptly
4. Adjust pH properly so as not to use excessive ammonia
c. Steam Lines and Valves
1. Open valves slowly
2. Caution -hot valve handles
d. Air Lines and Valves
1. Open valves slowly
2. Whip checks on hose connections
3. Do not use to blow off clothing
e. Guards
1. Pump
2. Drive units
3. Centrifuges
4. Driven rollers
5. Augers
f. Bird Centrifuges
1. Lock out when operator changes keys
White Mesa Mill -Standard Operating Procedures
Book 5 Section 9
Date: 12/19 Revision: EFR 2
Page 3 of 4
2. Check guards on auger before working on centrifuge
g. Health Hazards
1. Ammonia
2. Sulfuric acid
3. Airborne uranium
4. Beta -Gamma -Radon Daughters
a. Yellowcake precip
b. Enclosure
C. Centrifuge area
d. Packaging area
e. Scrubber -barometric tank
5. Radiation Work Permit will be issued for any work for any department
other than operations.
6. Sampling will be done in this area on a regular basis.
a. Radon-monthly
b. Airborne
1. Weekly
2. Monthly
c. Ammonia
1. Monthly or whenever the need arises
d. Silica
1. At least two samples yearly
h. Decks and Walkways
1. Slippery after a washdown
2. Hoses in walkway and on deck
3. Sample cup is long-handled
1. Heat
1. Dryer enclosure -up to 150°F.
2. Scrubber deck -off gas drying ducting
White Mesa Mill -Standard Operating Procedures
Book 5 Section 9
o. Scrubbers
Date: 12/19 Revision: EFR 2
Page 4 of 4
White Mesa Mill -Standard Operating Procedures
Book 5 Section 10
JOB PROCEDURES
Date: 05/16 Revision: EFR 4
Page 1 of 5
This section covers job procedures for non-daily routine jobs that are performed
m:
YELLOWCAKE PRECIPITATION, DRYING, AND PACKAGING
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 10
Date: 05/16 Revision: EFR 4
Page 2 of5
Procedures for Preparing Yellowcake Drums and Shipping
Purpose: Cleaning, inspecting, preparing, and shipping drums of yellowcake.
1. Yellowcake lots are stored in drums which may be stacked two high in the Energy
Fuels Resources (USA) Inc.' s storage yard.
2. Each lot will have to be moved so that each drum can be inspected and prepared for
shipping and/or storage.
3. As an ALARA measure, lots will be isolated from other lots, or moved to the
equipment shop for preparation.
4. Inspecting and preparing drums consists of the following steps:
a. Check for any holes in the top, bottom, and sides of the drum. (Notify your
supervisor before repairing drums -a Radiation Work Permit will be
required.)
b. Check that lids and rings are properly secured and tightened.
c. All rust is to be cleaned from drums and when drums are repainted. (Wear a
face shield when using and electric wire brush; wear a leather jacket and
pants; use only heavy duty woven wire brushes when grinding.)
d. All drum numbers, lot numbers, dates, and weights are listed on each drum
and are legible.
e. All drum numbers, lot numbers, dates, and weights are correct.
5. Safety is the most important aspect of the job. Do not rush the job to be done.
a. Always keep people away from the drums when lifting the drums from a stack
or when moving the drums to prevent dropping them on someone or getting a
person in a pinch point.
b. Remember -the drums can weigh up to 1,000 pounds.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 10
Date: 05/16 Revision: EFR 4
Page 3 of 5
c. Do not use mobile equipment unless you have been trained and signed off by
a qualified instructor.
d. Do not use a blasting machine until you have been trained and signed off by a
qualified instructor.
e. Always wear proper protective equipment when performing the job.
f. Use ground fault receptacles on electrical equipment.
g. Do not use any defective equipment.
h. Always contact your supervisor with any problems or questions.
1. Read and understand all SDS for paints and thinners used.
J. Mobile equipment will be inspected at the beginning of each shift and a
Mobile Check List will be filled out and signed.
Procedures
1. Move drums from stacked lots and place on ground space so that sides and tops can
be easily inspected and prepared as necessary. The bottoms of the drums are to be
inspected by lifting the drums with a forklift and visually checking for leaks and rust.
Do not get under the drums when checking or cleaning and painting the bottoms.
2. After the drums are placed on the ground, tap the lids and rings with a rubberhead
hammer and watch for any dusting. (Important: full-face respirators with a proper
canister must be worn during this procedure to prevent the inhalation of dust if there
is a leak.)
3. After the drums have been checked for leaks, remove any rust from the drums and
paint those areas. Paint any areas where the metal is bare.
4. Inspect labeling and numbers on the tops and sides of each drum making sure all are
legible.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 10
Date: 05/16 Revision: EFR 4
Page4 of5
5. Check the drum number, date, lot number, gross weight, tare weight, and net weight
on the tops and sides of each drum against the numbers on the master sheet given you
by the accounting department.
a. If numbers do not match exactly, note on the master sheet and notify your
shift foreman.
6. Loading of drums onto the truck:
a. Place the truck loading ramp up to the truck trailer.
b. Chain the ramp to the truck trailer after placing the ramp up to the trailer so
that the ramp cannot move away from the trailer.
c. Secure the truck trailer by chocking the rear wheels so that the trailer cannot
move.
d. Inspect the ramp after placing it at the trailer to be sure chains and blocks are
secure.
e. Do not use the ramp at any time if there are any defects in the ramp, chains, or
blocks.
f. Drums have to be scanned by trained personnel for surface contamination
prior to loading on the truck.
g. Prior to the truck leaving the yard area, scanning has to be done for gamma on
the truck cab and trailer. The trailer has to be placarded and the driver has to
receive our driver's shipping packet.
Precautions
1. Do not clamp barrel too tightly with the forklift.
a. It will bend the sides of the drums.
b. It will cause the lid to leak around the ring.
2. Do not clamp the barrel too lightly with the forklift.
a. It will fall and spill the material.
b. It will fall and could injure someone.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 10
3. Always wear proper protective equipment.
4. Do not hurry or rush -use caution at all times.
5. Do not use defective equipment.
Date: 05/16 Revision: EFR 4
Page 5 of5
6. Always wear a face shield and leather jacket and pants when using the electric wire
brush to remove rust from the drums.
7. Always wear a respirator with the correct canister when blasting and painting.
8. Watch for pinch points. Fingers could be smashed between drums when moving them
by hand.
9. Follow all safety rules and procedures.
10. Report any spills of yellowcake to your supervisor immediately.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
Date: 12/12 Revision: EFR 3
Page 1 of 9
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Ore Receiving, Feed Operator, and Grind.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
..
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
GENERAL RULES
Reporting Unsafe Conditions and lniuries
Date: 12/12 Revision: EFR 3
Page 2 of9
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal P1·otective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area-except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
c. Rubber gloves and rubber boots
Date: 12/12 Revision: EFR 3
Page 3 of9
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs, or having them in
your possession while in the plant area.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
Date: 12/12 Revision: EFR 3
Page 4 of9
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
Date: 12/12 Revision: EFR 3
Page 5 of 9
MOBILE EQUIPMENT -SAFETY RULES
General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be driven
to the shop for repairs. Otherwise, the equipment must be towed or repaired at the
location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
Date: 12/12 Revision: EFR 3
Page 6 of9
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
11. Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
Date: 12/12 Revision: EFR 3
Page 7 of 9
OPERA TIO NS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
8. Safe operation of conveyors requires that you shall:
Date: 12/12 Revision: EFR 3
Page 8 of9
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
Safety Rules -Yellowcake Precipitation, Drying, and Packaging
1. If any part of the dust collecting system for the drying and packaging facility is not
working, the operation shall be shut down at once.
2. Operators in this area are required to shower at the end of each shift.
3. All clothing used in the yellowcake area must be washed daily.
4. All spills and dust leaks shall be cleaned up at once and the cause corrected
immediately.
When any non-routine (i.e., maintenance, clean up work) is to be performed in the
yellowcake area, the radiation safety office shall be notified as far in advance of
doing the work as possible.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 11
SAFE WORK PERMIT
Date: 12/12 Revision: EFR 3
Page 9 of9
Issued by: ___________ Date: ________ Time: ____ _
For Dept.: ___________ In area: ______________ _
Task to be performed: _______________________ _
Permit good until: _________________________ _
Confined space hazard evaluation completed by: ______________ _
REQUIRED PRECAUTIONS
Safety Dept. approval for confined space entry
Relieve vac/pressure
Equipment & lines drained, washed out, and
ventilated
Atmosphere checked for explosion, toxicity, and
oxygen (see Safety Department)
Continuous air monitor
Radiation work permit
Shower and eye wash checked
Drive mechanisms locked out
Chemical and gas inlets locked and blanked
Steam, air, and high volume lines locked
and disconnected
Special zero energy considerations
Openings roped off or guarded
Proper ladder tied off
Ground fault interrupter
Disconnect level indicators, etc.
Class 1 Division 1 explosion proof lights
Proper bonding and grounding of equipment and
material will be verified for permissible OHMS
resistance by a qualified electrician
Fire extinguisher and/or charged hose
Test welding hose for leaks
Qualified safety watch
Stay clear when lifting materials overhead
PERSONAL PROTECTIVE EQUIPMENT
Splash goggles □ Face shield □
Rubber boots □ SCBA □
Safety belt & line 0
Rubber suit 0
F.F. respirator 0
COMPLETED BY
Latex nitril gloves 0
Hearing protection □
Other equipment _____________________________ _
Special instructions ____________________________ _
Job completed: Date Supervisor __________ _
Reviewed by: Dept. Head _________ Safety Department
White Mesa Mill -Standard Operating Procedures
Book 5 Section 12
Date: 12/12 Revision: EFR 3
Page i of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for ore receiving and grind which,
when followed, will maintain your exposures ALARA. Remember, you are the person
most responsible for controlling your radiation exposure. If the Radiation Safety
Procedures are followed and protective equipment is utilized correctly, your exposure
will be maintained ALARA.
Yellowcake Precipitation, Drying, and Packaging Safety Procedures
1. ALARA Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the ALARA program shall result in radiation exposures being maintained
to levels far below any applicable limits of the NRC regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
continuous reviews of radiation, environmental and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
White Mesa Mill -Standard Operating Procedures
Book 5 Section 12
Date: 12/12 Revision : EFR 3
Page 2 of 5
initial assessment of the work environment and associated work tasks as related to
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. The jobs mentioned below at yellowcake precipitation, drying, and packaging
will require a Radiation Work Permit:
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at yellowcake precipitation, drying and packaging
may require a Radiation Work Permit if the initial radiological assessment
indicates a potential for elevated radiation exposure:
1. Entry into thickeners or enclosed tanks.
2. Entry into the yellowcake dryer or packaging enclosures by anyone
other than the Operator unless covered by a written procedure.
3. Cleaning out the sumps.
4. Cleaning the yellowcake packaging and dryer scrubber system by
personnel other than the Operator. Repairs or cleaning of yellowcake
duct work. Repairs or replacement of process lines.
5. Addition of any clean up materials into the yellowcake sumps
6. Sandblasting the yellowcake dryer and packaging scrubber fans.
This is not an all-inclusive list of jobs at Yellowcake precipitation, drying and
packaging that could require a Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
White Mesa Mill -Standard Operating Procedures
Book 5 Section 12
Date: 12/12 Revision: EFR 3
Page 3 of 5
As a part of ALARA practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon daughter concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% DAC. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon daughter concentrations above 25%
DAC:
a. Airborne uranium concentrations at the yellowcake dryer and packaging
enclosure average 300% DAC. Full-face respirators and protective clothing
are required when entering the yellowcake dryer and packaging enclosures.
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. At the White Mesa Mill facility, there is only one cartridge used. The
cartridge is for nuisance dusts, chemical mist and radiological dust.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 12
5. Radiation Safety Procedures
Date: 12/12 Revision: EFR 3
Page 4 of 5
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your dosimetry badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas. (full-face respirator), if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions.
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
White Mesa Mill -Standard Operating Procedures
Book 5 Section 12
Date: 12/12 Revision: EFR 3
Page 5 of5
Routine urinalysis samples for operators at yellowcake areas will be taken every two
weeks. Urinalysis samples are utilized to determine the uranium content contained in
the urine of the operator. The frequency of sampling is dependent on the airborne
concentrations and will be changed if airborne levels exceed 25% of the airborne
standards.
To minimize the change of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing
into your work clothes or reporting to your work location. The samples can
then be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 13
Date: 12/12 Revision: EFR 2
Page I of 4
OPERATOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate departments within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
1. If a sample 1s contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 13
Date: 12/12 Revision: EFR 2
Page 2 of 4
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building and bioassay laboratory.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid ½ hour of
overtime to shower.
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
White Mesa Mill -Standard Operating Procedures
Book 5 Section 13
Date: 12/12 Revision: EFR 2
Page 3 of 4
survey. If the alarm sounds again, contact the Shift Radiation Technician, Radiation
Safety Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
White Mesa Mill -Standard Operating Procedures
Book 5 Section 13
Date: 12/12 Revision: EFR 2
Page 4 of 4
I have read, understood and have had the opportunity to ask questions regarding the
procedures set forth in this book.
Date __________ _
Name (print) ____________ _
Name (signature) ___________ _
White Mesa Mill -Standard Operating Procedures
Book 6 Section 1
INTRODUCTION
Mill Process
Date: 12/19 Revision: EFR 5
Page 1 of 1
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a slurry in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium (when present) is recovered from the barren uranium raffinate also utilizing a
solvent extraction circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered,
dried, melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent extraction
control room, vanadium control room, grind circuit below the derrick screens and in the
upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined, and now implements, a
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 2
Date: 12/19 Revision: EFR 4
Page 1 of 4
VANADIUM SOLVENT EXTRACTION
The purpose of the vanadium solvent extraction circuit is to extract the vanadium
from the vanadium bearing acid solution produced at leach when leaching ore and
prepare it for further processing.
The vanadium SX circuit consists of six extractor settlers: one acid wash, two
strippers, one loaded strip holding tank, one soda ash holding tank, three EMF adjustment
tanks, two oxidation tank, and one SX feed tank.
Organic is. used to extract the vanadium from the vanadium bearing solution from
leach. The organic is a mixture of kerosene, amine and TDA.
Each of the six extractors is designed with an overflow weir, underflow weir, and
two mix tanks and is operated in a counter-current cycle. Each extractor has an organic
recycle line with a manually operated valve. The valves are generally run in the full,
open position with the purpose of getting as much organic as possible to contact the
vanadium bearing solution. The mixer pulls the organic from the overflow weir of its
own extractor, through the recycle line, and back into the extractor mixer. The barren
organic is pumped to the number six extractor "A" mix tank and flows in a reverse order
of six, five, four, three, two, and one. The mixer of each extractor works as a pump
pulling the organic from one extractor while also pulling the vanadium bearing solution
from the opposite extractor.
Example: The "A" mixer of the number two extractor pulls the organic from the
overflow of the number three extractor and, at the same time, pulls vanadium bearing
solution from the underflow of the number one extractor, and also pulls extra organic
back through the recycle line. The mixing process allows the organic to contact the
vanadium bearing solution, thus extracting the vanadium from the solution and loading it
onto the organic.
When vanadium ores are processed in the mill, the ore also contains uranium.
After the uranium SX has extracted the uranium out of the solution, the solution still
contains the vanadium and now becomes the feed for the V 20s SX.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 2
Date: 12/19 Revision: EFR 4
Page 2 of 4
The feed is pumped from the number four uranium extractor underflow to the
number one adjustment tank where ammonia is added to bring the pH of the solution up
to a specified control point. The solution then overflows into the number two adjustment
tank where liquid chlorate is added at a controlled rate. This solution is then pumped to
the west oxidation tank to allow the solution to react with the chlorate and ammonia. The
solution overflows the west oxidation tank to the number three adjustment tank where
chlorate and/or ammonia can be added if needed.
The solution can now be pumped to the east oxidation holding tank or it can be
bypassed straight to the VSX feed tank. If it is pumped to the oxidation tank, the purpose
is for retention time to allow the chlorate and ammonia time enough to oxidize the
solution. The solution then overflows into the VSX feed tank and is then pumped into
the mixer of the number one extractor and is mixed with organic. The mixed material
overflows into the main body of the extractor where the organic and vanadium bearing
solution are allowed to separate. The organic rises to the top and overflows to the acid
wash. The vanadium bearing solution stays on the bottom and flows through the
underflow weir to the number two extractor "A" mixer.
As the solution moves through the extractors, ammonia can be added at the weir
end of each extractor to slowly bring the pH up. If the pH is taken up too high
precipitates are formed which creates emulsions. An emulsion is when the organic and
the solution will not separate. The pH has to be brought back down to achieve the
separation needed for a good extraction process. The higher the pH can be raised
(without forming an emulsion), the better extraction you will achieve. When the solution
has flowed through all six extractors, it will be virtually free of vanadium and becomes
barren solution and is pumped to a tailings pond.
The organic which has traveled through all six extractors is now loaded with
vanadium. The organic is then pulled to the acid wash where it is mixed with water. The
water washes out impurities that are considered waste, such as iron, etc. The loaded
organic then moves into the strip circuit. The strippers are numbered one and two and
have a two-mixer mixing system.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 2
Date: 12/19 Revision: EFR 4
Page 3 of 4
Concentrated soda ash, caustic soda and water are used to strip the vanadium from
the organic. Soda ash and water are added to the number two stripper mixer. Caustic is
added as needed to maintain appropriate pH levels. When the strip solution reaches the
underflow weir of the number one stripper, it is loaded with vanadium and is pumped to
the loaded strip holding tank which is then pumped to the vanadium precipitation circuit.
Each stripper has a recycle line, but unlike the extractors which recycle the
organic, the strippers recycle the strip solution (or the underflow) with the same purpose
of more contact with the organic for maximum stripping of the organic. Each recycle line
has a manually operated valve for control organic to aqueous ratio in the mixer.
Stripped organic from the overflow of the number two stripper is then pumped to
the barren organic holding tank. The barren organic contains a small amount of aqueous
carryover and will go to the barren organic tank with the organic. The aqueous solution
contains soda ash and is a high pH. The aqueous settles to the bottom of the barren
organic tank. There is an aqueous bleed pump that pumps the aqueous out of the tank to
the number one strip "A" mixer. If the aqueous is not pumped from the barren organic
tank, it will be pumped to the number six extractor mixer with the barren organic and will
cause foaming and emulsion in the number six extractor.
Caustic soda used in this process is stored in a bulk holding tank outside the north
end of the SX building.
Soda ash is stored in a dry holding bin on the north side of the SX. The dry soda
ash is augured into a wet tank where a specified specific gravity is obtained.
Liquid soda ash can then be pumped inside the building to the day tank and used
as needed for the strippers.
The controls, start/stop switches, indicators, readouts, and alarms are located on
any of the control room computers.
The power supply, main electrical disconnects, overhead light switches, and
overhead fan switches for all associated equipment are located in the SX MCC room
which is located on the north end of the SX building (a small cinder block building
attached to the SX building).
White Mesa Mill -Standard Operating Procedures
Book 6 Section 2
Safety Procedures
Date: 12/19 Revision: EFR 4
Page 4 of 4
Because of the flash point of the kerosene used in the SX building, the following
rules normally apply:
1. No gasoline driven engines are allowed in the building at any time.
2. No matches, lighters, or any spark producing items are allowed in the building.
3. No cutting, welding, or grinding is allowed in the building without a Safe Work
Permit.
4. All electric motors used in the SX have to be explosion proof.
5. Should maintenance activities require the use of cutting, welding or grinding devices,
the atmosphere must be monitored for the appropriate hazard and work must proceed
after a safety analysis has been performed and a Safe Work Permit issued.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 3
Vanadium Solvent Extraction Start-Up Procedures
1. Notify your supervisor you are ready to start the circuit.
Date: 12/19 Revision: EFR 5
Page 1 of2
2. Notify the Vanadium Precipitation Operator that the vanadium SX is starting up.
3. Notify the Uranium SX Operator to start the feed to the vanadium SX circuit (same as
number 11).
4. Set the feed flow indicator for the desired gpm feed.
a. Open the automatic feed control valve.
5. Set the organic flow indictor for the desired gpm organic.
a. Open the automatic organic control valve.
6. Start the raffinate pump.
7. Start numbers one through six extractor mix tank agitators.
8. Start numbers one and two stripper mix tank agitators.
9. Start the barren organic feed pump.
10. Start the barren organic return pump.
11. Start the vanadium SX feed pump (number four uranium SX raffinate pump).
12. Start the feed pump to the number one extractor mix tank (VSX feed tank pump).
13. Start the number two pH adjustment tank overflow pump.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 3
14. Start the number three pH adjustment tank overflow pump.
15. Start the barren organic aqueous return pump.
Date: 12/19 Revision: EFR 5
Page 2 of2
16. Start the soda ash strip pump to the number two stripper mix tank.
17. Start the caustic pump to the number two stripper mix tank.
18. Turn on the ammonia to the numbers one and three pH adjustment tanks and set the
correct pH value on the control computer.
19. Turn on the chlorate to the numbers two EMF adjustment tank.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 4
Vanadium Solvent Extraction Shutdown Procedures
Date: 12/12 Revision: EFR 3
Page 1 of2
When both of the uranium and vanadium solvent extraction circuits are operating,
both circuits will have to be shut down simultaneously to avoid overflowing extractors,
strippers, and tanks, etc.
1. Shut off the vanadium feed pump (number four uranium extractor underflow pump).
2. Shut off the organic feed and return pumps.
3. Shut off the extractor, acid wash, and stripper mix agitators.
4. Shut off the pH adjustment tank pumps and mixers.
5. Shut off the oxidation tank pumps and mixers.
6. Shut off the strip feed pumps.
7. Shut off the loaded strip pumps.
8. Shut off the acid wash spent solution pump.
9. Turn all gpm controllers to manual and close the automatic valves.
10. Close the manual valves upstream of the feed pumps.
11. Shut off the chlorate, steam, and ammonia to the adjustment tanks.
12. Flush loaded strip lines with water; drain water from the lines.
13. Flush strip lines with water; drain water from the lines.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 4
Date: 12/12 Revision: EFR 3
Page 2 of2
14. Flush the soda ash and caustic lines with water; drain water from the line.
15. Make a walk-around inspection to ensure that all valves are shut and the solution has
stopped flowing.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 5
Date: 12/12 Revision: EFR 3
Page 1 of2
Vanadium Solvent Extraction Emergency Shut Down Procedures
1. Notify the Uranium SX Operator to shut off his feed.
2. Shut off the chlorate to the numbers two and three adjustment tanks.
3. Shut off the ammonia to the numbers one and three adjustment tanks.
4. Shut off the steam to the adjustment tanks.
5. Shut off the lean organic pump.
6. Shut off the extractor and strip mixer agitators.
7. Shut off the soda ash valve to the strippers.
8. Shut off the caustic valve to the strippers
9. Shut off the raffinate pump.
10. Shut off the manual ammonia valves to the extractors.
11. Shut off the adjust tank overflow pump.
12. Shut off the number one extractor feed pump.
Power Outages
1. All electrical equipment will shut down.
2. Close the automatic feed valves.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 5
Date: 12/12 Revision: EFR 3
Page 2 of2
3. The automatic feed valves will close when the mill air is spent.
4. If the power outage lasts for more than five minutes, close all manual upstream feed
valves and wash out all solution lines as outlined in the shutdown procedures.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 6
Date: 12/12 Revision: EFR 3
Page 1 of2
Vanadium Solvent Extraction Shift Inspection -Operators Only
1. Inspect safety showers and eye wash fountains during the first hour of the shift for
proper operating conditions.
a. Immediately notify your supervisor if they are not working properly.
2. Inspect the area for good housekeeping during the first hour of the shift.
a. Clean up any spills, wood, paper, etc., as noted.
3. Inspect caustic, sulfuric acid, and ammonia lines every four hours for leaks.
a. Immediately notify your supervisor if any leaks are noted.
4. Inspect organic lines, feed lines, and solution lines every four hours for leaks.
a. Notify your supervisor if any are noted.
5. Inspect motors on pumps every four hours to be sure they are not running hot.
a. Immediately notify your supervisor if a motor is found to be running hot.
6. Inspect all equipment for proper guards and guards in place once per shift.
a. Shut off equipment, lock out, and replace a guard if the guard is not in place.
7. Inspect roof fans every four hours for proper operation.
a. Immediately notify your supervisor if any problems are noted.
8. Inspect the chlorate line every four hours for seeps or leaks.
a. Immediately notify your supervisor if any leaks or seeps are noted.
9. Inspect the oxidation thickener for leaks once per shift.
a. Notify your supervisor if any are noted.
10. Inspect the adjustment tanks once per shift for leaks.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 6
a. Notify your supervisor if any are noted.
Date: 12/12 Revision: EFR 3
Page 2 of2
White Mesa Mill -Standard Operating Procedures
Book 6 Section 7
Date: 05/16 Revision: EFR 5
Page 1 of 6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance office and
central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department, and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
Information Contained on Safety Data Sheets
White Mesa Mill -Standard Operating Procedures
Book 6 Section 7
Date: 05/16 Revision: EFR 5
Page 2 of6
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Physical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 7
Date: 05/16 Revision: EFR 5
Page 3 of6
Vapor Pressure The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V./T.W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
White Mesa Mill -Standard Operating Procedures
Book 6 Section 7
Date: 05/16 Revision: EFR 5
Page 4 of6
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material bum or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to bum without the addition
of more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will bum or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to bum; above the upper flammable limit, the mixture
is too rich to bum.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 7
Date: 05/16 Revision: EFR 5
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 7
Date: 05/16 Revision: EFR 5
Page 6 of6
For the
Environment
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Vanadium SX
Some of the major chemicals used in the Vanadium SX process areas are listed as examples:
1. Sulfuric Acid --93 to 95% strength
2. Kerosene
3. Organic Amines
4. Caustic Soda -50% strength
5. Caustic Soda Beads -98.5% strength
6. Decy 1 Alcohol
7. Salt
8. Soda Ash
9. Ammonium Sulfate
10. Sodium Chlorate
11. Chemfac 100
12. Ammonia-Liquid and Vapor
White Mesa Mill -Standard Operating Procedures
Book 6 Section 8
Hazards in the Solvent Extraction Building
Uranium and Vanadium SX
Date: 12/19 Revision: EFR 5
Page 1 of 6
1. Fire -There are approximately 200,000 gallons of kerosene in the SX extractors
2. Sulfuric acid-93% to 95% strength
3. Ammonia
4. High pressure steam lines -100 psi
5. High pressure air lines -100 psi
6. Chlorate
7. Caustic
8. Slippery floors if organic is spilled on them
9. Acid solutions
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 8
Fire Potential in the Solvent Extraction Building
Date: 12/19 Revision: EFR 5
Page 2 of6
Potential for fires in the SX building is present due to the 200,000 gallons of
kerosene used in the extractors. The kerosene has a flashpoint of 180 °F.
The Operator is to always be on the alert for:
1. Motors on pumps running hot.
2. Motors on settler mixers running hot.
3. Spills of chlorate -chlorate and kerosene together are a very dangerous combination.
A fire could start by the two materials coming in contact with each other.
4. Wood or paper in the SX circuit could cause a fire if they become saturated with
kerosene.
5. Sulfuric acid spills -spills of sulfuric acid on the floor will generate enough heat to
cause kerosene to ignite.
6. Any welding or cutting in the building -sparks from cutting or welding could cause a
fire.
7. Any open flames such as cigarettes or cigarette lighters -these items are prohibited in
the SX building.
8. Any gasoline mobile equipment in the SX building -gasoline mobile equipment is
prohibited in the SX building as the sparks from the ignition system could cause a
fire.
All uranium and vanadium SX operators must always practice good operating
procedures to prevent spills in the SX building and good housekeeping practices to be
sure no flammable materials are lying around in the area of the SX building. Operators
are to know and understand the operation of the automatic foam fire system in the SX
building and know and understand how to operate and effectively use the chemical fire
extinguisher also in the SX building.
You, as operators, have the responsibility to help prevent potentials for fire. You
have the responsibility and authority to prevent any person from entering or working in
the SX building if they do not follow all rules and regulations required for fire
White Mesa Mill -Standard Operating Procedures
Book 6 Section 8
Date: 12/19 Revision: EFR 5
Page 3 of6
prevention. If at any time you have a question or doubt about a situation that you think
might be a fire hazard, notify your supervisor immediately.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 8
Hazard Recognition -SX Circuit
1. Hazards
a. Sulfuric Acid Lines
1. Open slowly
2. Use personal protective equipment
b. Caustic Tank and Lines
1. Open valve slowly
2. Use personal protective equipment
Date: 12/19 Revision: EFR 5
Page 4 of 6
3. Air pressure during unloading is to be no more than 30 psi
C. Ammonia Tanks and Lines
1. Open valves slowly
2. User personal protective equipment
3. Report leaks promptly
d. Kerosene Tanks and Lines
1. Open valves slowly
2. Use caution around pumps and guards
3. Use personal protective equipment
e. Soda Ash Bins and Tanks
1. Use caution around the pumps and feed auger
2. Personal protective equipment
3. Open valve slowly
4. Open steam lines slowly
f. Sodium Chlorate Tanks and Lines
1. Open valves slowly
2. Caution around pumps
3. Use personal protective equipment
g. Amines
1. Burning and/or itching
2. Caution when dumping drums
h. Air Lines
White Mesa Mill -Standard Operating Procedures
Book 6 Section 8
1. Open valves slowly
2. Whip checks on hose connections
3. Do not use to blow off clothing
1. Steam Lines
1. Open valves slowly
2. Valves are hot
J. Fire Systems
1. Overhead sprinkler system (FDAM)
2. Fire extinguishers
Date: 12/19 Revision: EFR 5
Page 5 of6
3. Three five minute escape bottles in the SX observation platform
4. Four SCBA -two are located at each end of the building
5. Know where the exits are
k. Health Hazards
1. Sulfuric acid
a. Burns -flush with water for at least 15 minutes
b. Fumes -a respirator is required
2. Caustic Soda
a. Burns -flush with water for at least 15 minutes
3. Ammonia
a. Fumes -a respirator is required
b. Large spill or fire requires a Scott Air Pack
c. Burning -flush with water for at least 15 minutes
4. Kerosene
a. Burning and/or itching -wash with soap and water
5. Amines
a. Burning and/or itching -wash with soap and water
6. SodaAsh
a. Burning and/or itching -flush with water for at least 15
minutes
7. Sodium Chlorate
White Mesa Mill -Standard Operating Procedures
Book 6 Section 8
a. Fire hazard
Date: 12/19 Revision: EFR 5
Page 6 of6
1. Rubber gear, boots, gloves, goggles, or face shield
2. Discard clothing if contamination with chlorate shows
b. Chlorine gases
1. pH adjustment tank
2. Times when a respirator is required
1. Gamma Radiation
1. Posted for gamma on the SX uranium extractor mix tanks
2. Uranium SX feed line
m. Ladders
1. Ladder on the caustic tank
2. Ladders on the soda ash tanks
3. Ladders on the salt tanks
4. Ladder to the sump -chain must be in place
5. SX VPL feed tank
6. Strip make up tanks
n. Decks and Grating
1. Slippery when wet
o. Airborne Uranium Radon Daughters
White Mesa Mill -Standard Operating Procedures
Book 6 Section 9
JOB PROCEDURES
Date: 12/12 Revision: EFR 3
Page 1 of I
This section covers job procedures for non-daily routine jobs that are performed
in:
VANADIUMSX
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
Date: 12/12 Revision: EFR 3
Page I of IO
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Ore Receiving, Feed Operator, and Grind.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
GENERAL RULES
Reporting Unsafe Conditions and Injuries
Date: 12/12 Revision: EFR 3
Page 2 of 10
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
c. Rubber gloves and rubber boots
Date: 12/12 Revision: EFR 3
Page 3 of 10
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs, or having them in
your possession while in the plant area.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
Date: 12/12 Revision: EFR 3
Page4 of 10
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
Date: 12/12 Revision: EFR 3
Page 5 of 10
MOBILE EQUIPMENT -SAFETY RULES
General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be driven
to the shop for repairs. Otherwise, the equipment must be towed or repaired at the
location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
Date: 12/12 Revision: EFR 3
Page 6 of 10
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
11. Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
Date: 12/12 Revision: EFR 3
Page 7 of 10
OPERA TIO NS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
8. Safe operation of conveyors requires that you shall:
Date: 12/12 Revision: EFR 3
Page 8 of 10
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
Fire Potential in the Solvent Extraction Building
Potential for fires in the SX building is present due to the 200,000 gallons of
kerosene used in the extractors. The kerosene has a flashpoint of 180°F. which is higher
than normal kerosene which as a flashpoint of approximately 130°F.
The Operator is to always be on the alert for:
1. Motors on pumps running hot.
2. Motors on settler mixers running hot.
3. Spills of chlorate -chlorate and kerosene together is a very dangerous combination.
A fire could start by the two materials coming in contact with each other.
4. Wood or paper in the SX circuit could cause a fire if they become saturated with
kerosene.
5. Sulfuric acid spills -spills of sulfuric acid on the floor will generate enough heat to
cause kerosene to ignite.
6. Any welding or cutting in the building -sparks from cutting or welding could cause a
fire.
7. Any open flames such as cigarettes or cigarette lighters -these items are prohibited in
the SX building.
8. Any gasoline mobile equipment in the SX building -gasoline mobile equipment is
prohibited in the SX building as the sparks from the ignition system could cause a
fire.
White Mesa Mill -Standard Operating Procedures
Book 6 Section I 0
Date: 12/12 Revision: EFR 3
Page 9 of IO
All uranium and vanadium SX operators must always practice good operating
procedures to prevent spills in the SX building and good housekeeping practices to be
sure no flammable materials are lying around in the area of the SX building. Operators
are to know and understand the operation of the automatic foam fire system in the SX
building and know and understand how to operate and effectively use the chemical fire
extinguisher also in the SX building.
You, as operators, have the responsibility to help prevent potentials for fire. You
have the responsibility and authority to prevent any person from entering or working in
the SX building if they do not follow all rules and regulations required for fire
prevention. If at any time you have a question or doubt about a situation that you think
might be a fire hazard, notify your supervisor immediately.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 10
SAFE WORK PERMIT
Date: 12/12 Revision: EFR 3
Page 10 of 10
Issued by: ___________ Date: ________ Time: ____ _
For Dept.: ___________ In area: ______________ _
Task to be performed: _______________________ _
Permit good until: _________________________ _
Confined space hazard evaluation completed by: ______________ _
REQUIRED PRECAUTIONS
Safety Dept. approval for confined space entry
Relieve vac/pressure
Equipment & lines drained, washed out, and
ventilated
Atmosphere checked for explosion, toxicity, and
oxygen (see Safety Department)
Continuous air monitor
Radiation work permit
Shower and eye wash checked
Drive mechanisms locked out
Chemical and gas inlets locked and blanked
Steam, air, and high volume lines locked
and disconnected
Special zero energy considerations
Openings roped off or guarded
Proper ladder tied off
Ground fault interrupter
Disconnect level indicators, etc.
Class 1 Division 1 explosion proof lights
Proper bonding and grounding of equipment and
material will be verified for permissible OHMS
resistance by a qualified electrician
Fire extinguisher and/or charged hose
Test welding hose for leaks
Qualified safety watch
Stay clear when lifting materials overhead
PERSONAL PROTECTIVE EQUIPMENT
Splash goggles D Face shield D Rubber suit
Rubber boots D SCBA D F.F. respirator
Safety belt & line D Hearing protection D
D
D
COMPLETED BY
Latex nitril gloves D
Cartridge type D
Other equipment _____________________________ _
Special instructions
Job completed: Date __________ _ Supervisor __________ _
Reviewed by: Dept. Head ________ _ Safety Department _______ _
White Mesa Mill -Standard Operating Procedures
Book 6 Section 11
Date: 12/12 Revision: EFR 4
Page 1 of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for pre-leach and leach which, when
followed, will maintain your exposures ALARA. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained ALARA.
Vanadium SX Radiation Safety Procedures
1. ALARA Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the ALARA program shall result in radiation exposures being maintained
to levels far below any applicable limits of the NRC regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
continuous reviews of radiation, environmental and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
initial assessment of the work environment and associated work tasks as related to
White Mesa Mill -Standard Operating Procedures
Book 6 Section 11
Date: 12/12 Revision: EFR 4
Page 2 of 5
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at Vanadium SX may require a Radiation Work
Permit if the initial radiological assessment indicates a potential for elevated
radiation exposure:
1. Vanadium SX
a. Entry into tanks, thickener, or enclosed tanks.
b. Cleaning out the sumps.
c. Clean up of spills around the pulp storage tanks.
This is not an all-inclusive list of jobs at Vanadium SX that could require a Radiation
Work Permit, but is intended as a guide.
3. Posting of Specific Areas
As a part of ALARA practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon daughter concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% DAC. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
White Mesa Mill -Standard Operating Procedures
Book 6 Section 11
Date: 12/12 Revision: EFR 4
Page 3 of 5
of full-face respirators due to airborne or radon daughter concentrations above 25%
DAC:
a. Vanadium SX Area
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. If you are using a respirator with combo cartridges for protection against
nuisance fumes or mists, the chemical concentration of the contaminants must
be less than the limit set by the manufacturer and the oxygen concentration
must be at or above 19.5%.
d. If you are detecting an odor or changing combo cartridges frequently, it is an
indication that the chemical concentration exceeds the chemical cartridge
limits and you should leave the area and notify your supervisor immediately.
5. Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of contamination.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 11
Date: 12/12 Revision: EFR 4
Page 4 of 5
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your OSL badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas, if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions. Check the following equipment:
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at Vanadium SX will be taken monthly.
Urinalysis samples are utilized to determine the uranium content contained in the
urine of the operator. The frequency of sampling is dependent on the airborne
concentrations and will be changed if airborne levels exceed 25% of the airborne
standards.
To minimize the change of contaminating a urine sample, the following practices
should be followed:
White Mesa Mill -Standard Operating Procedures
Book 6 Section 11
Date: 12/12 Revision: EFR 4
Page 5 of 5
a. Urinalysis containers can be picked up at the bioassay laboratory upon
returning from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing
into your work clothes or reporting to your work location. The samples can
then be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 12
Date: 12/19 Revision: EFR 4
Page 1 of 3
OPERATOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his workstation before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit
logbook at the beginning of the shift for any operating changes or information
pertaining to the circuit since the last logbook review. The operator will be required
to initial the logbook stating he or she understands the information in the logbook. If
the information concerning your operation is not clearly understood, contact your
shift foreman as soon as possible. Review the logbook during your shift for any
operating changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit logbook.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate departments within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
1. If a sample 1s contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
White Mesa Mill -Standard Operating Procedures
Book 6 Section 12
Date: 12/19 Revision: EFR 4
Page 2 of 3
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their workstation. Sample
containers will be placed in the administration building.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid ½ hour of
overtime to shower.
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
White Mesa Mill -Standard Operating Procedures
Book 6 Section 12
Date: 12/19 Revision: EFR 4
Page 3 of3
survey. If the alarm sounds again, contact the Shift Foreman, Radiation Safety
Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
White Mesa Mill -Standard Operating Procedures
Book 7 Section I
INTRODUCTION
Mill Process
Date: 12/19 Revision: EFR 3
Page 1 of2
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a slurry in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium (when present) is recovered from the barren uranium raffinate also utilizing a
solvent extraction circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered,
dried, melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent extraction
control room, vanadium control room, grind circuit below the derrick screens and in the
upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined, and now implements, a
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
White Mesa Mill -Standard Operating Procedures
Book 7 Section I
Date: 12/19 Revision: EFR 3
Page 2 of2
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 2
Date: 12/l9 Revision: EFR 6
Page 1 of3
VANADIUM PRECIPITATION, FILTERING,
AND AMMONIUM META V ANADATE DRYING
Preface
The purpose of the vanadium precipitation, filtering, and drying circuit is to
convert the vanadium pregnant liquor (VPL) from the solvent extraction process to an
ammonium metavanadate vanadium (AMV) product.
Circuit process equipment consists of two vanadium pregnant liquor storage
tanks, three precipitation tanks, one low grade ammonium sulfate tank, one conversion
tank, two ammonium sulfate dry storage tank, one ammonia sulfate mix tank, one filter
belt, one repulp tank, one centrifuge tank and all related pumps, pump lines, electric
motors, and tank agitators.
A circuit control room located on the filter belt floor level houses the circuit
electrical controls, readouts, and equipment alarms.
Vanadium pregnant liquor is pumped from the solvent extraction circuit to the
vanadium pregnant liquor storage tanks. Steam is added to the storage tank to heat the
VPL pumped from the storage tank to the precip conversion tank where additional steam
heat is used to raise the VPL temperature to 65°C.
Vanadium pregnant liquor is precipitated to an ammonium metavanadate
vanadium (AMV) compound by adding ammonia sulfate solution to the VPL in the
precip tanks. AMV is precipitated batch-wise in one of the three precipitation tanks.
Batches are made by adding the designated volume of VPL and ammonium sulfate
solution to the precipitation tank through the control system on the control computer.
The precipitation tanks are equipped with motor-driven agitators to mix the
ammonium sulfate solution with the VPL to form AMV.
After the precipitation is complete, the AMV slurry is dumped from the
precipitation tank onto a continuous traveling filter belt where the solution is washed with
low-grade ammonium sulfate solution, and, by means of vacuum, the barren solution is
removed from the AMV resulting in a mostly dry filter cake.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 2
Date: 12/19 Revision: EFR 6
Page 2 of 3
The dewatered AMY discharges from the filter belt and is either dropped into the
re-pulp tank or augured directly into the deammoniator. If the AMY goes into the re-pulp
tank, add low-grade ammonium sulfate solution to the re-pulp tank to the specified
density. This slurry is fed to the centrifuge where it is dewatered and then augured to the
deammoniator.
Vanadium Precipitation Filtering and AMV Drying Operating Procedures
1. Transfer YPL solution to the conversion tank and heat to the appropriate temperature.
2. Set the desired volume of YPL and ammonium sulfate on the control room computer
and start a precipitation batch. Ensure all valves are correctly positioned.
3. Start the precipitation tank agitator.
4. Agitate the YPL and ammonium sulfate solution for a minimum of one hour.
5. Take a sample of the AMY slurry from the precipitation tank and assay the sample to
determine the remaining vanadium in solution. If the vanadium solution is low
enough, feed the slurry to the filter belt.
a. Make sure the vacuum pump is running.
b. Start the filter belt drive
c. Start the filter belt filtrate pump.
d. Start the filter belt wash sprays.
e. Start the AMY low-grade ammonium sulfate wash solution.
f. Check the filter belt for proper alignment and any rips or holes.
g. Start the AMY slurry from the precipitation tank to the filter belt.
h. Adjust the flow onto the filter belt to achieve maximum wash and moisture
removal from the filtered AMY.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 2
Please note the following:
Date: 12/19 Revision: EFR 6
Page 3 of 3
All start/stop controls, indicators, readouts, and alarms are located on the vanadium
precipitation tab on the mill control computers located in all of the control rooms. Main
electrical disconnect switches are located as noted below:
Precip feed pump
Splitter tank agitator
Precip tank agitators
North filter belt
South filter belt
Outside vacuum pump
Inside vacuum pump
Ammonium sulfate auger
Ammonium sulfate tank agitator
Ammonium sulfate feed pump
Number one auger
Number two auger
Bucket elevator
Yellowcake area master control center
Yellowcake area master control center
Yellowcake area master control center
Behind the north filter belt (north wall)
Yellowcake area master control center
Yellowcake area master control center
North wall behind the vacuum pump
Yellowcake area master control center
Yellowcake area master control center
Yellowcake area master control center
Fusion furnace control room
Fusion furnace control room
Fusion furnace control room
White Mesa Mill -Standard Operating Procedures
Book 7 Section 3
Vanadium Precipitation-Start Up Procedures
Date: 12/19 Revision: EFR 4
Page 1 of2
Vanadium pregnant liquor (VPL) is batch-fed to the precipitation circuit. The
start up procedures will indicate the pumps to start up and shut down. This has to be
done to prevent overfilling the tanks and for controlling reagent usage during the start up
procedures.
1. Open the feed valve on the VPL storage tank.
2. Transfer solution to the "Precipitation Feed Tank".
3. If heating the VPL is required, turn on steam to the heat exchanger and recycle the
VPL through the heat exchanger until the appropriate temperature is reached.
4. Turn off the recycle pump and allow solution to be stagnant for 20-30 minutes
5. Check VPL for solution and any entrained organic on the top of the solution
6. Transfer to one of the precipitation tanks. This is done through the auto batch make
up system on the control computer.
7. Check specific gravity (SG) of the ammonium sulfate solution and determine how
much ammonium sulfate is required for the precipitation batch.
8. Start the agitator to the precipitation tank that is being filled.
9. Close the ammonium sulfate valve to the other four precipitation tanks.
10. Agitate the VPL solution for a minimum of one hour and then check the V2O5 grade
in the barren solution
White Mesa Mill -Standard Operating Procedures
Book 7 Section 3
Date: 12/19 Revision : EFR 4
Page 2 of2
11. Once the barren solution grade is at satisfactory levels (as determined by your
supervisor) it is ready to feed to the filter belt.
12. Start the belt drive.
13. Make sure the vacuum pump is on.
14. Turn on the low grade ammonium sulfate wash belt.
15. Make sure the slide plate is in the correct position (ammonium metavanadate (AMV)
will either go directly to the dryer or drop to the repulp tank)
16. Open the valve on the bottom of the precipitation tank that is to be fed to the belt
filter and adjust the feed to the belt so that the feed on the belt will be de-watered
before it reaches the first wash.
17. Control the feed rate on the belt to obtain a good wash of the AMV and a de-watered
AMV before it drops off the belt.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 4
Vanadium Precipitation -Shut Down Procedures
Date: 12/19 Revision: EFR 4
Pagel of l
1. Shut off the feed valve from the precipitation tank to the belt filter.
2. Shut off the belt filter after the AMV has been cleaned off.
3. Shut off the wash water to the filter belt.
4. Shut off the filter belt washes.
5. Leave the vacuum pump running (it ceases up with not running)
6. Leave the agitator running in the precipitation tank.
7. Shut off the precip feed pump to the precipitation tank filling.
8. Shut off the ammonium sulfate pump.
Power Outages
1. Shut off the feed valve from the precipitation tank to the filter belt.
2. Shut off the low-grade ammonium sulfate wash solution.
3. Shut off the filter belt wash.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 5
Date: 12/19 Revision: EFR 4
Page 1 of 1
Vanadium Precipitation and Filtering -Emergency Shut Down Procedures
1. Shut off the precip feed pump.
2. Shut off the steam valves.
3. Shut off the ammonium sulfate feed pump.
4. Shut off the feed to the belt filter.
5. Run the AMV off the belt filter.
6. Shut off the belt filter wash water.
7. Shut off the low-grade ammonium sulfate wash solution.
8. Shut off the belt filter drive.
9. Shut off the auger.
Power Outages
1. All electrically powered equipment will shut down.
2. Shut off the feed to the filter belt.
3. Turn off all filter belt wash water.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 6
Vanadium Precipitation-Shift Inspections
Date: 12/19 Revision: EFR 5
Pagel of2
1. Inspect the safety shower and eye wash fountain at the beginning of the shift for
proper operating conditions.
a. Immediately repair if they are not in good operating condition.
b. Immediately notify your supervisor if the shower or eye wash fountain cannot
be repaired.
2. Inspect the guards on all moving equipment once per shift for their condition and if in
place.
a. If the guard is not in place, shut off the equipment, lock out, and replace. Do
not operate equipment if the guards are not in place.
b. Notify your supervisor if the guard cannot be installed or if it is in bad
condition.
3. Inspect the VPL storage tanks once per shift for leaks.
a. Immediately notify your supervisor if any leaks are noted.
4. Inspect the control computer alarms at the beginning of each shift.
a. Immediately notify your supervisor if any problems are noted.
5. Inspect the precip tanks once per shift for leaks.
a. Notify your supervisor if any are noted.
6. Inspect the splitter tank once per shift for leaks.
a. Notify your supervisor if any are noted.
7. Inspect pumps and piping every two hours for seeps or leaks.
a. Notify your supervisor if any are noted.
8. Inspect the ammonium sulfate tank once per shift for leaks.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 6
a. Notify your supervisor if any are noted.
Date: 12/19 Revision: EFR 5
Page 2 of2
9. Documentation of items found during the inspections, should be indicated on the
Operating Daily Foreman's Inspection form.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 7
Date: 05/16 Revision: EFR 5
Page 1 of 6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance office and
central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department, and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
Information Contained on Safety Data Sheets
White Mesa Mill -Standard Operating Procedures
Book 7 Section 7
Date: 05/16 Revision: EFR 5
Page 2 of 6
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Physical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 7
Date: 05/16 Revision: EFR 5
Page 3 of 6
Vapor Pressure The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V.ff.W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S. T .E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
White Mesa Mill -Standard Operating Procedures
Book 7 Section 7
Date: 05/16 Revision: EFR 5
Page 4 of6
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to burn without the addition
of more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 7
Date: 05/16 Revision: EFR 5
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 7
Date: 05/16 Revision: EFR 5
Page 6 of6
For the
Environment
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Vanadium Precipitation
1. Ammonia
2. SodaAsh
3. Ammonium Sulfate
White Mesa Mill -Standard Operating Procedures
Book 7 Section 8
Hazards -Vanadium Precipitation
1. Hot solutions -85°C.
2. Ammonia fumes
3. Vanadium dust
4. Propane gas leaks
5. Heat from the vanadium de-ammoniator
6. Elevated walkways
Date: 12/12 Revision: EFR 3
Pagel of6
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 8
Hazard Recognition -A.M.V. Precipitation
1. Hazards
a. Sulfuric Acid Lines
1. Open slowly
2. Use personal protective equipment
3. Report leaks immediately
b. Ammonium Sulfate
1. Open valve slowly
Date: 12/12 Revision: EFR 3
Page 2 of6
2. Exercise caution when lifting and dumping bags
3. Use personal protection equipment
c. Anhydrous Ammonia
1. Open valves slowly
2. Reports leaks promptly
3. Use personal protection equipment
d. SodaAsh
1. Open valves slowly
2. Use caution when lifting and dumping bags
3. Use personal protective equipment
e. Steam Lines
1. Open valves slowly
2. Caution -hot valve handles
3. Use personal protection equipment
f. Air Lines
1. Open valves slowly
2. Whip checks on hose connections
White Mesa Mill -Standard Operating Procedures
Book 7 Section 8
3. Do not use to blow off clothing
2. Hazards -A.M.V. Precipitation Area
a. Roof
Date: 12/12 Revision: EFR 3
Page 3 of6
1. Use caution when climbing ladders; pipe in deck at the bottom of the
roof access ladder
2. Cleaning bucket elevator on the roof requires locking out
3. Use caution when the cover plate is removed on the bucket elevator
b. Air Lines
1. Guards
a. Drives
b. Demister fan
2. Low Roof Beams
a. Above the number one precip tank
b. Above the number two precip tank
3. Decking
a. Sections lift up for sampling
b. Holes for sampling
c. Decks are slippery when wet
d. Ladders and stairs are slippery when wet
e. Slip and trip hazard when carrying and dumping soda ash
3. Hazards -A.M.V. Filtrate Belts and Augers
a. Filtrate Belts
1. Head and tail pulleys -pinch points
2. Return idlers -pinch points
3. Drive -pinch points
b. Augers
White Mesa Mill -Standard Operating Procedures
Book 7 Section 8
1. Number one auger has to be stepped over
2. Guards
3. Concrete floor is slippery when wet
c. Hoisting and Dumping Wet A.M.V. from Drums
1. Caution around drum dumper
2. Caution around rollers
3. Caution around propane gas lines
4. Caution around auger with covers removed
4. Hazards at Ammonium Sulfate Mix Area
a. Guards
b. Augers
c. Deck and stairs are slippery when wet
Date: 12/12 Revision: EFR 3
Page 4 of6
d. Use caution while lifting and dumping ammonium sulfate bags
5. Hazards at V.P.L. Tanks
a. Hot liquid
b. Steam lines and controls (use personal protection equipment)
c. Deck is slippery when wet
d. Guards on pumps
6. Hazards at Ammonium Sulfate Pump Area
a. Guards on pump
b. Deck is slippery when wet
7. Hazards at Wet Bin
a. Augers
b. Guards
c. Head and tail pulleys on feed belt
White Mesa Mill -Standard Operating Procedures
Book 7 Section 8
d. Deck and stairs are slippery when wet
8. Hazard at Bucket Elevator Bottom
a. Lock out before cleaning
Date: 12/12 Revision: EFR 3
Page 5 of6
b. Caution when shoveling wet material into the bucket elevator (with bottom
cover removed)
c. Caution around cyclone (very hot)
d. Caution around propane gas lines
9. Health Hazards
a. Ammonia Fumes and Vanadium Fumes
1. Respirator required
b. Hearing Protection
1. Required in the vanadium building
c. Radiation
1. Airborne (sampled monthly)
2. Beta and gamma (sampled monthly)
3. Radon daughters (sampled monthly)
d. Personal Protection Equipment (gloves and rubber boots)
White Mesa Mill -Standard Operating Procedures
Book 7 Section 8
Hazard Recognition -A.M. V. Dryer Area
1. Hazards
a. Rotary Dryer
1. Guards must be in place
2. Open carrier rollers
3. Dryer is hot
4. Propane gas lines
5. Auger and conveyor
a. Feed belt -guards
b. Return idlers -covered
Date: 12/12 Revision: EFR 3
Page 6 of6
c. Feed belt to de-ammoniator -idlers not covered
d. Auger to de-ammoniator feed belt
6. Bucket elevator
a. Caution when cleaning up with the door off
b. Cyclone is hot
c. Fan east of bucket elevator
b. Health Hazards
1. Fumes -ammonia and vanadium (full-face respirator required with
combo cartridge)
2. Vanadium dust from rotary dryer
3. Heat from the dryer and heat rising from the de-ammoniator, and
fusion furnaces
4. Decks and stairways are slippery when wet after a wash down
5. Hearing protection
6. Radiation
a. Airborne uranium
b. Radon daughters
c. Beta and gamma
White Mesa Mill -Standard Operating Procedures
Book 7 Section 9
JOB PROCEDURES
Date: 12/12 Revision: EFR 3
Pagel of l
This section covers job procedures for non-daily routine jobs that are performed
in:
VANADIUM PRECIPITATION, A.M. V. DRYING, AND PACKAGING
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 7 Section I 0
Date: 12/12 Revision: EFR 3
Page I of6
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Vanadium Precipitation.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rule manual.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 10
GENERAL RULES
Reporting Unsafe Conditions and Iniurles
Date: 12/12 Revision: EFR 3
Page 2 of6
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
White Mesa Mill -Standard Operating Procedures
Book 7 Section 10
c. Rubber gloves and rubber boots
Date: 12/12 Revision: EFR 3
Page 3 of6
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs, or having them in
your possession while in the plant area.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 10
Date: 12/12 Revision: EFR 3
Page 4 of6
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 10
Date: 12/12 Revision: EFR 3
Page 5 of6
OPERA TIO NS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
8. Safe operation of conveyors requires that you shall:
White Mesa Mill -Standard Operating Procedures
Book 7 Section 10
Date: 12/12 Revision: EFR 3
Page 6 of6
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 11
Date: 12/12 Revision: EFR 4
Page I of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for pre-leach and leach which, when
followed, will maintain your exposures ALARA. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained ALARA.
Vanadium Precipitation Radiation Safety Procedures
1. ALARA Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the ALARA program shall result in radiation exposures being maintained
to levels far below any applicable limits of the NRC regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
continuous reviews of radiation, environmental and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
initial assessment of the work environment and associated work tasks as related to
White Mesa Mill -Standard Operating Procedures
Book 7 Section 11
Date: 12/12 Revision: EFR 4
Page 2 of 5
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at vanadium precipitation may require a Radiation
Work Permit if the initial radiological assessment indicates a potential for
elevated radiation exposure:
1. Vanadium Precipitation
a. Entry into tanks, thickener, or enclosed tanks.
b. Cleaning out the sumps.
c. Cleaning of the demister scrubber system.
d. Clean up of spills around the pulp storage tanks.
This is not an all-inclusive list of jobs at vanadium precipitation that could require a
Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
As a part of ALARA practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon daughter concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% DAC. The following areas
White Mesa Mill -Standard Operating Procedures
Book 7 Section 11
Date: 12/12 Revision: EFR 4
Page 3 of 5
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon daughter concentrations above 25%
DAC:
a. Precipitation Area
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. If you are using a respirator with combo cartridges for protection against
nuisance fumes or mists, the chemical concentration of the contaminants must
be less than the limit set by the manufacturer and the oxygen concentration
must be at or above 19.5%.
d. If you are detecting an odor or changing combo cartridges frequently, it is an
indication that the chemical concentration exceeds the chemical cartridge
limits and you should leave the area and notify your supervisor immediately.
5. Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
White Mesa Mill -Standard Operating Procedures
Book 7 Section 11
Date: 12/12 Revision: EFR 4
Page 4 of 5
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your OSL badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas, if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions. Check the following equipment:
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at vanadium precipitation will be taken
monthly. Urinalysis samples are utilized to determine the uranium content contained
in the urine of the operator. The frequency of sampling is dependent on the airborne
concentrations and will be changed if airborne levels exceed 25% of the airborne
standards.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 11
Date: 12/12 Revision: EFR 4
Page 5 of 5
To minimize the change of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the bioassay laboratory in the
Administration Building upon returning from your scheduled days off (two
and four days). The sample containers should be filled after washing your
hands and prior to changing into your work clothes or reporting to your work
location. The samples can then be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 12
Date: 12/12 Revision: EFR 3
Page 1 of 4
OPERA TOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate departments within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
1. If a sample 1s contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 12
Date: 12/12 Revision: EFR 3
Page 2 of 4
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid ½ hour of
overtime to shower.
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
White Mesa Mill -Standard Operating Procedures
Book 7 Section 12
Date: 12/12 Revision: EFR 3
Page 3 of 4
survey. If the alarm sounds again, contact the Shift Foreman, Radiation Safety
Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
White Mesa Mill -Standard Operating Procedures
Book 7 Section 12
Date: 12/12 Revision: EFR 3
Page 4 of 4
I have read, understood and have had the opportunity to ask questions regarding the
procedures set forth in this book.
Date __________ _
Name (print) ____________ _
Name (signature) ___________ _
White Mesa Mill -Standard Operating Procedures
Book 8 Section 1
INTRODUCTION
Mill Process
Date: 12/19 Revision: EFR 5
Page 1 of2
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, is fed at a rate determined by the metallurgical staff to the semi-
autogenous grinding (SAG) mill. The ground ore is stored as a slurry in three agitated
tanks. The processing stages include acid leaching compatible with the ore that is fed,
followed by the recovery of uranium and vanadium bearing solution in a counter-current
decantation (CCD) system.
The uranium that is in the leach solution is recovered utilizing solvent extraction.
Vanadium (when present) is recovered from the barren uranium raffinate also utilizing a
solvent extraction circuit.
The uranium strip solution from solvent extraction is precipitated with anhydrous
ammonia and the resultant yellowcake is dewatered, dried, and packaged.
The vanadium strip solution is precipitated with ammonium sulfate, filtered,
dried, melted and cast to produce a concentrated vanadium black flake for packaging.
Process Controls
Process control computers are located in the central control room, solvent extraction
control room, vanadium control room, grind circuit below the derrick screens and in the
upper level of the CCD circuit.
Energy Fuels Resources (USA) Inc. has outlined, and now implements, a
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the State of
Utah Division of Waste Management and Radiation Control under the direction of the
Director. These applicable regulations are detailed in the Code of Federal Regulations
Title 10 Energy and the State of Utah regulations.
White Mesa Mill -Standard Operating Procedures
Book 8 Section I
Date: 12/19 Revision: EFR 5
Page 2 of2
Radiation Protection Operating Procedures are included in this manual for each
Unit Operation.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 1 of 11
VANADIUM DE-AMMONIA TING, FUSING,
AND PACKAGING
De-watered ammonium metavanadate vanadium (A.M.V.) is fed from the wet
storage bin to the top hearth of the de-ammoniator by the de-ammoniator feed belt. The
feed belt is equipped with a variable speed drive motor to control the rate of feed to the
de-ammoniator.
The de-ammoniator is equipped with a center drive column with attached rabble
arms and rabble teeth which are angled so as the shaft rotates, the teeth distribute the cake
over each hearth in or out, as the case may be, and until it reaches the bottom hearth
where the rabble teeth plow the cake into a product drop to the fusion furnace feed auger.
The de-ammoniator has eight propane fired burners, two each on hearths two,
four, five, and six which are located 180° apart and directly in line with each other.
Hearth numbers three and one are heated from the air draft from the fired hearths. There
are two doors per hearth located 180° apart and directly in line with each other.
Temperatures on each hearth will be controlled to drive the ammonia from the A.M.V.
and dry the A.M. V. to a granular vanadium pentoxide. Ideal temperatures are 500° to
600° in the number two hearth, 600° to 800° in numbers four and five hearths, and 800° to
1,000° in the number six hearth. Hearth temperatures will vary due to moisture content of
the A.M. V. and the feed rate to the de-ammonia tor.
Upon entering the de-ammoniator, the west ammonium metavanadate filter cake
will be rabbled towards the drop hole of the top hearth. Moisture will be driven from the
feed in the upper hearths of the de-ammoniator. The ammonium metavanadate
decomposes to vanadium pentoxide in the lower hearths. During this process, ammonia
gas is liberated and the feed changes color. In hearths one, two, and three, the moisture is
driven off and the color of the feed will change from white to gray/black. In hearths four,
five, and six, as the ammonia is liberated from the feed, the feed color will change in the
number four hearth to a brown/orange and in hearths five and six, the feed color will be
orange/deep red. The product is now decomposed and converted a granular vanadium
pentoxide.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 2 of 11
The granular vanadium pentoxide from the de-ammoniator is fed to the fusion
furnace by the furnace feed auger.
The fusion furnace is a fire, brick-lined cylinder with fire, brick-lined end caps.
The end caps are water cooled at the feed intake and the feed discharge openings. The
fusion furnace is equipped with a propane fired burner with a heat range of up to l,700°F
and is capable of melting the tech granular vanadium feed from the de-ammoniator to a
molten, free flowing product. The fusion furnace is mounted on a slight incline from the
feed end to the discharge end which allows the molten product to flow out the discharge
spout of the furnace and onto the water cooled casting wheel. The furnace discharge
opening is equipped with a propane fired spout burner to keep the molten vanadium from
solidifying in the furnace discharge spout.
The casting wheel is a variable speed driven, circular plate with a water cooling
jacket between the top and bottom plates. The casting wheel is equipped with a product
breaker roller, product scraper, and a motor-driven cleaning brush.
The free flowing molten vanadium discharges from the fusion furnace onto the
casting wheel and hardens to a thin layer and is broken into flakes no larger than 1 ½" x
1 ½" by the casting wheel breaker roller and is scraped and brushed from the casting
wheel into the bucket elevator feed auger.
The product from the casting wheel 1s now vanadium pentoxide flake ( or
blackflake) and is conveyed to the blackflake storage and packaging bin by the bucket
elevator.
The bucket elevator is a motor-driven drag link chain with cup buckets mounted
at intervals which pick up the vanadium blackflake from the bucket elevator feed auger
and discharges the blackflake into the packaging storage bin.
The blackflake storage bin has a cone bottom and is equipped with a bin vibrator
and a cone vibrator which causes the blackflake to slide to the cone star feeder vane
valve. The blackflake storage will store approximately 35,000 pounds of blackflake.
The blackflake is packaged in 55 gallon steel drums. The drums will be fitted
with a new lid gasket and an identifying product number, lot number, drum number,
gross, tare and net weights identified. Drums will each be labeled on the top and side. A
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 3 of 11
Daily Product Log Sheet will be kept. The log sheet will record the lot number, drum
number, gross, tare, and net weights of each drum. Packaged blackflake will be packaged
in 72 drum lots; the lot number will change after every 72 drums have been packaged.
Drums will be filled to 250 kilograms net weight. The blackflake packaging
scales are to be checked with the calibrated scales weight at the beginning of each shift.
Each drum will be tare weighed before being filled with the blackflake.
The tare weighed drum is then placed on the scale conveyor directly under the
blackflake bin packaging hood. The drum lid is removed and placed beside the drum on
the scales. The drum hood is lowered down to the top of the open drum and, by
activating the storage bin star feeder valve, the drum can be filled with blackflake. No
fused chucks of blackflake are to be put in the drums.
After the drum is filled to 250 kilograms net weight, raise the drum hood, activate
the scale roll conveyor, and move the filled drum from the scales.
One sample of blackflake will be taken from each drum -a lot sample consisting
of a sample of blackflake from drums one through 72 will be kept in a sample container.
Samples are turned into the metallurgical laboratory for assay and accounting purposes.
Sample bottles are to be marked with the date and drum numbers contained in the sample.
After the filled drum has been sampled, place the lid on the drum, secure the lid to the
drum with the lid ring and ring bolt. Record the drum numbers and drum weights on the
drum and on the Daily Product Log Sheet.
Some blackflake dust is created at the casting wheel and the packaging station.
This dust is controlled by means of a dust collection system in that dust is picked up at
the casting wheel and packaging drum hood and goes through a baghouse located on top
of the blackflake storage bin. The baghouse is equipped with cloth bags to collect the
dust. The cloth bags are shaken by an automatic shaker and the dust collected in the cloth
bags discharges into the blackflake storage bin. Any residual dust goes through the
blackflake packaging scrubber venturi throat and is washed with water sprays into the
vanadium scrubber thickener to be recycled through the mill stream.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 4 of 11
Air flow from the casting wheel and packaging hood dust collection pickup areas
and to the baghouse is achieved by means of a scrubber booster fan and scrubber exhaust
fan which vent the washed air stream to the atmosphere.
All start/stop switches, readouts, alarms, and electrical disconnects are located in
the vanadium control room. Local job switches for the de-ammoniator rake drive are
located at each hearth level. Local job switches are also located at the casting wheel.
Blackflake packaging controls are located at the packaging stations.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Skinner Dryer Description
Date: 02/16 Revision: EFR 5
Page 5 of 11
The de-ammoniator, a refractory lined, multiple unit with burners on hearths two,
four, five, and six, has a variable speed rotating central shaft with attached rabble arms
and angled rabble teeth used to move the material down through the de-ammoniator. The
arms and shaft are cooled by air forced into the bottom of the shaft by the cooling air fan.
After passing through the arms and shaft, the cooling air will have been heated to a
temperature of between 200° and 300°F and is vented out through the cooling air stack
into the atmosphere. There are two doors per hearth located 180° apart and directly in
line with each other.
The ammonium metavanadate filter cake is delivered to the de-ammoniator top
hearth. This material is moved through the de-ammoniator by means of rabble arms with
attached rabble teeth which are angled in such a way that, as the shaft rotates, the teeth
distribute the cake over each hearth (in or out as the case may be) and down until it
reaches the bottom hearth where the teeth plow the cake into a product outlet. From here,
the product passes into the screw conveyor to feed the fusion furnace. The drying and
decomposition of this material in the de-ammoniator gives rise to water vapor, ammonia,
and gaseous products of combustion from the fuel used. All of these gases are discharged
through a gas outlet at the top of the de-ammoniator through a dry cyclone and into the
exhaust gas handling scrubber system.
Purging and Firing De-ammoniator Burners
Pre-purge Procedures
1. Ensure the power is on for all equipment at the MCC. Turn the panel power circuit
breaker switch to the "On" position (located in the breaker panel on the control room
wall). Alarms will light and the alarm horn will sound. The horn can be silenced by
pressing the "Silence Alarm" button, but the lights will remain on until alarm
conditions are cleared, i.e., the equipment is started.
2. Check and close all hearth doors, including the peep hole doors.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 6 of 11
3. Start the scrubber recirculation pump and adjust the water flow at the scrubber as
required. Proper water flow to the scrubber will clear the alarm light on the panel for
"Scrubber Water-Low Flow."
4. Ensure that the condensation drain valves on the stainless steel tubing running from
the equipment to the control panel are closed ( de-ammoniator hearth number one and
the scrubber differential pressure).
5. Start the I.D. fan (scrubber fan). This will start as long as the scrubber water flow is
proper; the I.D. fan inlet temperature is not high and the draft control damper is
closed.
6. Start the dryer combustion air blower. This will cause the panel light for the "Dryer
Combustion Air Fan -Low Pressure" to go out.
7. Check to be sure the "Maxie" valves in the gas lines to the burners are closed. Valves
will indicated "Closed in Maxie Valve Windows."
8. Open the manual valves in the gas lines to the burner pilots.
9. Open the temperature control valves for all fired hearths by setting the four dryer
hearth controllers to a temperature setting that is higher than that indicated on the
controller. This will cause the valves to drive to the "High Fire" position which is
necessary to supply maximum purge air.
10. Start the cooling air fan. The panel light for "Shaft Cooling Air Fan -Low Pressure"
will go out.
a. This fan should never be stopped when furnace temperatures at any hearth
exceed 500°F since damage to the rabble arms my result from over-heating.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 7 of 11
11. If all of the equipment required to initiate the purge cycle is functioning properly and
the temperatures on hearths two, four, five, and six are not too high (above the pre-set
alarm temperature), the "De-ammoniator Purging" red light will come on.
12. After the required purge time has elapsed, the "De-ammoniator Purge Complete"
green light will come on. The burners for the de-ammoniator can be started as
outlined in the next section.
13. Open the manual gas valves to the burners.
14. Do not open the maxie valves.
15. Close the temperature control valves on all hearths by setting the four de-ammoniator
temperature controllers to a temperature setting that is lower than that indicated on
the controller. This will cause the valves to drive to the "low fire" position which is
necessary before the burners can be started.
16. Light the selected burners by pushing in and holding the "Start" buttons of the
burners to be lighted. The pilot must light as proven by the ultra-violet scanner. The
burner "On" indicator light will come on. The maxie gas control valve to the burner
can now be manually opened to establish main burner fire and the maxie valve
"Open" green light will come on. When the desired burner has started, the burner
indicator light will stay on and the panel light for that burner will go out.
17. Set the de-ammoniator hearth temperature controllers to the desired hearth
temperature and the burners will automatically modulate and vary the firing rate as
required to maintain the set-point temperature.
Vanadium Fusion Furnace Description
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 8 of 11
The fusion furnace is a fire, brick-lined steel cylinder with fire, brick-lined end
caps. The feed end cap is water cooled at the feed auger opening. The discharge end cap
is water cooled at the feed discharge opening.
The fusion furnace is a single chamber, reverberatory type unit with one main
burner at the feed end and a flue gas breaching at the discharge end. Flue gases from the
fusion furnace are tempered by means of an automatic bleed-in damper. The automatic
bleed-in damper is controlled by a single set-point controller at the control panel.
The burner system consists of two burners, a large main burner for the fusion
furnace, and a small auxiliary burner for the product discharge spout. Both burners are
designed to burn propane. The main burner is controlled from a single set-point
temperature controller at the control panel. The auxiliary burner firing rate is manually
controlled by a hand valve located near the burner. The main furnace burner is monitored
by a ultra-violet flame scanner. The main burner can be started or stopped from the
control panel mounted start/stop station. The propane gas systems incorporate the
necessary safety valves, regulators, and pressure switches. The flame safety equipment is
housed in the main control panel which also contains the necessary interlocks and
controls for the rest of the system.
Purging and Firing Fusion Furnace Burner
1. Ensure the power is on for all equipment at the MCC. Turn the panel power circuit
breaker switch to the "On" position (located in the breaker on the control room wall).
Alarms will light and the alarm horn will sound. The horn can be silenced by
pressing the "Silence Alarm" button, but the lights will remain on until the alarm
conditions are cleared, i.e., the equipment has been started.
2. Start the scrubber recirculation pump and adjust the water flow at the scrubber as
required. Proper water flow to the scrubber will clear the alarm light at the panel for
the "Scrubber Water-Low Flow."
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 9 of 11
3. Start the I.D. (scrubber fan). This will start as long as the scrubber water flow is
proper.
4. Start the fusion furnace combustion air blower. This will cause the panel light for
"Furnace Combustion Air Fan -Low Pressure" to go out.
5. Check to be sure the "Maxie" valve in the gas line to the furnace burner is closed.
(The valve will indicate "Closed" in the maxie valve window.)
6. Open the manual valve in the gas line to the burner pilot.
7. Open the temperature control valve for the furnace burner by setting the furnace
burner controller to a temperature setting that is higher than that indicated on the
controller. This will cause the valve to drive to the "High Fire" position which is
necessary to supply maximum purge air.
8. If all of the equipment required to initiate the purge cycle is functioning properly, the
"Furnace Purging" red light will come on.
9. After the required purge time has elapsed, the "Furnace Purge Complete" green light
will come on. The fusion furnace burner can then be started as outlined in the next
section.
10. Open the manual gas valve to the furnace burner.
11. Do not open the maxie valve.
12. Close the temperature control valve to the furnace by setting the fusion furnace
controller to a temperature setting that is lower than that indicated on the controller.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 10 of 11
This will cause the valve to drive to the "Low Fire" position which is necessary
before the furnace burner can be started.
13. Light the furnace burner by pushing in and holding the "Start" button for the furnace
burner. The pilot must light as proven by the ultra-violet scanner. The burner "On"
indicator light will come on. The "Maxie" gas control valve to the burner can now be
manually opened to establish main burner fire and the maxie valve "Open" green
light will come on. When the burner has started, the burner indicator light will stay
on and the panel light for the burner will go out.
14. Set the furnace burner temperature controller to the desired furnace temperature and
the burner will automatically modulate and vary the firing rate as required to maintain
the set-point temperature.
De-ammoniator Fusion Furnace Scrubbers and
Packed Tower De-mister Description
The purpose of the de-ammoniator and the fusion furnace scrubbers, and the
packed tower de-mister is to wash the ammonia bearing gases and residual dust from the
air stream before being exhausted to the atmosphere.
The scrubbers are Venturi Scrubbers and Cyclonic Separators.
The air stream from the de-ammoniator and the fusion furnace is washed with
recycled wash water from the scrubber thickener as the air stream passes through the
venturi throat of each scrubber. A stream of recycled wash water is pumped through the
narrow part of the venturi throat as it washes the air stream. The cyclonic motion is
created by the air stream movement in a counter-current direction. The counter-current
movement through the scrubber vessel cyclones the residual dust and wash water to the
scrubber thickener. The scrubber thickener is used to thicken the dust which settles to the
cone outlet of the scrubber thickener. The scrubber underflow is pumped back into the
mill stream to recover the values separated from the air stream.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 2
Date: 02/16 Revision: EFR 5
Page 11 of 11
The packed tower de-mister is used as a third wash for the air stream before the
air stream is exhausted into the atmosphere.
The de-mister is packed with four feet of one inch tellerettes. The air stream
enters the bottom of the de-mister and is washed as it goes through the tellerette packing
with a maximum wash rate of 120 gpm recycle wash.
Three in-line exhaust fans are used to move the air stream through the scrubbers
and de-mister before exhausting into the atmosphere.
Vanadium Pentoxide Packaging Scrubber Description
The purpose of the packaging scrubber is to wash any residual dust from the
packaging operation before the air stream is exhausted into the atmosphere.
The scrubber is a Sly Venturi Scrubber and Cyclonic Separator.
Normal water consumption for the scrubber liquid is approximately 40 to 50 gpm
of recycled wash water pumped from the scrubber barometric seal tank.
Two flanged removable scrubbing liquid pipes are located on either side of the
venturi inlet. These pipes are right hand and left hand and should be positioned to spray
downward through the venturi throat.
Air and dust are moved through the scrubber from the packaging area dust pick up
points by means of a booster fan located downstream from the scrubber and an exhaust
fan located upstream from the scrubber.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 3
Date: 12/12 Revision: EFR 3
Pagel of3
Vanadium De-ammoniating, Fusing, and Packaging Start Up Procedures
1. Check all equipment and equipment safety guards. Do not operate any equipment
without the safety guards. Always follow the lockout procedures while cleaning or
repairing the equipment.
2. Start the de-ammoniator and fusing furnace as outlined in the de-ammoniator and
furnace start up procedures.
3. After the de-ammoniator and the furnace are at operating temperatures:
a. Start the de-ammoniator feed belt
b. Start the fusion furnace feed auger
4. Feed the de-ammoniator at a rate that allows the material to be dry and de-
ammoniated by the time it leaves the number six hearth.
5. Start the furnace spout burner.
6. Start the casting wheel.
a. Turn on the casting wheel cooling water.
b. Start the casting wheel cleaning brush
7. Start the bucket elevator feed auger.
8. Start the bucket elevator.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 3
Vanadium Pentoxide Flake Packaging Start Up Procedures
1. Fit each drum lid with a new gasket.
Date: 12/12 Revision: EFR 3
Page 2 of3
a. Do not use the drum lids that have a screw in the bung plugs.
2. Check the scales at the beginning of each shift with the calibrated scale weights.
a. Start the packaging scrubber pump, packaging fan, and blackflake storage bin
baghouse, baghouse shaker motor, and the star valve.
3. Each drum will be stenciled with the company name, "Vanadium Pentoxide," lot
number, drum number, gross weight, and tare weight.
4. Place the empty drum on the scale directly under the drum hood. Weight the drum
for tare weight, record the tare weight on the drum and the Product Log Sheet.
5. Lower the drum hood onto the top of the drum.
6. Fill the drum with blackflake to 550 pounds net weight.
7. Lift the drum hood from the drum.
8. Turn on the roll conveyor and roll the drum off the scales and onto the roll conveyor.
9. Blackflake will be packaged in 72 drum lots.
10. Each drum of blackflake will be sampled. A lot sample of drums one through 72 will
be kept in a sample container. The sample container will be marked with:
a. Date the lot was started
11. Place the lid and lid ring on each drum; secure the lid with the ring bolt.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 3
Date: 12/12 Revision: EFR 3
Page 3 of3
12. Record the gross, tare, and net weights on the filled drum and on the Product Log
Sheet.
13. Start/stop controls, burner controls, readouts, and alarms are located on the control
panel in the circuit control room. Main electrical disconnect switches are located on
the west wall of the control room.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 4
Date: 12/12 Revision: EFR 3
Page 1 of 1
Vanadium De-ammoniating, Fusing, and Packaging-Shut Down Procedures
1. Shut off the de-ammoniator feed belt.
2. Rabble all of the feed out of the de-ammoniator to the fusion furnace.
a. Shut off the furnace feed auger.
3. Lower the de-ammoniator hearth temperatures at 50° per hour until all of the hearths
are at 300°F or lower.
a. After the hearth temperatures are 300°F or less, shut off the burners.
b. Shut off the rake drive.
c. Shut off the center column cooling fan.
4. Fuse all of the vanadium out of the fusion furnace.
5. Shut off the furnace spout burner.
6. Lower the fusion furnace temperature 100° per hour until the furnace temperature is
300°F or less.
7. Shut off the casting wheel cleaning brush.
8. Shut off the casting wheel.
9. Shut off the casting wheel cooling water.
10. Shut off the bucket elevator feed auger.
11. Shut off the bucket elevator.
12. Empty the blackflake storage bin.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 5
Date: 12/12 Revision: EFR 3
Page I of I
De-ammoniator Fusing Furnace Emergency Shut Down Procedures
1. Stop the de-ammoniator feed belt.
2. Shut off all of the hearth burners.
3. Shut off the rake drive.
4. Shut off the fusion furnace burner.
a. Shut off the furnace spout burner.
5. Shut off the combustion air fan.
6. Shut off the scrubber feed water pump.
7. Shut off the scrubber fans.
8. Shut off the de-mister feed solvent water pump.
9. Shut off the mill fresh water addition to the de-mister barometric seal tank and to the
scrubber thickener.
Power Outages
All electrically operated and powered equipment will be shut down.
1. Turn off the casting wheel cooling water.
2. Turn off the mill water addition to the de-mister barometric seal tank.
3. Turn off the mill water to the scrubber thickener.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 6
Date: 04/14 Revision: EFR 4
Page 1 of3
Shift Inspection -Vanadium De-ammoniating, Fu ing, and Packaging
De-ammonia ting
1. Inspect safety guards on all moving equipment at the beginning of each shift.
a. If safety guards are not in place, shut off the equipment, lock out, and replace
the safety guard(s). Do not operate the equipment if the guards are not in
place.
b. Notify your supervisor if the safety guard cannot be installed or if the safety
guard is in bad condition.
2. Inspect the panel alarms at the beginning of each shift for proper operation.
a. Immediately notify your supervisor if problems are noted.
3. Inspect each de-ammoniator hearth every hour of your shift, or as often as needed, to
keep the de-ammoniator operating as efficiently as possible.
a. Check the rabble arms and rabble teeth.
b. Notify your supervisor if problems are observed, i.e., damaged rabble arms or
broken rabble teeth.
4. Inspect propane gas lines each shift for leaks.
a. Immediately notify your supervisor if any leaks are observed in the propane
gas lines.
5. All documentation of issues from the inspections should be indicated on the Operating
Foreman's Daily Inspection form.
Fusion Furnace
1. Inspect safety guards on all moving equipment at the beginning of each shift.
a. If safety guards are not in place, shut off the equipment, lock out, and replace
the safety guard(s). Do not operate equipment if the safety guards are not in
place.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 6
Date: 04/14 Revision: EFR 4
Page 2 of 3
b. Notify your supervisor if the safety guards cannot be installed or if the safety
guard is in bad condition.
2. Inspect the water cooling jackets and assure that the cooling water is flowing through
the cooling jackets.
a. Notify your supervisor if there is no cooling water flow through the cooling
jackets.
3. Inspect the casting wheel each shift for any cracks in the wheel surface and that
adequate cooling water is flowing through the casting wheel cooling jacket.
a. Notify your supervisor if any problems are noted.
4. All documentation of issues from the inspections should be indicated on the Operating
Foreman's Daily Inspection form.
Blackflake Packaging
1. Inspect the safety guards on all moving equipment at the beginning of each shift.
a. If safety guards are not in place, shut off equipment, lock out, and replace
safety guard(s). Do not operate equipment if the guards are not in place.
2. Check the blackflake weight scales at the beginning of each shift with the calibrated
scale weight.
a. If the weight scales do not calibrate, make the calibration changes on the
weight scale control panel. If the weight scales cannot be zeroed in, notify
your supervisor. Do not open the control panel.
3. Inspect the roll conveyor for broken or damaged rollers.
a. Notify your supervisor if any problems are noted.
4. Ensure that the blackflake baghouse bag shaker is operating.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 6
Date: 04/14 Revision: EFR 4
Page 3 of 3
a. Notify your supervisor if the baghouse or bag shaker are not operating.
5. Inspect the blackflake storage bin rubber transition seals for leaking dust or
blackflake chips.
a. Notify your supervisor if any leakage is observed.
6. Inspect the product drums before filling with blackflake.
a. Do not use drums that are damaged. On questionable drums, contact your
supervisor.
7. Do not use any drum lid that has a screw in the bung plugs.
8. All documentation of issues from the inspections should be indicated on the
Operating Foreman's Daily Inspection form.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 7
Date: 05/16 Revision: EFR 5
Page 1 of 6
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
1. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
11. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Safety Data Sheet (SDS) provided in strategic locations throughout the mill area.
These can be found in the following locations; safety office, laboratory, maintenance office and
central control room.
The SDS supplies a description of the chemicals and reagents. The SDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the SDS of all chemicals and reagents used in his/her
department, and be familiar with the chemicals and reagents used in all operating departments.
Each operator must know the location of all SDS's for his/her operating circuit at all times.
Information Contained on Safety Data Sheets
White Mesa Mill -Standard Operating Procedures
Book 8 Section 7
Date: 05/16 Revision: EFR 5
Page 2 of 6
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Physical Description
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous material,
the S.T.C.C. number will begin with the digits "49."
Normal Physical State Physical state or form of the material at normal ambient temperatures
(68°F -77°F).
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
Boiling Point
Melting Point
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than 1, the material is
lighter than water and will float; if the specific gravity is greater than 1,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than 1, the material is lighter than air and may rise; if the
vapor density is greater than 1, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric pressure.
The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 7
Date: 05/16 Revision: EFR 5
Page 3 of 6
Vapor Pressure The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard
T.L.V.ff.W.A.
LCso
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Is there any hazard from breathing this material?
Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in ppm that kills 50% of the laboratory animals in a
given length of time.
Is there any hazard from ingesting ( eating) this material?
Lethal Dose -the dose that kills 50% of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value -an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value -maximum allowable concentration
or ceiling, not to be exceeded during a 15 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a developing
embryo.
Is the material harmful to aquatic life?
White Mesa Mill -Standard Operating Procedures
Book 8 Section 7
Date: 05/16 Revision: EFR 5
Page 4 of 6
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to burn without the addition
of more heat.
Auto-ignition Temperature -the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range -the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 7
Date: 05/16 Revision: EFR 5
Page 5 of 6
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from Oto 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
Level A -Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B -Requires the highest level of respiratory protection, but a lower
level of skin protection. It is the minimum level recommended on initial
entries until the hazards have been further identified and defined by
complete monitoring, sampling, and evaluation.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 7
Date: 05/16 Revision: EFR 5
Page 6 of 6
For the
Environment
Level C -Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D -Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Safety Data Sheet can be used to collect additional information of a
more specific nature.
Vanadium Fusing and Packaging
1. Ammonium Metavanadate (A.M.V.)
2. Caustic Soda
3. Propane
4. Sulfuric Acid -93%
5. Vanadium Pentoxide (Blackflake)
6. Ammonia
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
Hazards-Vanadium Fusing and Packaging
1. High de-ammoniator operating temperatures -1,300°F.
2. High fusion furnace operating temperatures -1,650°F.
3. Molten vanadium
Date: 02/16 Revision: EFR 4
Page 1 of9
4. Molten vanadium coming in contact with water -could cause an explosion, splatting
molten vanadium
5. Hot pipes and ductwork
6. Vanadium dust
7. High working area temperatures
8. Propane gas
9. Cleaning fusion furnace spouts
10. Cleaning de-ammonia hearths and hearth drops
11. Cleaning plugged augers
12. Handling vanadium drums
13. Elevated walkways
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
Hazard Recognition -Blackflake (V20s) Packaging Area
1. Hazards
a. Heat
1. From fusion furnaces
2. From V 205 bin
3. From bucket elevator
4. Casting wheels
5. De-ammoniator
Date: 02/16 Revision: EFR 4
Page 2 of9
6. Coveralls and long-sleeved shirts will be supplied
7. Water will be supplied
b. Drums
1. Stacking of drums
2. Rolling drums on rollers
3. Standing on rollers to install drum lids
4. Training and forklift safety
5. Seat belts must be worn when using equipment
6. Strip doors
a. Cannot see through the doors
b. Use of man doors when entering the vanadium area
c. Caution when removing full drums to the outside
7. Safe use of impact wrenches
c. Filling of Drums
1. Hood on the feeder must be on the rim of the drum
2. V 205 bin must not be leaking above the operator area; if it leaks, report
it immediately
3. Caution when working on the star feeder -must be locked out
4. Caution around the casting wheel dump chute when shoveling spilled
material
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
Date: 02/16 Revision: EFR 4
Page 3 of 9
5. Use of air to blow off scales only; use water for the rest of the area
6. Do not spray water onto the fusion furnace shells
d. Health Hazards
1. Vanadium dust
a. Coveralls and long sleeves
b. Full face respirators
c. Gloves
d. Vanadium dust sampling will be done as needed
e. Ammonia fumes from the V 20s scrubber thickener
2. Hearing protection
3. Radiation
a. Airborne uranium -sampled monthly
b. Radon daughters -sampled monthly
c. Beta and gamma -sampled monthly
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
Hazard Recognition -A.M. V. Packaging Area
1. Hazards
a. Drums
1. Stacking of empty drums
2. Rolling full drums on rollers
3. Training and forklift safety
a. Seat belts must be worn at all times
4. Strip doors
a. Cannot see through the doors
Date: 02/16 Revision: EFR 4
Page 4 of 9
b. Using man doors when entering the vanadium area
c. Using the forklift when removing full drums to the outside
5. Impact wrench ( safe use of)
b. Filling of Drums
C.
1. Auger outside enclosure
a. Guard must be in place
2. Drum tops must be up close to the feeder hood to eliminate dust
exposure
Health Hazards
1. Vanadium dust
a. Coveralls must be worn
b. Full face respirators
C. Gloves
2. Heat
a. From the fusion furnace area
b. Water will be supplied
3. Hearing protection
a. Required in the vanadium building
4. Radiation
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
a. Airborne uranium
b. Radon daughters
c. Beta and gamma
Date: 02/16 Revision: EFR 4
Page 5 of9
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
Hazard Recognition -De-ammoniator Area
1. Hazards
a. Heat or Hot Surfaces
1. Ducting (steel)
2. Cyclone (auger and bin)
3. De-ammoniator (surface)
4. Doors
a. Opening of outer doors
1. Use of gloves
Date: 02/16 Revision: EFR 4
Page 6 of9
2. Close doors when finished raking
b. Inner doors
1. Use of gloves
2. Hearths average 500°F to 1,000°F.
3. Caution when raking clinkers from the de-ammoniator
4. Caution -do not rake material past the outer door
5. Rake handles and doors are extremely hot
6. Hand rails are hot in all areas around the de-
ammoniator
7. Close doors when finished raking clinkers
b. V2Os Control Room
1. MCC panel
a. Keep all doors closed on the panel
b. Be careful when washing down
c. Floor is slippery when wet
d. Air conditioner installed to relieve heat from the control room
c. Fusion Furnace Area
1. Fusion furnace feed augers
a. Hot -approximately 500 F to 1,000 F.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
b. Guards on drives
c. Guards on de-ammoniator drive
Date: 02/16 Revision: EFR 4
Page 7 of9
d. Augers must be locked out before cleaning or maintenance
work
e. Door on chute must be replaced prior to starting auger
2. Fusion furnaces
a. Spouts
1. Be extremely cautious when drilling or chipping out
spout with casting wheel running
2. Splattering caused from hot material falling off the
casting wheel
3. Rotation casting wheels are hot
4. No one is permitted beyond the hand rails above the
casting wheel while it is in operation
5. Hand rails are extremely hot
3. Casting wheels
a. Points for accident potential
1. Between bucket elevator and wheels
2. Between fusion furnaces and wheels
3. Between augers and casting wheels
d. De-ammoniator
1. Chipping of fused material off rabble arms
a. Safe Work Permit
b. Lock out all equipment
c. Air lines; whip checks
d. Personal protective equipment
1. Leather gloves
2. Full face respirator
3. Cotton coveralls
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
e. Fusion Furnaces
1. Chipping of spouts
a. Rotating casting wheels
Date: 02/16 Revision: EFR 4
Page 8 of9
b. Using bars above the rotating casting wheels
c. If completely plugged:
2. Health Hazards
a. Heat
1. Shut down and lock out
2. Air drill; whip check, long steel, and be qualified to
operate the air drill
3. Lock out the feed auger
4. Adjusting spout burners will be adjusted before starting
the casting wheels
1. Water will be supplied
2. Cotton coveralls (with sleeves intact) will be worn in this area and are
furnished by the company
3. Leather gloves (furnished by the company)
b. Vanadium Dust
1. Coveralls
2. Leather gloves
3. One-half hour of paid overtime for showers
4. Eye wash (furnished by the company)
5. Full face respirators are required
6. Sampling for vanadium dust will be accomplished per corporate
directives
7. Hearing protection required
White Mesa Mill -Standard Operating Procedures
Book 8 Section 8
c. Radiation
1. Airborne uranium
2. Radon daughters
3. Beta and gamma
Date: 02/16 Revision: EFR 4
Page 9 of9
White Mesa Mill -Standard Operating Procedures
Book 8 Section 9
JOB PROCEDURES
Date: 12/12 Revision: EFR 3
Page 1 of 2
This section covers job procedures for non-daily routine jobs that are performed
m:
VANADIUM FUSING AND DRYING
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 9
Safety Rules -Vanadium Fusing and Packaging
Date: 12/12 Revision: EFR 3
Page 2 of2
1. Exposure to excessive vanadium dust can be harmful. All spills should be cleaned up
as soon as possible.
2. An approved respirator will be worn in these areas at all times and clothing will be
washed daily.
3. Personnel working in this area are required to shower at the end of each shift.
4. Be aware of and avoid hot surfaces around the furnace and cooling wheel.
5. If the dust collectors are not operating properly, the operation should be shut down as
soon as possible.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
Date: 04/14 Revision: EFR 4
Page 1 of9
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
GENERAL RULES
Reporting Unsafe Conditions and Injuries
Date: 04/14 Revision: EFR 4
Page 2 of9
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries -no matter how slight -to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Per onal Protective Equipment and Clothing
1. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area -except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
c. Rubber gloves and rubber boots
Date: 04/14 Revision: EFR 4
Page 3 of 9
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
a hazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs, or having them in
your possession while in the plant area.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
Date: 04/14 Revision: EFR 4
Page 4 of9
3. Fighting, wrestling, or engaging in "horseplay" while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
Date: 04/14 Revision: EFR 4
Page 5 of9
MOBILE EQUIPMENT -SAFETY RULES
General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be driven
to the shop for repairs. Otherwise, the equipment must be towed or repaired at the
location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
Date: 04/14 Revision: EFR 4
Page 6 of9
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
11. Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required
White Mesa Mill -Standard Operating Procedures
Book 8 Section I 0
Date: 04/14 Revision: EFR 4
Page 7 of9
OPERA TIO NS -SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
8. Safe operation of conveyors requires that you shall:
Date: 04/14 Revision: EFR 4
Page 8 of 9
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
Safety Rules -Vanadium Fusing and Packaging
1. If any part of the dust collecting system for the drying and packaging facility is not
working, the operation shall be shut down at once.
2. Exposure to excessive vanadium dust can be harmful. All spills should be cleaned up
as soon as possible.
3. All clothing used in the vanadium area must be washed daily.
4. All spills and dust leaks shall be cleaned up at once and the cause corrected
immediate! y.
5. Personnel working in this area are required to shower at the end of each shift.
6. Be aware of and avoid hot surfaces around the furnace and cooling wheel.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 10
Date: 04/14 Revision: EFR 4
Page 9 of9
SAFE WORK PERMIT
Issued by: ___________ Date: ________ Time: ____ _
For Dept.: ___________ In area: ______________ _
Task to be performed: _______________________ _
Permit good until: _________________________ _
Confined space hazard evaluation completed by: ______________ _
REQUIRED PRECAUTIONS
Safety Dept. approval for confined space entry
Review MSDS Where Applicable
Appropriate Lockout/Tagout/Zero Energy
Considerations
Atmosphere checked for explosion, toxicity, and
oxygen (see Safety Department)
Continuous air monitor
Radiation work permit
Shower and eye wash checked
Special zero energy considerations
Openings roped off or guarded
Proper ladder tied off
Ground fault interrupter
Class 1 Division 1 explosion proof lights
Proper bonding and grounding of equipment and
material will be verified for permissible OHMS
resistance by a qualified electrician
Fire extinguisher and/or charged hose
Test welding hose for leaks
Qualified safety watch with radio
Stay clear when lifting materials overhead
Cleanup of all spare parts and debris
PERSONAL PROTECTIVE EQUIPMENT
Splash goggles D Face shield D Rubber suit D
F .F. respirator D
PAPR respirator D
Rubber boots D SCBA 0
Cartridge type D Safety belt & line D
COMPLETED BY
Latex Nitril gloves D
Hearing protection D
Other equipment _____________________________ _
Special instructions
Job completed: Date __________ _ Supervisor __________ _
Reviewed by: Dept. Head ________ _ Safety Department _______ _
White Mesa Mill -Standard Operating Procedures
Book 8 Section 11
Date: 12/12 Revision: EFR 4
Page 1 of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for pre-leach and leach which, when
followed, will maintain your exposures ALARA. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained ALARA.
Vanadium Fusing and Packaging Radiation Safety Procedures
1. ALARA Program Policy Statement
The policy of Energy Fuels Resources (USA) Inc. to maintain good radiation
protection practices is the expenditure of every reasonable effort to achieve and
maintain low levels of contamination and radiation in occupational exposures. By
definition, the ALARA program shall result in radiation exposures being maintained
to levels far below any applicable limits of the NRC regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Energy Fuels Resources (USA) Inc. is committed to maintammg occupational
exposures of personnel at White Mesa to levels as reasonably achievable. This
commitment is supported by the training program conducted for facility personnel,
continuous reviews of radiation, environmental and industrial hygiene protection
policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2. Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
initial assessment of the work environment and associated work tasks as related to
White Mesa Mill -Standard Operating Procedures
Book 8 Section 11
Date: 12/12 Revision: EFR 4
Page 2 of 5
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at vanadium fusing and packaging may require a
Radiation Work Permit if the initial radiological assessment indicates a
potential for elevated radiation exposure:
1. Vanadium Fusing and Packaging
a. Entry into tanks.
b. Cleaning out the sumps.
c. Cleaning of the demister scrubber system.
d. Clean up of spills around the pulp storage tanks.
This is not an all-inclusive list of jobs at Vanadium Fusing and Packaging that could
require a Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
As a part of ALARA practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION -AIRBORNE RADIOACTIVE AREA This sign is posted in an area
in which airborne uranium or radon daughter concentrations are, or at above 25% of
the specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25% DAC. The following areas
White Mesa Mill -Standard Operating Procedures
Book 8 Section 11
Date: 12/12 Revision: EFR 4
Page 3 of 5
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon daughter concentrations above 25%
DAC:
a. Vanadium Fusing and Packaging Area
CAUTION -RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 rnr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Decreasing time of exposure.
b. Increasing distance between you and the source.
c. Increasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the respirator room. After the
initial fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to
change the filter after two to three hours. When resistance to breathing
becomes uncomfortable, it is a sign that the filters have served their useful life
and need to be replaced.
c. If you are using a respirator with combo cartridges for protection against
nuisance fumes or mists, the chemical concentration of the contaminants must
be less than the limit set by the manufacturer and the oxygen concentration
must be at or above 19.5%.
d. If you are detecting an odor or changing combo cartridges frequently, it is an
indication that the chemical concentration exceeds the chemical cartridge
limits and you should leave the area and notify your supervisor immediately.
5. Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
White Mesa Mill -Standard Operating Procedures
Book 8 Section 11
Date: 12/12 Revision: EFR 4
Page 4 of 5
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your OSL badge when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas, if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions. Check the following equipment:
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at vanadium fusing and packaging will be
taken monthly. Urinalysis samples are utilized to determine the uranium content
contained in the urine of the operator. The frequency of sampling is dependent on the
airborne concentrations and will be changed if airborne levels exceed 25% of the
airborne standards.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 11
Date: 12/12 Revision: EFR 4
Page 5 of 5
To minimize the change of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the bioassay laboratory in the
Administration Building upon returning from your scheduled days off (two
and four days). The sample containers should be filled after washing your
hands and prior to changing into your work clothes or reporting to your work
location. The samples can then be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner,
the worker should shower immediately prior to voiding. When a shower is not
possible, disposable plastic or rubber gloves should be worn during voiding. Take all
necessary precautions to ensure that your urine sample is not contaminated.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 12
Date: 02/16 Revision: EFR 4
Page 1 of 4
OPERA TOR'S RESPONSIBILITIES
1. Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
2. After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
3. The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book. Any items that are out of the ordinary should also be
documented on the Operating Foreman's Daily Inspection form.
4. It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate departments within specified parameters.
c. No alarms are to be blocked out or otherwise made to be inoperable at any
time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 12
Date: 02/16 Revision: EFR 4
Page 2 of 4
1. If a sample is contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
f. Communicate operating conditions in an accurate and timely manner.
g. Maintain and practice good housekeeping.
h. Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Vanadium operators will be required to shower before leaving the mill. These
operators will be paid ½ hour of overtime to shower.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 12
Date: 02/16 Revision: EFR 4
Page 3 of 4
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
survey. If the alarm sounds again, contact a member of the Radiation Safety Staff.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
White Mesa Mill -Standard Operating Procedures
Book 8 Section 12
Date: 02/16 Revision: EFR 4
Page 4 of 4
I have read, understood and have had the opportunity to ask questions regarding the
procedures set forth in this book.
Date -----------
Name (print) ____________ _
Name (signature) ___________ _
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 1 of 19
1.0 RADIATION MONITORING-PERSONNEL
This section contains the following procedures for personnel radiation monitoring
including: (1) airborne particulates (2) alpha surveys (3) beta/gamma surveys and (4)
urinalysis surveys.
1.1 AIRBORNE PARTICULATES
Sampling for personnel exposure to airborne particulate radionuclides, other than for
radon progeny, is done utilizing two distinct sampling protocols: (1) personnel breathing
zone samplers, and (2) ambient air high volume samplers. Specific standard operating
procedures for these two collection methods is described in Section 1.1.2 and 1.1.3
below.
1.1.1 Frequency
For work where there is the potential to cause airborne radiation doses to site personnel,
the frequency and type of air sampling to be conducted is determined from measured air
concentrations:
0.01 DAC -0.1 DAC Quarterly or monthly area air sampling and/or bioassay
measurements
>0.1 DAC Continuous sampling is appropriate if concentrations are
likely to exceed 0.10 DAC averaged over 40 hours or
longer.
The RSO will determine the exact frequency of area air sampling, breathing zone sampling
and/or bioassay measurements and determine how many workers in a group of workers
performing similar jobs are to be equipped with breathing zone air samplers. Higher
airborne concentrations warrant more frequent use of area air samplers, bioassay
measurements, and breathing zone air samplers. Area air samplers may be used where
documentation exists showing the sample is equivalent to a breathing zone sample.
Breathing zone samples taken within one foot of the worker's head is considered
representative without further documentation. Breathing zone air samplers are preferred
under work conditions of higher airborne concentrations. Table 1.1.1-1 below, from
Regulatory Guide 8.25, provides additional guidance for the RSO in designing and
implementing air-sampling programs for specific jobs.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 2 of 19
Table 1.1.1-1
Air Sampling Recommendations Based on Estimated Intakes and Airborne Concentrations
Worker's Estimated Estimated Airborne
Annual Intake as a
Fraction of ALI
< 0.1
> 0.1
Any annual intake
Concentrations as a Air Sampling Recommendations
Fraction of DAC
< 0.01 Air sampling is generally not necessary.
> 0.01
<0.3
>0.3
> 1
>5
However, monthly or quarterly grab samples or
some other measurement may be appropriate to
confirm that airborne levels are indeed low.
Some air sampling is appropriate. Intermittent or
grab samples are appropriate near the lower end of
the range. Continuous sampling is appropriate if
concentrations are likely to exceed 0.1 DAC
averaged over 40 hours or longer.
Monitoring of intake by air sampling or bioassay is
required by 10 CFR 20.1502(b).
A demonstration that the air samples are
representative of the breathing zone is appropriate
if ( 1) intakes of record is based on air sampling and
(2) concentrations are likely to exceed 0.3 DAC
averaged over 40 hours (i.e., intake more than 12
DAC-hours in a week).
Air samples should be analyzed before work
resumes the next day when potential intakes may
exceed 40 DAC-hours in 1 week. When work is
done in shifts, results should be available before the
next shift ends. (Credit may be taken for protection
factors if a respiratory protection program is in
place.)
Continuous air monitoring should be provided if
there is a potential for intakes to exceed 40 DAC-
hours in 1 day. (Credit may be taken for protection
factors if a respiratory protection program is in
place.)
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
1.1.2
1.1.2.1
Breathing Zone Sampling
General
Date: 03/09/2020Revision: EFR 15
Page 3 of 19
Breathing zone samplers (SKC pumps and accessory kits, or equivalent) are used to
determine airborne exposure to uranium while individuals are performing specific jobs.
The units consist of a portable low volume pump that attaches to the individuals belt, tygon
tubing and filter holder that is attached to the individual's lapel or shirt collar. The unit
monitors airborne uranium in a person's breathing zone. Pumps must be recharged after 6
to 8 hours of use.
1.1.2.2 Applicability
Breathing zone samples are required:
• for all calciner maintenance activities,
• at least quarterly during routine operating and maintenance tasks on
representative individuals performing these tasks,
• when radiation work permits are issued in which airborne concentrations may
exceed 25% of 10CFR20 limits,
• weekly for yellowcake operations, or
• at the discretion of the RSO.
1.1.2.3 Procedure
The procedure for collecting a breathing zone sample is as follows:
1. Secure the breathing zone sampler, which has been charged and loaded with a filter
paper from the radiation department.
2. Secure the pump to the worker's belt and the filter holder to the shirt collar or lapel.
Try to secure pump tubing to minimize restriction of motion.
3. Turn pump on and continue monitoring until the work being monitored is completed
and the worker no longer is in the exposure area. Record the total time at which the
job is complete.
4. Return the pump and accessories to the RSO or designee, who will remove the filter
paper for analysis after a 24-hour decay period. Be sure to indicate accurately the total
time taken by the work being monitored.
5. Analysis of filter samples will be performed using a sensitive alpha detector. The
procedure is as follows: (a) count a background sample for ten minutes; (b) divide the
background count by ten to obtain the background count rate in cpm; ( c) Place the
breathing zone sample in the instrument and count the sample again for ten minutes;
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 4 of 19
(d) divide the sample count by ten to obtain the count rate in cpm; (e) subtract the
background count rate from the sample count rate; and, (f) record all data on the
Breathing Zone sampling analysis form (a copy of which is attached).
6. Record the total hours of exposure that are being assigned to the employee on the
Employee Exposure form, which is maintained in personnel folders. Be sure to
consider protection factors permitted by respirator use if the employee was also
wearing respiratory protection during the job.
7. The number of DAC hours assigned is calculated using the following formula:
DAC hours = Measured air concentration x Total hours of exposure
of exposure (DAC)(PF)
Where: DAC = Derived Air Concentration (for uranium; 10 CFR Part 20,
Appendix B)
PF = protection factor for respirator use. If no respiratory protection
was used PF =l.
The measured air concentration must be in µCi/cc.
1.1.2.4 Calibration
Prior to use, calibration of the breathing zone samplers will be done using a calibration
method as described in Section 3.2.
1.1.2.5 Equipment -Breathing Zone Sampler
The equipment used for breathing zone samples consists of:
1. Personal sampling pumps
2. Gelman 37 mm Delrin filter holders, or equivalent
3. Gelman 37 mm type A/E glass fiber filters, or equivalent
4. Kurz Model 543 air mass flow meter, or equivalent
1.1.2.6 Data Record
Data maintained on file includes:
1. Run time for each sample pump.
2. Sampling location(s).
3. Individual's name, identification number, etc.
4. Date and sample number.
5. Sample count rate.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Date: 03/09/2020Revision: EFR 15
Page 5 of 19 Book 9: Radiation Protection Manual, Section 1
1.1.2.7 Calculations
The airborne concentration in µCi/cc is equal to the sample count rate minus the
background count rate in cpm divided by the instrument alpha efficiency, the sample flow
rate in cc/minute, the sample time in minutes and a conversion factor converting dpm to
µCi.
The calculation is:
Eq uation Number 1:
Airborne concentration= (Count Rate)
(Time)(eff.)(Conversion factor)(Flow Rate)
i.e. µCi= (cpm-Bkg) 1 uCi (1) (1)
cc ( eff. )(2.22x 106dpm)( cc/min)(min)
Where: eff. = cpm/dpm for counting instruments
cpm = counts/min
dpm = di integrations/min
conversjon factor 1 µCi= 2.22xl06 dpm
Flow Rate = cc/min
Collection time = min
Once the airborne concentration has been calculated it is possible to calculate personnel
exposure in microcuries (µCi). Personnel exposure is determined for an individual who is
working in an area at a known air concentration (µCi/cc) for a given amount of time (hours)
breathing the area air at an assumed rate. The breathing rate for a standard person
(Handbook of Radiological Health) is 1.20 cubic meters per hour (m3/hr.).
The calculation for personnel exposure is:
Equation Number 2:
Exposure µCi= (µCi/cc)(l.20m3/hr.)(hours of exposure)(conversion rate)
Where: µCi/cc = air concentration from Equation 1
1.20 m3/hr. = breathing rate for standard man (ICRP)
hours of exposure = hours
conversion factor = I06cc/m3
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 6 of 19
It is also possible to determine the percent or fraction of the Derived Air Concentration
(DAC) for a particular radionuclide using the information obtained from the exposure
calculation and dividing this value by the regulatory limit DAC listed in 10 CFR Part 20.
% DAC = Exposure in µCi/µCi limit 10 CFR Part 20
For the natural uranium (U-Nat) the DAC limits from 10 CFR Part 20 for insoluble Class
Y compounds are as follows:
1.1.2.8
• Weekly
• Quarterly
• Yearly
1.0 x 10-3 µCi/week
1.25 X 10-2 µCi/Qt
5.0 X 10-2 µCi/yr.
ALARA/Quality Control
The RSO reviews each monitored result and initiates action if levels exceed 25% of 10
CFR 20 limits. At a minimum, ten percent (10%) of the air samples collected in a given
quarter will be recounted using the same instrument or using a different instrument and
these results will be compared to the original sample results. Deviations exceeding 30%
of the original sample results will be reviewed by the RSO and the samples will be
recounted again until the sample results are determined to be consistent. Additional QA
samples consisting of duplicate samples and blank samples will be submitted to the
radiation department for counting. This will be based on ten percent ( 10%) of the number
of samples collected during a quarter. The sample results will be compared to duplicate
values or blank (background) values of the prepared sample. Deviations exceeding 30%
of the determined duplicate or blank value will be recounted. If no resolution of the
deviation exceeding 30% is made the QA samples preparation will be repeated. Periodic
reviews by the RSO and the ALARA audit committee will be made and documented to
ensure quality maintenance and ALARA control.
1.1.3 Airborne High-Volume Sampling
Grab air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airborne
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high-volume sample pump will be
used for this purpose. Samples will be analyzed as per standard gross alpha analysis
procedures using a sensitive alpha detector.
1.1.3.1 Frequency and Locations
The following principles used for the collection of area grab samples must be considered
when collecting a sample in order to obtain a representative air concentration that workers
may be exposed to during their assigned work tasks.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 7 of 19
1. The locations selected for sampling should be representative of exposures to employees
working in the area.
2. For special air sampling, the sampling period should represent the conditions during
the entire period of exposure. This may involve sampling during the entire exposure
period.
3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow
rate of 40 liters per minute for at least 60 minutes.
4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector. A decay
period of 3 to 7 days is required to count only long lived alpha.
5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for
special jobs or non-routine situations.
1.1.3.2 Sampling Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40
liters per minute for one hour or longer. Equipment utilized will be and Eberline RAS-1,
or a Scientific Industries Model H25004, or equivalent. Filter media will be of appropriate
micron pore diameter. Equipment is calibrated prior to each usage as per Section 3.3 of
this manual.
1.1.3.3 Sampling Procedure
Steps for collection of area airborne grab samples are as follows:
1. A high-volume pump will be used for sample collection.
2. Check sample pump calibration.
3. Locate sampler at designated site. Insert a clean filter, using tweezers, into the filter
holder on the sampler. Do not contaminate the filter. Log start time and Mill operating
conditions at the site.
4. Collect a sample for a minimum of 60 minutes at a flow rate of 40 liters per minute.
5. After sampling is completed, carefully remove the filter, using tweezers, from the filter
holder and place it in a clean glassine envelope, or in the plastic casing furnished with
the filter.
6. Log all sample data on the log sheet.
A. Sample location and number (also on the envelope).
B. Time on, time off and date.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section I
C. Mill operating conditions at the site.
D. Sampler's initials.
7. Analyze for gross alpha
1.1.3.4 Calculations
Perform calculations as described in Section 1.1.2. 7.
1.1.3.5 Records
Date: 03/09/2020Revision: EFR 15
Page 8 of 19
Logs of all samples taken are filed in the RSO's files. Data are used to calculate radiation
exposures as described in Section 4.0.
Whenever grab sampling results indicate that concentrations in work locations exceed 25%
of the applicable value in 10 CFR Part 20, Appendix B, time weighted exposures of
employees who have worked at these locations shall be computed. Calculations will reveal
an individual's exposure in DAC hours. This value shall be assigned to the worker and
logged onto the worker's "Employee Exposure to Airborne Radionuclides" form. This·
form is in Section 4. Whenever special air sampling programs (as required for cleanup,
maintenance, decontamination incidents, etc.) reveal that an employee has been exposed
to airborne radioactive material, the calculated value shall also be entered on the
individual's exposure form.
1.1.3.6 Quality Assurance
Function checks on each air sampler, prior to field use, ensure accurate airflow volumes.
Use of tweezers and new filter storage containers minimizes contamination potential. Field
logging of data during sampling and logging of identifying data on sampled filter
containers minimizes sample transposition. Quality control samples will be analyzed as
described in Section 1.1.2.8
Review of data by the RSO and by the ALARA Audit committee further assures quality
maintenance.
1.2 ALPHA SURVEYS
1.2.1 Restricted Area
The Restricted Area is defined as:
1. The property area within the chain link fence surrounding the mill property and the area
enclosed to the north and east of the facility by the posted Restricted Area fence.
2. The active tailings and liquid waste disposal areas.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 9 of 19
All personnel who enter the Restricted Area will monitor themselves each time they leave
the Restricted Area and at the end of their shift. The Radiation Safety Department will
review the monitoring information. All personnel exiting the Restricted Area must initial
a record of their monitoring activity.
1.2.2 Instrumentation
The instrumentation utilized for personnel alpha scanning is listed in Appendix 1 at the end
of this manual. Personnel alpha survey instruments are located at the exits from the
Restricted Area.
1.2.3 Monitoring Procedures
The monitoring procedure includes the following steps:
1. The alarm rate meter should be set as close to 1,000 dpm/100 cm2 without exceeding
that mark.
2. An individual monitors himself by slowly passing the detector over their hands,
clothing and shoes, including the shoe bottoms, at a distance from the surface of
approximately 14 inch. An area that is suspected of possessing any contamination (i.e.
hands, boots, visible spotting/stain on clothing etc.) should be carefully monitored by
placing the detector directly on the surface and note the measurement.
3. Should an alarm be set off indicating the presence of contamination, the individual
should:
a. Resurvey themselves to verify the contamination.
b. If contamination is present the individual must wash the affected area and again
resurvey themselves to ensure the contamination has been removed.
4. If the decontamination efforts by the individual are not successful, then the Radiation
Safety personnel will be contacted to assess the situation. Further decontamination
may be required.
5. If an individual's clothing cannot be successfully decontaminated, they must obtain
clothing from the warehouse to use and must launder the personal clothing in the
laundry room by a member of the Radiation staff.
6. Individual surveys are to be logged and initialed.
7. Access to and from the Mill's Restricted Area by all Mill workers, contractors and
delivery personnel, other than Radiation, Safety and Environmental Staff, Senior
Laboratory personnel, Mill Management and Mill Supervisory personnel and others as
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 10 of 19
may be designated by the RSO, will be limited to one or more access points as may be
designated by the RSO from time to time.
8. A Radiation Technician will be positioned at each access point designated by the RSO
under paragraph 7 above during peak transition times, such as during breaks and at the
ends of shifts, to observe that each worker, contractor or delivery person is performing
a proper scan. This paragraph 8 will cease to apply to any such access point if and
when one or more automated full body scanners portals or the equivalent are situated
at the access point, which would require workers exiting at that location to scan
themselves by exiting through the portal, and the procedures in this Manual are
amended to incorporate the use and maintenance of such portal or portals.
1.2.4 Training
All employees will be trained on the proper scanning procedures and techniques.
1.2.5 Records
Log sheets will be collected daily and filed by the Radiation staff. Records will be retained
at the Mill. Contamination incidents will result in a written record, which is maintained on
file.
1.2.6 Limits/ ALARA
Contamination limits for personnel scans are set at 1,000 dpm/100 cm2• Records will be
reviewed by the RSO to maintain levels noted as low as reasonable achievable.
1.2.7 Quality Assurance
A random check of an individual's scanning technique provides quality assurance of the
monitoring procedures. Daily function checks using calibrated sources assures
instrumentation performance. Periodic review by the RSO and the ALARA audit
committee document and ensure quality control and ALARA maintenance.
1.3 BETA-GAMMA SURVEYS
Site employees working within the Restricted Area will be required to wear a personal
monitoring device (such as a TLD, LUXEL badge or other NVLAP approved device which
has been approved by the RSO and the SERP) during their work period. The personal
monitoring devices are normally issued to each employee quarterly; however, during
pregnancy or if the radiological potential for exposure to an individual is anticipated to be
elevated and requires quick assessment the badges may be issued monthly.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
1.3.1 Monitoring Procedures
The monitoring procedures consist of:
Date: 03/09/2020Revision: EFR 15
Page 11 of 19
1. Personnel issued personal monitoring devices will wear the device on the trunk (torso)
of the body. The personal monitoring device records beta/gamma radiation as well as
other forms of penetrating radiation such as x-rays. A personal monitoring device is an
exposure record of an individual's personal exposure to radiation while on the job.
Therefore, personal monitoring devices are to remain at the Mill and stored on the
assigned dosimeter storage boards. All exposure records obtained by a personal
monitoring device which are not consistent with the exposure rates of work tasks or
work location measurements made throughout the Mill will be evaluated by the RSO.
This evaluation will result in an investigation by the RSO and a written explanation of
the findings. These written records will be maintained at the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be
exchanged by the Radiation Safety Department. Missing or lost badges will be reported
to management.
3. Female employees that become pregnant who declare their pregnancy and continue to
work during the course of their pregnancy will be placed on a monthly personal
monitoring device exchange during this period. NRC Regulation Guide 8.13 provides
guidelines to be followed during pregnancy and is made part of this procedure.
1.3.2 Records
The Radiation Safety Department will maintain all occupational exposure records in the
departmental files:
1. Occupational exposure records are a part of an individual's health record and, as such,
will be considered private information.
2. An individual may examine his/her exposure record upon request.
3. An employee terminating his/her employment with Energy Fuels Resources (USA) Inc.
may request a copy of his/her occupational exposure records.
4. The Radiation Safety Department on the signature of the employee will request prior
occupational exposure records.
5. Occupational exposure records will be made available to authorized company or
regulatory personnel.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
1.3.3 Quality Assurance
Date: 03/09/2020Revision: EFR 15
Page 12 of 19
Periodic reviews by the RSO and the ALARA audit committee document and ensure
quality control and maintenance of conditions ALARA.
1.4 URINALYSIS SURVEYS
1.4.1 Frequency
Urinalyses will be performed on those employees that are a) exposed to airborne
yellowcake or involved in maintenance tasks during which yellowcake dust may be
produced, b) routinely exposed to airborne uranium ore dust or c) after the use of a
respiratory device if the employee is not being monitored under one of the other
aforementioned tasks. Baseline urinalyses will be performed prior to initial work
assignments. A sample will also be collected after the completion of an individual's
employment at the facility.
Urine samples are collected on a routine basis from mill employees as required in
Regulatory Guide 8.22. Urine samples will be collected from employees who have worked
in yellowcake packaging, yellowcake precipitation, grind area (SAG mill), ore feed, sample
plant, scale house, and the sample preparation room every two weeks during production
periods. Samples will be collected from all other employees monthly during production
periods or after periodic respirator usage. During non-production periods, bi-weekly
samples will be collected if individual exposures are expected to exceed 25% of the DAC
value otherwise samples will be collected from all employees quarterly. Non-routine
urinalyses will be performed on employees who have been working on assignments that
require a Radiation Work Permit and the use of a respiratory device, and always on any
individual that may have been exposed to airborne uranium or ore dust concentrations that
exceed the 25% of the DAC level.
1.4.2 Specimen Collection
Clean, disposable sample cups with lids will be provided to each employee that will be
required to submit a urine specimen. The containers will be distributed by a Radiation
Technician at the administration building before individuals enter the Restricted Area prior
to the beginning of their shift.
The container, filled to a minimum of 20 mL with specimen, will be returned to the
Designated area or to the authorized person prior to reporting to work. The Radiation
Technician will initiate a Chain of Custody on samples received. Any samples not returned
will be considered as taken during shift. The name of the employee and the date of
collection will be recorded, and the sample identification number will be indicated on the
specimen cup. Specimen samples will be put in a controlled location and the laboratory
will be notified of their receipt. The laboratory will be contacted when samples are
received and after the Chain of Custody is completed.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section I
Date: 03/09/2020Revision: EFR 15
Page 13 of 19
A valid sample must be collected at least 48 hours, but not more than 92 hours, after the
most recent occupancy of the employee's work area ( after two days, but not more than four
days off).
The specimen should be collected prior to reporting to the individual's work location. To
prevent contamination, the hands should be carefully washed prior to voiding.
Under unusual circumstances where specimens cannot be collected in this manner, the
worker will shower immediate I y prior to voiding.
1.4.3 Sample Preparation
Equipment required:
• 50 mL disposable centrifuge tubes with lids (or equivalent)
• 15 mL disposable centrifuge tubes with lids
• 10 mL pipette
• 1 mL pipette
• 200 µL pipette
• 5 µL pipette
• 10 µL pipette
• Disposable tips for the above pipettes
• 1,000 -100 ppm uranium spiking solution
• Stir Rod
• Concentrated Nitric Acid
After the specimens are received, they will be stored in a refrigerator until they are prepared
for analysis.
Sample preparation will be done in an area decontaminated to less than 25 dpm alpha
(removable) per 100 cm2 prior to preparation of samples. All of the equipment that is used
in sample preparation will be clean and maintained in such condition. The sample
preparation will be conducted by a member of Laboratory Staff.
A Chain of Custody (COC) will be prepared and the following information will be kept for
each urinalysis performed:
Sample identification number
Name of employee submitting the specimen
Date/time of sample collection
Name of person receiving specimen (member of the Radiation Staff)
Date the sample was sent to the laboratory
Date the results were received
Results of the urinalysis in µg/L
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Indication of expected spike concentration (µg/L)
Date the sample was disposed
Name of person disposing
Date: 03/09/2020Revision: EFR 15
Page 14 of 19
50 mL centrifuge tubes (or equivalent) will be marked with the sample identification
numbers. 20 -50 mL of urine will then be pipetted into the corresponding tube using the
pipette device and record the volume on the log. 1 mL of nitric acid is added to the tube
and is not capped until any reaction has subsided. The solution will then be checked to
ensure the pH is <2 being careful not to cross contaminate samples. If pH is >2, then
incrementally add acid until pH is <2.
The 15 mL centrifuge tubes will also be marked with each sample identification number.
10 milliliters of urine will then be pipetted from the 50 mL tube into the 15 mL centrifuge
tube using the pipette device. Or 1 milliliters of urine will then be pipetted into the
centrifuge tube using the pipette device (To prevent contamination, a new tip must be used
for each specimen). After each step of the procedure, the applicable entry must be recorded.
The samples that are to be spiked for quality assurance purposes will then be prepared. 100
-400 µL of the spike solution will be introduced into the sample with the correct pipette.
For example, with the standard spike solution of 1.0 g/L of U, a 100 µL spike will result in
a 10 µg/L concentration for the 10 mL sample; the 200 µL spike will give 20 µg/L. The
proper entry must be recorded for each sample spiked.
After preparation has been completed, the QA verification samples are securely packaged
as soon as practicable and sent to the contract laboratory for analysis.
The samples that are to be analyzed in-house will be placed in the chemistry laboratory's
refrigerator until the analysis can be completed. A copy of the in-house analytical
procedure is described in Section 1.4.5.
1.4.4 Quality Assurance / Quality Control
To assure reliability and reproducibility of the sample preparation process, at least 25% of
the samples that are submitted for analysis will be used for quality assurance purposes.
These samples will consist of matrix spikes, duplicates, and matrix blanks.
Matrix blanks are samples collected from individuals known to have no lung or systemic
uranium exposure. Results should be less than 1 Ox the reporting limit or 5 ppb.
Matrix spiked samples will be prepared as stated under sample preparation of this
procedure. The spike concentration must be more than 25% of the sample concentration.
Spike Recoveries should have a recovery of 100% ±30%.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 15 of 19
Duplicates will be identical samples of the same specimen and/or spikes of identical
samples and concentrations. Duplicate results should be within 20% Relative Percent
Difference (RPD)
To assure reliability of the in-house analytical procedure, 10% of the samples will be sent
to a contractor laboratory for analysis. These samples will contain quality assurance items
designed to provide intra-laboratory comparisons.
Instrumentation Quality Control (QC) will include:
In t s rument QC F requency
Calibration with a correlation coefficient Before Instrument run
(R) value of at least 0.995
Calibration Verification (CV) with at least At the beginning, after every 10 samples
a 90 -110% recovery and at the end of the run
Calibration Blank (CB) that is less than the After the CV
reporting limit of 0.5 ppb
Low Level Standard (LLS) at the lowest After the beginning CB
calibration level resulting in at least a 75 -
125% recovery
QC failure protocol: investigate cause of failure, Correct, and explain or reanalyze samples
and QC from last failure.
1.4.5 Analysis
After the samples are collected as outlined in Guide 1.4.2, they are identified by the lab by
sample identification number. Urinalysis results should be completed and reported to the
Radiation Safety Department within seven days of the sample collection.
1.4.5.1 Equipment List
1. Specimen collection cups with disposable lids (VWR No. 15708-711 or equivalent)
2. Screw cap, disposable, graduated 15 mL centrifuge tubes (Coming No. 25310 or
equivalent)
3. Micro-pipettes 1 each 5, 5 each 10 microliters (Oxford Model 7000 or equivalent)
4. Adjustable Finnpipette each 1,000 µL, 200 µL and 5 mL
5. Disposable micro-pipette tips for micro-pipettes (Oxford No. 910A or equivalent)
6. FumeHood
7. Ultrasonic Cleaner
8. PE-SCIEX ELAN DRC II AXIAL FIELD TECHNOLOGY ICP-MS (or equivalent)
9. Polyscience Water Circulator (or equivalent)
10. Perkin-Elmer AS-10 Auto Sampler ( or equivalent)
11. Thermo Scientific Vortex mixers (or equivalent)
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
1.4.5.2 Reagent List
1. 1 % to 2% Nitric Acid
2. Concentrated Nitric Acid
Date: 03/09/2020Revision: EFR 15
Page 16 of 19
3. 1,000 µg/mL Uranium Stock Solution, certified vendor prepared
4. Dilutions of the above stock solution. Used for QA/QC.
5. Appropriate Cleaning Solution for Ultrasonic Cleaner
6. Internal Standard, certified vendor prepared
Ensure that all reagents used are within their expiration dates listed on each reagent
package, if applicable.
1.4.5.3 Premise
A portion of urine is diluted with 2% Nitric acid solution, mixed thoroughly and analyzed.
1.4.5.4 Sa/ ety Precautions
1 Follow laboratory guidelines when working with acids.
2 Utilize all appropriate PPE.
1.4.5.5 Sample Preparation Procedure
1. Compare sample numbering with bioassay result sheet to ensure order and eliminate
discrepancies.
2. To 15 mL centrifuge tube add 1 mL urine sample, 200 µL of prepared internal standard
and dilute to 10 mL with 2% Nitric acid.
3. Maintaining sample order of left to right, front to back, lowest sample number to
highest sample number in the set is recommended.
4. Use vortex to mix it thoroughly.
5. Analyze using procedure on the ICP-MS described in section 1.4.5.6.
1.4.5.6 ICP-MS Procedures
Special considerations: Because of the high salt content of the samples, it is necessary to
clean the skimmer and sampler cones after each use as-well-as the sample introduction
glassware using a ultrasonic cleaner or by soaking in diluted nitric acid.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 17 of 19
1. Turn the argon on at the tank and set the delivery pressure at 80 pounds per square inch
(psi).
2. Turn on the chiller to the ICP-MS. The chiller has to have a delivery pressure of -50
psi. It may be necessary to change the filters on the water supply in order to achieve
sufficient water supply pressure. The ICP-MS will not operate too much below this
pressure.
3. Turn on the computer, monitor and printer.
4. On the windows desktop, double-click the ELAN icon.
5. Check the condition of the sample introduction system.
6. Check that the sample tubing and drain tubing leading from the peristaltic pump to the
spray chamber are properly set up and in good working condition. It is recommended
to use new tubes every day.
7. Place the capillary tubing into a container of 2% Nitric acid solution.
8. Open the instrument window, and then click the Front Panel Tab.
9. On the front panel tab click vacuum start if not started.
10. When the instrument is ready, click Plasma Start.
11. After the plasma ignites, allow the instrument to warm up for 45 minutes.
12. To begin sample analysis, click the sample tab, build the sample analysis list and click
on analyze sample.
13. After the last sample, aspirate the blank long enough to clean the lines.
14. Allow the pump to run long enough without aqueous uptake to void all lines.
15. Turn the flame off and relax lines off of pump.
16. After 5 to 10 minutes, turn off the water supply, exhaust fan and argon.
17. Instrument data logs will periodic~ly be downloaded onto a removable data storage
device and archived.
All bioassay samples need to be analyzed three (3) working days from receipt in the
laboratory. Samples are extremely susceptible to contamination. Precautions should be
taken to minimize traffic and fugitive dust while samples are exposed.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Date: 03/09/2020Revision: EFR 15
Page 18 of 19 Book 9: Radiation Protection Manual, Section I
1.4.6 Calculations
Use the calculations below to derive the reportable answer. Instrumentation may correct for one
or more of the following calculations, therefore, use only the necessary calculations.
Dilution Factor (DF)
Total volume(mL) after nitric acid added 1. Sample Prep DF =
Volume (mL) of urine added to 50mL tube
L b P DF Total volume (mL) in 15mL vial 2. a rep = --------------
Volume (mL) of prepared uJine added
3. Total DF = Lab Prep DF x Sample Prep DF
4.
5.
Concentration of U in
Sample (µg/L)
Expected U in
Spiked Samples or
CV (µg/L)
= Instrument x Total DF reading (µg/L)
spiking standard (µg/L) x Volume of spiking standard (mL) = ~-.....;;_-----'--''----------=---~-----
Total volume (mL)
6 S d d m R Standard Instrument Result (µg/L) X 100 . tan ar w ecovery = -----------------
Expected U in Spiked Sample or CV (µg/L)
S .k m R SpikelnstrumnetRe ult(µg/L)-Samplelnst.rumentRe: ult (µg/L) X 100 7. p1 e-10 ecovery =----------------------
Expected U in SpikedSampleor CV (µg/L)
I Sample (µg/L) -Duplicate (µg/L) I 8. RPD = X 100 (Sample (µg/L) + Duplicate (µg/L))/2
1.4. 7 Reporting and Corrective Actions
As soon as the analytical results are received, they are entered in the logbook and the entries
are checked for correctness and completeness. Prep QC and instrument QC will also be
documented with the reported results.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 1
Date: 03/09/2020Revision: EFR 15
Page 19 of 19
The lab report is returned to the Radiation Safety Department with results reported as
micrograms/liter of uranium. The information must be placed in the individual employee's
exposure file and maintained as directed by the DRC.
The Radiation Safety Department is notified immediately of any sample with a
concentration greater than 35 µg/1 of uranium. Corrective actions will be taken when the
urinary uranium concentration falls within the limits listed in Table 1 (attached).
The Laboratory Department should compute the error on the control spiked samples and
advise the lab if the results are more than ± 30% of the known values. If any of the results
obtained for the quality assurance control samples are in error by a ± 30%, the analysis
must be repeated.
1.5 IN-VIVO MONITORING
In-vivo body counting for lung burdens of U-natural and U-235 will not be routinely
conducted. Monitoring will be conducted at the discretion of the RSO, samples may be
sent for a follow-up analysis for specific radionuclides in consultation with EFR
management should potential exposure to an individual warrant.
)
T1bl11
CORIIECTIV& ACTION£ BASl!D ON MONTHLV'URIMARY URANIUM RIIULU-
Urina,v Uranf"m
Cbna11111_mia11
IS to JS pB/L
Confirmed to 118 peatu
dwa J5 a,1/L rar 1wv
IJOllseClltM .,,ectmcns,
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uon ot 111Dn than a
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intake
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nil\ll"o,y limit on biftke.
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rio.111 ii MCitiUY.
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._ IIQtOVe Ulaa1wa "oftaon'8ar contl'DII or~
pro1& ... pri,lrll,i u iftvmimauoa U\IUCata.
l. Tak& u,a actlo1:11 dt'•utxwa.
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oth11r: wadcer lri1L IUU:Oed • uri,ta,y ll1Wnfwn COCICeDtrlr
tJo1 of SS ',11/L.
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~ 'plOIBOdaft ,-qldremuUIIJadiQled.
d. Comidet CCHltbwo6 .. JtlCdadoAI Da IIJ&Dhtll
,~p!oycut undl udnuy COl!aClltmb&l ua bolaw U J.AJ/J.
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cihllra •.-sllk-~-ud ... d bv·s:Pdtc&ou .__di c~•d-
. . .
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Date: 03/6/2020 Revision: EFR 11
Page 1 of 17 Book: Radiation Safety Manual, Section 2
2.0 RADIATION MONITORING -AREA
2.1 HIGH VOLUME AIRBORNE AREA AIR SAMPLING
Area air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airborne
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high volume sampler or similar high
volume pump will be used for this purpose. Samples will be analyzed as per standard
gross alpha analysis procedures using a sensitive alpha detector.
2.1.1 Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of 40 1pm or
greater for one hour or longer. A variety of equipment may be used for area air sampling,
however normally the equipment used is an Eberline RAS-1, Scientific Industries Model
H25004, or equivalent. Equipment is calibrated prior to each usage as per Section 3.6 of
this manual.
2.1.2 Frequency/Locations
Area dust monitoring frequency is monthly for the locations shown in Table 2.1.2-1.
Code
BAI
BA2
BA3
BA4
BAS
BA6
BA7
BAS
BA9
BAIO
BAll
BAI2
BAI3
BAI4
BA15
Table 2.1.2-1
Airborne Radiation Sample Locations
Location/Description
Ore Scalehouse
Ore Storage
Sample Plant
SAG Mill Area
Leach Tank Area
CCD Circuit
Solvent Extraction Building/Stripping Section
Solvent Extraction Building/Control Room
Yellowcake Precipitation & West Storage Area
North Yellowcake Dryer Enclosure
South Yellowcake Dryer Enclosure
Yellowcake Drying & Packaging Area
Yellowcake Packaging Enclosure
Product Yard
Bucking Room
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Date: 03/06/2020 Revision: EFR-11
Page 2 of 17 Book: Radiation Safety Manual, Section 2
Code
BA16
BA17
BA18
BA19
BA20
BA21
BA22
BA23
BA24
BA25
BA26
BA27
BA28
BA29
BA30
BA31
BA32
BA33
BA34
BA35
Location/De cription
Lunch Room Area
Change Room
Administrative Building
Warehouse
Maintenance Shop
Boiler
Vanadium Control Room
Vanadium Packaging
Vanadium Filter Belt
Tails
Central Control Room
North Dump Station
Emergency Generator Station
Truck Shop
Women's Locker Room, (as needed)
Eating Area and Offices Above Ware house
Oxidation
AF South Pad
AF North Pad
AF Dump Station
Areas BA-7, 8, and BA-9 are soluble uranium exposure areas. These areas are areas
where the uranium compounds that are produced are soluble in lung fluids and are
comparatively quickly eliminated from the body. All the other areas are insoluble
exposure areas. Insoluble uranium areas are areas where the uranium compounds are not
readily soluble in lung fluids and are retained by the body to a higher degree.
Temperature of drying operations has a significant impact on solubility of uranium
compounds. High drying temperatures produce insoluble uranium compounds. Area
uranium dust monitoring, during production periods, is weekly in the designated
yellowcake production areas. Monitoring increases to weekly in other monitored areas
with the observance of levels exceeding 25% of 10 CFR 20 limits and reverts to monthly
upon a continued observance of levels below 25% of 10 CFR 20 limits as determined by
the RSO. The RSO may also perform any additional samplings at his or her discretion.
The RSO will designate those areas involved in area monitoring during non-production
periods. Non-production period monitoring becomes effective one month following the
cessation of production.
Annually, the licensee shall collect, during mill operations, a set of air samples covering
eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40
liters per minute), in routinely or frequently occupied areas of the mill. These samples
shall be analyzed for gross alpha. In addition, with each change in mill feed material or at
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 03/06/2020 Revision: EFR-11
Page 3 of 17
least annually, the licensee shall analyze the mill feed of production product for U-Nat,
Ra-226 and PB-210 and use the analysis and results to assess the fundamental constituent
composition of air sample particulates.
2.1.3 Sampling Procedures
1. A RAS-1 or similar high volume pump shall be used for area grab sampling. Ensure
the pump has been recently calibrated within the past month.
2. The locations selected for area air samples should be representative of exposures to
employees working in the area.
3. For routine sampling, the sampling period should be for a nummum collection
duration of 60 minutes at a flow of 40 1pm or greater.
4. Insert a clean filter into the filter holder on the sampler. Note start time of pump and
record unusual mill operating conditions if they exist.
A. Stop sample collection and note time. Normally, an automatic timer is
connected to the sampler and a 1 hour sample collection time is used.
6. Remove the filter from the sampler and place in a clean glassine envelope or the
package supplied by the manufacturer for delivery to the Radiation Department.
7. Sample filters will be analyzed for gross alpha using a sensitive alpha detector after a
three to seven day decay period to count only long lived alpha.
8. Count the sample by gross alpha counting techniques and enter the result and
sampling information into the record.
2.1.4 Calculations
Perform calculations as specified in Section 4.0.
2.1.5 Records
Logs of all samples taken are filed in the Radiation Safety Officer's files. Data is utilized
to calculate radiation exposures as specified in Section 4.0.
2.1.6 Quality Assurance
Calibration on each air sampler are made at least monthly to ensure accurate airflow
volumes are being collected. Usage of tweezers and new filter storage containers
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 03/06/2020 Revision: EFR-11
Page 4 of 17
minimizes contamination potential. Field logging of data during sampling and logging of
identifying data on sampled filter containers minimizes sample transposition. Samples
may periodically be submitted for chemical analysis and a comparison of these results to
the radiometric measurements will be made.
Review of data by the RSO and by the ALARA audit committee further assure quality
maintenance.
2.2 RADON PROGENY
2.2.1 Definitions
Working Level:
A. The exposure to l .3E + 05 MEY of alpha energy or the potential alpha energy
in one liter of standard air containing 100 pCi each of RaA (Polonium-218), RaB
(Lead-214), RaC (Bismuth-214), and RaC prime (Polonium-214). (Exposure
level, not a dose rate)
Kusnetz Method: Method of radon progeny measurement and calculation based
upon a 10 liter sample and at least 40 minutes decay time before counting.
2.2.2 Equipment
The equipment utilized consists of the following, or appropriate equivalents:
• Portable personal sampler
• Gelman 25 mm filter holder with end cap, or equivalent
• Gelman Type A/E 25 mm diameter glass fiber filters, or equivalent
• Counter-Scaler-Eberline MS-3 with SPA-1 probe, or equivalent
2.2.3 Frequency/Location
Radon progeny samples are obtained monthly at those locations included for area
particulate uranium monitoring during production periods. Monitoring is increased to
weekly upon observance of levels exceeding 25% of 10 CFR 20 limits. Monitoring is
reduced to monthly upon the continued observance of levels below 25% of 10 CFR 20
limits. During non-production periods, monitoring is done monthly for only those
locations occupied by personnel where exposures may have the potential of exceeding
25% of 10 CFR 20 limits. The RSO shall so designate those areas to be monitored during
non-production periods.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
2.2.4 Procedures
The procedures to be utilized are as follows:
1. Assemble filter trains.
2. Ensure pump batteries are fully charged.
3. Calibrate pump (see Section 3.2).
Date: 03/06/2020 Revision: EFR-11
Page 5 of 17
4. Attached filter trains at sample locations; disconnect end plug.
5. Collect sample in the breathing zone of the employee.
6. Collect sample for five minutes at 4.0 1pm.
7. Log sample site, time started, time stopped, and filter pump number prior to leaving
each site on the field log notebook.
8. Samples are counted between 40 minutes and 90 minutes after collection using
sensitive alpha detector.
9. Check the calibration and function check information to ensure the detector 1s
calibrated and operating.
10. If the calibration check correlates, proceed with sample analysis.
11. Radon progeny samples are normally counted for three minutes, however any sample
count time may be selected for counting.
12. Run background detector count prior to running sampled filters.
13. After counting, calculate working levels.
Equation:
Where:
(CPM-Bkg)
(aeft) (20 liters) (Time Factor)= W.L.
CPM -sample count per minute
Bkg -counter-detector background count per minute
a Efficiency -The efficiency of the counting system (See Section
3.2.3.3)
Time Factor -Values determined from Kusnetz method (See
attached Table 2.2.4-1)
White Mesa Mill -Standard Operating Procedures Date: 03/06/2020 Revision: EFR-11
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 6 of 17
W .L. -Working Levels
TABLE 2.2.4-1
Time Factors
Min. Factor Min. Factor
40 150 71 89
41 148 72 87
42 146 73 85
43 144 74 84
44 142 75 83
45 140 76 82
46 138 77 81
47 136 78 78
48 134 79 76
49 132 80 75
50 130 81 74
51 128 82 73
52 126 83 71
53 124 84 69
54 122 85 68
55 120 86 66
56 118 87 65
57 116 88 63
58 114 89 61
59 112 90 60
60 110
61 108
62 106
63 104
64 102
65 100
66 98
67 96
68 94
69 92
70 90
2.2.5 Exposure Calculations
The personnel exposure calculations are a job-weighted average of those areas and
concentrations that an individual is exposed to. The procedure is:
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 03/06/2020 Revision: EFR-11
Page 7 of 17
1. Determine areas and durations (hrs.) each individual worked during the period (month
and quarter).
2. Determine monitored concentrations (WL) for each area so noted.
3. The multiplication of the hours worked in each area by the area concentration (WL)
noted is added to the result for each area involved in the period.
4. The result is the Working Level Hours exposed (WLH) for the period.
5. The working level hours (WLH) divided by 173 (30 CFR 57.5-40 note); or hours per
month gives the working level months (WLM) exposure. (The limit is 4 working
level months exposure per year.)
6. If calculated per quarter, the working level hours summed for the quarter are divided
by 519 ( 173 X 3) to obtain the working level quarter exposure.
See Section 4.0 for details on how to perform exposure calculations and maintain the
exposure records.
2.2.6 Records
Data records, which are filed in the Radiation Safety files, include:
1. Sample location
2. Date and time of sample
3. Time on and off of sample pump
4. Counts per minute of sample
5. Elapsed time after sampling
6. Background detector count
7. Appropriate Kusnetz time factor
8. Working level
9. Sampler identification
Employee exposure records include:
1. Month monitored
2. Areas and duration worked
3. Employee identification
4. Concentrations (WL) observed
5. Calculated WLMs
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Date: 03/06/2020 Revision: EFR-11
Page 8 of 17 Book: Radiation Safety Manual, Section 2
2.2. 7 Quality Assurance
Calibration checks each month assure proper calibration of the counting equipment.
Documented semi-annual calibrations of the counting equipment using certified alpha
calibration and pulse meter sources ensure proper calibration of the equipment over the
anticipated ranges. The air sampling system has documented calibration prior to each
use, ensuring sampling the appropriate air volumes. Duplicate counts of select data may
be counted to assure instrument precision. Field documentation is maintained for each
sample during monitoring. This methodology provides assurance in data quality.
Review of data by the RSO and the ALARA audit committee further assures quality
maintenance.
2.3 ALPHA SURVEYS
2.3.1 Equipment
Equipment to be utilized in area alpha surveys is shown in Appendix 1. Pre-use function
checks will be performed on all radiation survey equipment as specified in Section
3.1.2.3.2.
2.3.2 Frequency/Locations
Fixed and removable alpha surveys are made at those general locations on the Table
2.3.2-1, "Alpha Area Survey Locations." Surveys are completed weekly during
production periods. During non-production periods, only those areas designated by the
RSO as authorized lunchroom/break areas are monitored. Designated eating areas are
listed in Table 2.3.2-2.
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Benches
Maintenance Lunchroom Tables
CCR Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Date: 03/06/2020 Revision: EFR-11
Page 9 of 17 Book: Radiation Safety Manual, Section 2
2.3.3
2.3.3.1
Procedures
Respirators
Table 2.3.2-2
White Mesa Mill
Designated Eating Area Locations
Maintenance Supervisor Break Room
Main Lunchffraining Room
Administrative Break/Conference Rooms
Administrative Office Desks
Respirators are monitored utilizing a removable alpha smear that is read using alpha
scaler meter such as a Ludlum Model 2200 or other equivalent radiological instruments.
Readings exceeding 100 dpm/ 100 cm2 result in re-cleaning or discarding of the respirator.
Respirator cleaning and monitoring is a function of the Radiation Safety staff assigned to
this duty. The meter's performance is checked prior to each use period.
2.3.3.2 Fixed Alpha Surveys
Alpha surveys for fixed alpha contamination are performed using a variety of alpha
detecting instruments, as listed in Appendix 1. Each instrument is checked using a
calibrated alpha source for proper function and operation prior to use, as described in
Section 3.1.2.3.2.
Adjustments to the surface area being measured must be made to convert from the
particular detector's surface area to the commonly used surface area of 100 square
centimeters. Therefore when converting a measurement to the commonly used unit of
dpm/100cm2, a multiplying area factor must be applied to the measurement. For the
Ludlum instrument with a 43-1 detector of 75 cm2 surface, multiply the value by 1.33 (i.e.
100cm2 divided by 75cm2).
The procedures are:
1. Turn the meter on and check the meter battery condition.
2. Check alpha detector mylar surface for pinholes, etc. Replace if necessary and repeat
calibration.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 03/06/2020 Revision: EFR-11
Page 10 of 17
3. As specified in Section 3.1.2.3.2, perform a function calibration check using
calibrated alpha source.
4. If check is acceptable, proceed with monitoring.
5. At each designated site, monitor designated surfaces, table tops, etc., holding within
14 inch of the surface.
6. Record data, location, cpm/cm2 monitored on data sheet.
7. At the conclusion of the survey, transpose results to the file log, correcting to
dpm/100 cm2, using correction for detector's surface area and cpm/dpm conversion
factor.
2.3.3.3 Removable Alpha Surveys
The Ludlum Model 2200 scaler with 43-17 detector, or a variety of other sensitive alpha
detection instruments such as Model 2929 or equivalent, counts wipe samples collected
during removable alpha surveys. Glass fiber filters, sized to fit the detector sample slot,
are utilized as the wipe medium. A template having a 100 square centimeter surface area
maybe used to standardize the surface area wiped.
The procedure is:
1. Perform function check calibration of the scaler/detector. Ensure that this
measurement is within ± 20% of the value obtained from the calibration laboratory.
2. If so proceed with the survey and counting.
3. Obtain clean filters and clean envelopes for filter storage.
4. At a location to be surveyed, remove the filter from the envelope and wipe the surface
covering approximately 100 cm2• This is easily accomplished by making a "S"
shaped smear for approximately 10 inches using normal swipes (approximately 2.5
cm diameter).
5. Record on envelope the date and location of the sample.
6. Upon returning to counting lab, place an unused filter in the counting unit for at least
1 minute and obtain a background count rate.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 03/06/2020 Revision: EFR-11
Page 11 of 17
7. Repeat procedure for each used filter, extracting filter from envelope, immediately
prior to counting, using tweezers and placing in the detector slot with the wiped
surface facing the detector, and count for at least 1 minute.
8. Convert results from cpm/filter to dpm/filter (100 cm2 wiped) after subtracting the
blank background count.
9. Record on the alpha survey form the following information:
A. Sample location and conditions
B. Sample date
C. Sampler identification
D. Wipe count dpm/100 cm2
10. Discard the filters and envelopes
2.3.4
2.3.4.1
Action Limits
Respirators
Levels greater than 100 dpm/100 cm2 squared require re-cleaning or discarding of a
respirator.
2.3.4.2 Fixed Alpha Surveys
Levels greater than 1,000 dpm/100 cm2 squared require remedial action by management.
ALARA criterion ensures that the RSO takes action where necessary to maintain levels as
low as reasonably achievable.
2.3.4.3 2.3.4.3 Removable Alpha Surveys
Levels greater than 1,000 dpm/100 cm2 squared require remedial action and
decontamination. ALARA criteria ensures that the RSO takes action where necessary to
maintain levels as low as reasonably achievable.
2.3.5 Records
Records of fixed and removable alpha surveys are maintained in the Radiation Safety
office files. Records include:
1. Sample location/conditions
2. Sample date
3. Sampler identification
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
4. Fixed alpha determination -dpm/100 cm2
5. Removable alpha determination -dpm/100 cm2
6. Remedial action taken, where necessary
2.3.6 Quality Assurance
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Page 12 of 17
Calibration function checks of detector performance and visual observation of detector
surfaces prior to each survey ensures counting reliability and consistency. Usage of clean
containers and tweezers minimizes contamination of wipe samples. Field logs of sample
I.D.'s on sample containers minimizes transposition of samples. Data review by the RSO
and by the Audit Committee further assures quality maintenance.
2.4 BETA-GAMMA SURVEYS
2.4.1 Equipment
Beta/Gamma surveying instruments used for beta-gamma surveys are listed in Appendix
1 and the sources used are listed in Appendix 2.
Some instruments read directly in mrem/hour while others read in cpm (with a conversion
to mrem/hour). The model 44-6 detector has a removable beta shield allowing
discrimination between beta and gamma contributions. Each instrument has a
manufactures user's manual which describes the function, use and capability of each
instrument. These manuals must be understood before surveying proceeds. Calibration
of Beta/Gamma and functional checks are performed using calibrated sources
2.4.2 Frequency/Locations
The sites noted on Table 2.4.2-1 are monitored on a monthly basis by of the Radiation
Safety staff during production periods. During non-production periods, only areas
routinely occupied by personnel are monitored as designated by the RSO.
Identification Number
WM-1
WM-2
WM-3
WM-4
WM-5
WM-6
WM-7
Table 2.4.2-1
Beta-gamma Survey Locations
Description of Possible
Source of Area of Exposure
Mill Feed Hopper & Tran sf er Chute
SAG Mill Intake-Feed Chute
Screens-Area Floor Between Screen
Leach Operator's Desk
Leach Tank Vent #3
Leach Tank #3 -Wall
CCD Thickeners
Distance from Source in cm
1
1
1
1
1
1
I
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Identification Number
WM-8
WM-9
WM-10
WM-11
WM-12
WM-13
WM-14
WM-15
WM-16
WM-17
WM-18
WM-19
WM-20
WM-21
WM-22
WM-23
WM-24
WM-25
WM-26
WM-27
WM-28
WM-29
WM-30
WM-31
WM-32
WM-33
WM-34
WM-35
WM-36
WM-37
2.4.3 Procedures
Description of Possible
Source of Area of Expo ure
Pumphouse Tailings Discharge
Oxidant Makeup Room-Sump Pump
Shift Foreman's Office-Work Desk
SX Operator's Area
Precipitation Tanks #1 Tank; Wall
Precipitation Section "Lab Bench"
Precipitation Vent
Yellowcake Thickener # 1; Wall
Centrifuge Discharge-Chute Wall
Yellowcake Thickener #2; Wall
Yellowcake Packaging Room
Yellowcake Dryer
Yellowcake Dust Collector
SX Uranium Mixer #1 Extractor
SX Uranium Mixer #1 Stripping
SX Vanadium Mixer #1 Stripping
Vanadium Dryer
Mill Laboratory Fume Hood
Chemical Laboratory Work Area
Metallurgical Laboratory Work Area
Lunchroom Eating Area
Lunchroom Wash Area
Maintenance Shop-Work Area
Maintenance Shop -Rubber Coating
Tailings Impoundment Discharge
Tailings Impoundment Dike 1
Tailings Impoundment Dike 2
Tailings Impoundment Dike 3
Scalehouse
Tailings Impoundment Dike 4
The monitoring procedures are:
1. Check meter battery condition.
2. Check detector using a check source.
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Page 13 of 17
Distance from Source in cm
I
1
1
1
]
I
l
I
1
1
I
1
1
I
I
I
l
1
I
I
I
L
1
L
3. If the calibration function check indicates that the instrument is operating within
calibration specifications, proceed with monitoring.
4. Survey each designated location on Table 2.4.2-1 and record in the field log:
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
A. Site location/condition
B. Date
C. Instrument used
D. Sampler's initials
E. Meter reading (beta + gamma)
F. Meter reading (gamma)
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Page 14 of 17
5. Upon returning to the office, record the mr/hr reading into a permanent file which is
maintained for beta-gamma exposure evaluation.
2.4.4 Action Levels
The ALARA concept is utilized in action levels. Responses include operative cleaning of
the area or isolation of the source. The Radiation Safety Department will ensure levels
ALARA.
2.4.5 Records
Records maintained in the Radiation Safety office files include:
1. Date monitored
2. Site location/condition
3. Instrument used
4. Sampler's initials
5. Beta/Gamma level, mr/hr
6. Remedial action taken, if necessary
2.4.6 Quality Assurance
Quality of data is maintained with routine calibration and individual function checks of
meter performance. Personnel utilizing equipment are trained in its usage. Records of
the operational checks and calibrations are maintained in the files. The RSO routinely
reviews the data and the ALARA audit committee periodically analyzes the performance
of the management of the monitoring and administrative programs.
2.5 EXTERNAL GAMMA MONITORING
External gamma area monitoring is conducted at various locations around the Mill site in
order to provide Radiation Safety Staff with area-specific gamma measurements. The
procedures applicable to such monitoring are set out in Section 4.3 of the Mill's
Environmental Protection Manual.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
2.6 EQUIPMENT RELEASE SURVEYS
2.6.1 Policy
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Page 15 of 17
Materials leaving a Restricted Area going to unrestricted areas for usage must meet
requirements of NRC document "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use or Termination of License for
Byproduct, Source, or Special Nuclear Material" (dated May 1987).
All material originating within the restricted area will be considered contaminated until
checked by the Radiation Safety Department. All managers who desire to ship or release
material from the facility will inform the RSO of their desires. The RSO has the authority
to deny release of materials exceeding the NRC document "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" (dated May
1987). No equipment or materials will be released without documented release by the
RSO or his designee.
2.6.2 Limits
The release limits for unrestricted use of equipment and materials is contained in the
NRC guidance listed above in Section 2.6.1 and are summarized as follows:
Limits for Alpha emissions for U-Nat and its daughter products are:
Average
Maximum
Removable
5,000 dpm/100 cm2
15,000 dpm/100 cm2
1,000 dpm/100 cm2
Limits for Beta-gamma emissions (measured at a distance of one centimeter) for
Beta/Gamma emitting radioisotopes are:
Average
Maximum
2.6.3 Equipment
0.2 mr/hr or 5,000 dpm/100 cm2
1.0 mr/hr or 15,000 dpm/100 cm2
Radiological survey instruments are listed in Appendix 1.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
2.6.4 Procedures
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Page 16 of 17
Upon notification that materials are requested for release, the Radiation Safety
Department hall inspect and survey the material. Surveys include fixed and removable
alpha surveys and beta-gamma surveys. An equipment inspection and release form is to
be prepared and signed by the RSO or his designee. Any material released from the mill
should be accompanied with the appropriate release form. If contamination exceeds
levels found in NRC document "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use or Termination of Licenses For
Byproduct, Source, or Special Nuclear Material", (dated May 1987) then decontamination
must proceed at the direction of the RSO. If the material cannot be decontaminated, then
it will not be released.
2.6.5 Records
Documented records for each released item are filed in the Radiation Safety Department
files.
2.6.6 Quality Assurance
The RSO and the ALARA Audit Committee periodically review the policy and
documented release forms to ensure policy and regulatory compliance.
2. 7 PRODUCT SHIPMENT SURVEYS
2.7.1 Policy
The Radiation Safety Department, prior to shipment release, will survey product
shipments from the facility. Product shipments include uranium concentrate and solid
vanadium products.
The Radiation Safety Department is to be notified in advance of each shipment. The
shipment will not be released prior to the Radiation Safety Department's authorization.
2. 7.2 Equipment
Equipment used for product shipment surveys is the same as equipment used for material
release surveys and is listed in Appendices 1 and 2.
2.7.3 Frequency
All barrels are fixed alpha and gamma scanned prior to shipment. A minimum of 25
percent of the barrels consigned are also wipe tested.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
2. 7 .4 Solid Vanadium Shipments
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Page 17 of 17
The procedure to be followed for solid vanadium shipments were detailed in the
Radiation Safety Manual in Section 2.7.4. These procedures have been replaced with
procedures No.: PBL-15 Book 10, "Release and Shipping of Vanadium Blackflake".
2.7.5 Uranium Concentrate Shipments
The procedures for exclusive use uranium concentrate shipments are:
1. Inspect each product barrel that makes up the consigned shipment for leaks, holes in
the barrels, cleanliness, etc.
2. Barrels requiring repair shall be repaired prior to the radiation survey.
3. Perform a total and removable alpha survey of each barrel, using the procedures and
equipment specified in Section 6.0. The release limits for exclusive use shipments is
outlined in 49 CFR Part 173.441-.
2. 7 .6 Records
The attached form serves as a record of shipment and is retained in the Radiation Safety
files.
2. 7. 7 Quality Assurance
Periodic reviews of transport forms and policies by the RSO and the ALARA Audit
Committee ensures quality assurance for product shipment surveys.
Monthly Area Airbt 1! Sampling Field Sheet
Energy Fuels Resources \OSA) Inc. White Mesa Mill Month: _______ _
-Fiber Locatiaa
m
Air Parumlam calmJatirm
Count
Dmll""mm Fillerm
-
RuTbac
Date IMia.\
•y Sheet
I:nstnm.:nt
Saial.No. Efficiency
(NetCPM)
(2.22 E6)(V)(Eftd)
F'lowRate
II.PM\
Total
Counrll'ime
ll.D or MDA= 2.71+3.29 ,J Bkg...-rs(l+Tsflb)
(fs)(Bft c1)(Ef[ f)(FF)(V)(2.22B6)
Paamt ofDAC= Adual Concmdratian
DAC
Volume
{ml,)
-
CPM
Sampled By: _________ _
S.mDled •• eom.e.ts
Reviewed by: _________ _
Bkg. Net:Cauut LLD Com:cmzration Pen:mtof
Coum:/'l"'nne CTot.·B1'2. l (uCi/mL} uCi/mL
'T
Ts= Time of Sample
Tb-Backgn,und Count Time inMinok:s
Eff: d= Deblctor ef6cimey in Counts per ~OD
E1f. f = Filter Efliamlcy
V= Total Volume in miI1ilitres or Cubic Cealiwetms
.2.22.E6-Factor to convat DPM to uCi
N~ CPM ... Total Counts-Background Count
DAC
· Sample
ComdedBv
-Breathing Zonr mpling Field Sheet
Enerv Fuels Resources \ USA) Inc. White Mesa Mill Month:. _______ _ Sampled~----------
. .Filter Location Date Raa'l'lllle 11owRla
JD (M"m.\ 11..PM\
Air PartlCUWe CelculaliOm y Sbeet
Count IDstrummt Total
Date/Time FiltetJD Serial No. --· CouotfJ'ime
Conccmndicm C 1,1Ci1ec)• CNetCPM>
(U2 E6)(V)(Ef[d)
Ill) or MDA= 2. 71+3:29 ,.,J Bkg.*Ts(l+Ts/l'b)
(Ts)(E1f. 4)(Bft•~
Pcrceat ofDAC= Actual Com:adrldion
DAC
.
Vol11111e
(mL)
CPM
--.
BY Comm.ats
~by:
Bkg. . NctCount IlD Ccmcemration Percmtof
Countl'l'ime (Tot.-Bb. l (UCi/mL) uCi/mL
. .
Time of Sample
Tr Badtground Coum TDJJe in.Minutes
Th= DGl2ctor' effici.mcy in Counts per Disintegmtion
Efl: (P Filra' Efm:eim.y·
Etf. f-Tocd Volume inmillilitra of Cubic cc:utbnelen
V-Factor,1D conwrt DPM to uCi
2..22E6 = Talal CPIDlls • Background Count
NetCPM=
DAC
Sample
CounbsdBv
EMPLOYEE NAME:
WEEK BEGINNING:
AHkA
BA 1 SCALEHOOSE
BA2 ORE STORAGE
BA 7 SAG lilU..
BA8LEACH
BA9 CCO CIRCUIT
BA 1DSXBU1LD1NG
BA 12 VC PRECIP
BA 12A N. YC DRYER ENC
BA 128 S. YC DRYER ENC
BA 13 YC PACKAGING
BA 13A YC PKG ENCL.
BA 15 BUCKING ROOM
BA 16 WNCH ROOM
BA 17 CHANGE ROOM
BA 18 ADMIN. BLDG
BA 19 WAREHOUSE
BA 20 MA1NT SHOP
BA21 BOILER
BA 22 VAN. PANEL
BA 22A VAN. DRYER
BA23 VAN. BELT SCRN
8A24 TAILINGS
BA25.CONTROL ROOM
BA 28 MILL OFFICE
BA27 OPER. LUNCH RM
BA28 DUMP STATION
BA 29 FILTER PRESS
BA 301RUCK SHOP
EMPLOYEE SIGNATURE:
WEEK ENDING:
s1ii MON lUE WED lHIJ
11U 1ff ,u 1f.i 114
.
EXPOSURE TIME SHEET
FRJ
1r.5
COMPANY ID:
~--~-~ ~ ~ ~ ~ ~ ~ ™
w 1n m w ~ ~ ~ ~
..
Total: Talal:
White Mesa Mill Weekly Alpha Survey
Date: --------------
Technician: --------------
Alpha Survey Instruments
Fixed Removable
Model#: ________ _ Model#: _______ _
Serial#; Serial#: ------------------
Ca Ii brat ion: --------Calibration: ---------
E ff i c i en c_y ___ : --------Efflcfen~cy.__: _______ _
Background: _______ _ Background: ______ _
MDA: ----------MDA: ----------
Notes:
All fixed readings are in dpm/100 cm 2
Tort= Total or Fixed Alpha Reading in dpm/100 cmZ
R or r = Removable Alpha Reading per swipe or filter· (approximately 100 cm2)
·Rso Reviewed:
RSO Comments! ----------
EMPLOYEE SPOT ALPHA CONTAMINATION SURVEY
DATE NAME BOOTS CLOTHES
.
All units In dpm/100 cm2
Alpha Instrument Information:
Instrument Model: _____________ _
Instrument SN: ______________ _
ThaSourceSN: _____________ _
DPM: CPM: _______ _
Efficiency: Efficiency Factor: ___ _
Comments:
HANDS COMMENTS
Central Control Room
Dest f "' -
D a a • :I •·
k
I Table I
EJ
survey-Alpha n 0 :::, Date ... a
"g Inst. m ::::,
!!.
Cal Date
SN
Tech
All units In dpm/100 cm2 I Table I
Comments:
Survey-
Date_
Inst._
cat Date
SN __
Tech_
All units
§
Alpha
in dpm/100 cm2
Safety Safety Office
Office
RSO Office
comments:
Administration Building
Chief Chemist Mass Spec Balance
Office Room Room
Product Room Mau Spec -~ Room Dlliae
Electrical I Olcmkal~ I Roam
Mi11Supt. Bioassay Room Training Room
Office
Respirator Sample Storage
Room Room
Copy Room
Vault
I ller:eplionist Alu I
Envl!'Clnrnen Radiation Accounting WMI
lalOffloR Olllce Office I W.lti,,.Alu I Office
Bucking
Room ,Mm~I
I.Jlbamory I
Metallurgist
Office
Min's"'"*-"
Clmet
Wam~n"s--..
E]
Office Conference Roam Chief
Mmlupt
Oflioe
Erci,,..,,S Office MiU Manager's Office
Offiae
Scale house
Restroom Table
Table
Desk
Survey-Alpha
Date
Inst.
cal Date
SN
Tech
All units in dprn/100 cm2
Comments:
Change/Lunch Room
-
j Table I I
en's~Room M
I
J
I Shower
J -
Tl~ l
~
I [r•
~ I
I Survey-Alpha Laundry
Room -
Date_ D Inst. -
I cal Date __
I SN_ --
Women's Locker Room Tedi -
2
Lunch Room l All units in dpm/lOO cm
I .,--
-
Comments:
Maintenance and Warehouse Areas
Rubbering Room ,,
!I. Malntnanca
::I .. Fcnmln's
:a 0 ~
i warehouse
Supply .Office
EJect.
Fon!man's
Office
Maiatenan(2
Supt. Office
Warehaus
eOffice
j ,
D
Survey-Alpha
: 2 ! Date a a .. ~ :I
a.-Inst. -Instrument -Shop cal Date
Carpenter Shop Electrical Shop
QIII-. SN --Tech
All units in dpm/100 cm2
Tool Room
.....
mi.
Comments:
SHIPMENT SURVEY
CONTRACT NO.
TRACTOR NO.
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
FACTOR
MDA
LOT NO.
i;"!l'QY Fuel& Aeloul08I (USA) Inc.
While M ... MIii
8425 S. Highway 191, PO Box 809
Blanclng, UT 84511
USA
Tel: "'35-878-2221
Fax: [phone]
TRUCK CARRIER
TRAILER NO.
ALPHA SURVEY INSTRUMENTS
TOTAL REMOVABLE
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
FACTOR
ALLOWABLE LIMITS AS OUTLINE IN 49 CFR PART 173.443. TABLE 9
SURFACE AREA OF PROBE
100cm2
1.0
X ~-E_F_F_IC_IE_N_C_Y_O_F_IN_S_T_R_U_M_EN_T_(_%~)~=FACTOR
100
(EFFICIENCY/1 OOcm2)
Factor X counts/minute • Disintegrations/mtnute/100cm2
GAMMA SURVEY (49 CFR 173.441 (b) (1))
INSTRUMENT NO. MEASURED IN MILUREMS/ HOUR
SERIAL NO.
CALIBRATION (MR/HR)
TRAILER SURFACE 200 MR/HR ALLOWABLE
SIX FEET DISTANCE 10 MR/HA ALLOWABLE
DRIVERS SEAT 2 MRt'HR ALLOWABLE
SLEEPER 2 MR/HR ALLOWABLE
ALL DRUMS WERE INSPECTED PRIOR TO LOADING. ALL DRUMS WERE TIGHTLY
SEALED. NONE LEAKED AND THERE WAS NO LOOSE MATERIAL IN THE VEHICLE.
INSPECTOR SIGNATURE
Energy Fuels Resources (USA) Inc.
DRUM CONTAMINATION SURVEY Page2
Type of Shipment: ______ _ Lot#: ___ _ Date: __ _
Total Alpha Removable Alpha Ptv
Drum dpm/100cm2 dpm/100cm2 Average
# Too Sides Bottom Top Sides Bottom mrem/hr
1
2
3
4
5
6
7
8
9
10
11
12
13
14'
15
16
17
18
19
20
21
22
23
24
25
• If total Alpha Is greater than or equal to 1.000 dpm/100 cm2• a removable smear is required.
Alpha Meter Removable Alpha Beta/Gamma Meter
Model#: _____ _ Model#: ____ _ Model#: ____ _
SN#: -------SN#: _____ _ SN#: _____ _
Cal. Date:------Cal. Date:-----~. l)ate: ____ _
Efflcle.ncy: ____ _ Efficiency: ____ _ Check Date: ----Eff. Check: V / N Eff. Check: Y / N Cs 137SN#2
Reading: ____ _
Bkg: _____ _
Page3
Total Alpha Removable Alpha Plv
Drum dpm/100cm2 dpm/100cm2 Average
# Too Sides Bottom Top Sides Bottom mrem/hr
26
27
28
29
-
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
Comments:
I
(
--:-.-
oumBUNBS FOR DECONTAMINATION OP FACILITIES AND BQUJPMBNT
PRIOR TO REL.BASE FOR UNRBSTRICTBD USB
OR TBRMINATION OF UCBNSBS FOR BYPRODUCT, SOURCB,
· OR SPP.CIAL NUCLEAR MATBRIAL
...
U.S. Nuclear Regulatory Commission
Division of lZucl Cycl~, Medical, A~c,
and Commerclal Use Safety
Wuhingtoa, DC 20SSS .
April 1993 .
. ..
.p
I
I
·-
The instruction, in this auidc:, in coajuiacdon widl Tablo 1, spedfy the
ndionuclides and Jadiadon exposure are limits which lhou1d be ued in
decon--don and survey ·of IUl'face.1 or premises 111d cquipmc:nt prior to
abandonment or release for unrestricted use. The llmita in 'hble 1 do not
apply to ~ses, equipment, or scrap containing inducccl ndioactivity for
which the radiological conaideradons pertinent to their use may be
dfffeJent. The release of such fidlitics or Items from recutatory control is
cons1dered on a cue-by-c:aso basis. . ...
1. ne .licensee shall mab a reasonable effort to eliminate reaidual
. contaminadon.
2. Radioactivity on equipment or aurfacea shall not be covered by paint,
pladn1, or other coveria1 material unleo contaminadon levels, as
determined by a ~ey and documented, are below the llmlta specffled 1n
Table 1 prior to tho application of the covwa. A RISODlblo effort
must be mado to mlnhnu.e tho contamfoadon pdor ta u._ of my covering.
3. Tho radioactivity on tbe intcdor smfaces of plpa, dn.iD U.~ or
duciwodc shall. be deiermined by making meuuramaats at all ~ and
other appropriate accas p,in11, provided that eonlamfDatlon at tbele .
locations fl lib1y to be npmentative of eolltamfnatloa on the hlfllrior
of the pipea, dram line.a, or ductwork. SurfiM:el of preml11e1, equipmmt,
or smp which are 1ibly to be conlaminaml but are of sucll llze,
comtruction, or locadol1 u to mab the surface ina~alble for purpoaea
of measurement ~ be presumed to be contaminated in excess of the Umlts.
4. Upon request, the Commission may authorize a llrmsce to reUnquilb.
possemoa or contn;,J of JnlDlses, equipment, 01 ICJBP llavin1 surfaca
conflrninat.ed with matedala la eaceu of the HmltJ ,pecified. 'I1lls may
fnclude, but would not ~ limited to, special ciroumslancea such u ming
of bwkllnp, transfer of premiJel to another orpaiadon continuing work
with radlbaedve mabmls, or convmloa of fadlidm to • laai-term
1torap or standby llabla. Such iequem IDUlt:
,a. ~ delliled, ~ lnformadoa clescribflll the )JIUlile,,
equfpmeat or scrap, radioactive cootarnfalats. IDd the ll8fum, ex.tail
and cfearee. of realduaf lll1'fam contamfNdoa.
b. rn,vide a delliled -1th and safety analysis which.~ that the
teSidua1 llllO'IIDtl Of materfab OD sudice 8111111 fopdler widl other
comldentlou IUCh u prbJpCICtlve me of tbe preadaes, equipment,
or ICl'lp, am anJUcely to result In an unn:uoaable mk flO the -1th
and aafety of the public. 1
J
:.
2
S. Prior to release of premises for unrestricted use, the licensee shall
make a comprehensive radiation survey wbtch establishes that contamination is
within th.e limits specified 1n Table I. A copy of lhc ,urv&y n,port shall be
filed with tho Division or Fuel Cycle Safety and Safeguards, U.S. Nucle.ar
Regulatory Commission, Washington, D.C. 20SSS, and also the Administrator
of the NRC Regional Office having jurisdiction. The reports lhouJd be filed at
least 30 days prior to the planned date of abandonment. The 1urvoy report shall:
a. Identify the premises,
b. Shaw dw reasonable effort bu been mado to eliminate reildual
contamination. ·
c. Delcribe the scope of the survey and general procedUrel fallowed.
d. State the findings of the survey in units specified In the
instructlons.
Followin& review of the report, the NRC will consida' viii.ting ~
facilltles to confum the survey.
I~
/
.. . .. ... . ..
-·----,..,, ... .. , * .. '
White Mesa Mill -Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
3.0 EQUIPMENT/CALIBRATION
Date: 12/19 Revision: EFR 11
Page I of 4
All radiation detection instruments used at the Mill are sent to a qualified independent
laboratory for calibration yearly or according to manufactures requirements.
3.1.1 Function Checks
Calibration function checks are required prior to use of radiation detection instruments
used at the Mill for the purpose of verifying that the instruments are operating at the same
efficiency as when they were calibrated by the calibration laboratory (i.e., within ±20% ).
See section 3.1.3.1 for frequency. Function checks are also used for verifying
repeatability, reliability, and comparability of an instrument's measurements from one
period to another. By performing function checks for extended time periods, or on a
larger sample size, these goals are met.
Establishing Operating Range.
Prior to using the newly calibrated instrument, an operating range determination must be
established that will be used for the pre-use function tests for the instrument.
1.:. Place alpha check source either in the counter if it is a drawer counter or on the
probe.
2. Count for at least one minute.
3. Record the counts.
4. Repeat steps 2 and 3 until 10 data points are acquired.
5. Place source back into its storage case.
6. Complete necessary calculations to obtain the operating range for the system.
Enter this range in the function check log.
7. This range becomes the operating range for the function test that is to run prior to
each use of the machine.
Prior to use daily a comparison of a reading of the check source and the operating range
will be done and recorded on the Instrument Function Check Form.
A number of radiation detection instruments are used at the Mill. An Instrument Users
Manual for each instrument is maintained in the calibration files, together with
calibration documentation. The Users Manuals are to be considered the primary
reference for operating a particular instrument. This Standard Operating Procedure
(SOP) is not intended to replace the Users Manual, but rather to supplement the Manual
by providing steps to be performed for function checks. Before operating an instrument,
personnel should read the Users Manual and become familiar with the instrument's
operation, capabilities, and special features. Personnel will also receive on the job
training on each instrument.
White Mesa Mill -Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
3.1.2 Alpha Monitors
Date: 12/19 Revision: EFR 11
Page 2 of4
Alpha particles travel very short distances in the air due to their high ionization ability -
typically ':4 to 1/2 inch. Due to this limitation, alpha monitoring must be done at a distance
of 1A inch or less between the detector face and the source. Alpha monitoring, to be
consistent, requires ensuring a consistent distance be utilized between the detector face
and the source. Alpha detectors read out in counts per minute (cpm). A correlation
relationship, known as the efficiency factor, between the meter response and the actual
disintegration rate of the source is used to determine actual calibration of the meter.
Radioactivity is measured in curies (Ci), which, by definition, is 3.7 x 10 10 disintegrations
per second (dps), or 2.2 X 1012 disintegrations per minute (dpm). Another measurement
unit is the Becquerel, or one dps. Alpha radiation is usually monitored as dpm, per
surface area measured.
Radiation survey equipment used at the Mill for alpha surveys are listed in Appendices 1
and 2.
3.1.2.1 Calibration and Function Check Frequency
The frequency of calibration is specified in individual instrument user manuals and
manufacturer's specifications.
During production periods, the following frequencies are observed for calibration and
function checks of radiation detection instruments:
Calibration Function
~ Freguenc~ Checks
1. Employee scans Yearly 5 days/week
2. Radon progeny Yearly Daily or each use
3. Respirator checks Yearly Daily or each use
4. Area fixed scans Yearly Daily or each use
5. Area wipe scans Yearly Daily or each use
During non-production periods, the following frequencies are observed:
Calibration Function
~ Freguenc~ Checks
1. Employee scans Yearly bi-monthly
2. Radon progeny Yearly Daily or each use
3. Respirator checks Yearly Daily or each use
4. Area fixed scans Yearly Daily or each use
5. Area wipe scans Yearly Daily or each use
White Mesa Mill -Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
Date: 12/19 Revision: EFR 11
Page 3 of 4
3.1.2.2 Function Check Procedures -Alpha Counters and Scaler Instruments
Follow the steps outlined in 3.1
Note: 1 curie= 2.22 E + 12 dpm
1 microcurie = 2.22 E + 6 dpm
1 picocurie = 2.22 dpm
3.1.3 Beta-gamma Monitors
Equipment utilized for beta-gamma monitoring is listed in Appendices 1 and 2.
3.1.3.1 Function Check Procedure
1. Follow the steps outlined in 3 .1.
3.1.3.2 Calibration
All beta-gamma survey instruments are sent out yearly for calibration. Additional
calibration, if necessary, may be performed on site using techniques described in Reg.
Guide 8.30, Appendix. C -Beta Correction Factor for Survey Instruments for onsite
verification performed by a qualified calibration laboratory using the indicated source as
listed in Appendix 2.
3.1.4 Gamma Monitors
Instruments for gamma measurements are listed in Appendix 1.
3.1.4.1 Calibration
Independent calibration service laboratories perform calibration yearly. Meters are
calibrated to Cs-137 or other radioisotopes as suggested by the calibration laboratory or
manufacturer. Most calibration service laboratories calibrate Beta/Gamma instruments
electronically in accordance with their standard calibration procedures.
3.2 PERSONNEL AIR SAMPLERS
The calibration procedure for personnel air samplers involves electronic or mass flow
determinations. The high-volume pumps, 40 1pm flow, are sent out annually for
calibration by third party. Prior to use flow rate is adjusted directly on the pump.
Whit~ Mesa Mil I ·~ Standard Oper3ting Procedures
S0P-PBL-RP-<l
Book: Radiation Protection Manual, Section 3
3.2.1 Electronic Calibration Method
D~ter 12/19 Re\lision: BFR l J
Page4of 4
The electronic primary gas flow calibration is the primary calibration method and does
not r~uire corrections to or from standards conditions for temperature and pressure.
Personal air samplers are calibrated for the flow rate for the sampling being performed
typically 2 -4 liters per minute.
The equipment utilized is as. follows:
I. UJtraFlo Primary Gas Flow Calibrator, or equivalent
2. Tubing
3. Small screwdrive.r
4. Sample pump
The procedure proceeds as follows:
l. Remove the two nipples Qn the back of the UltraFlo Primary O~s Flow Calibr~tor:.
2. Attach the connection tubing from the top nipple to the sample pump.
3. Turn calibrator on.
4. Tum sample pump on.
5. Write down tbe digital reading from the calibrator device.
6. Repeat steps 4 and 5 three times.
7. Take an average of the three readings.
8. If the sample pump requires adjustrnent, take the screwdriver .and adjust the set
screw on the face. of the sample pump and then repeat steps 4 through 8.
9. After the sample pump b calibrated, document the calibration on the Breathing
Zone/Radon in the Radiation department
1 O. Replace nipple caps on the back of the calibrator.
3.3 AREA AIR SAMPLERS
The function check procedure for arei air samplers involves checldng the flow rate
directly on the pump prior to use.
3.3.1 Electronic Calibration
Refer.to Section 3 .. 2.1 to pedol'n\ this method.
Technician:
Instrument S/N:
Model:
Location:
Source S/N:
WHITE MESA MILL
Calibration Worksheet
Date:
ProbeS/N:
Model:
Isotope:
Activity:
Minimum of one minute per readlns,
Observation
1
2
3
4
5
6
7
8
9
10
AVGCPM
Bacqround:
Efficency:
Operating Range set at+/-20%:
High:
Low:
•
R di (CPM) ea ng
#DIV/01
fDN/01
#DIV/01
IDiy/Qi
#DIV/01
Model No.:
Probe:
Calibration Due Date:
Date Tech.
WHITE MESA MILL
Instrument Function Check Form
Serial No.: Source:
Serial No.: Serial No.:
Operating OK
Reading Range Y/N Comments
:,: ... ..
(
.. .
, . ., '
,"'1 •
Figure I -Apparatus for bubble method of pump calibration
Double filter holder
Flow indicator
ump to be calibrated
(
t
1 (
(
WHITE MESA NILL
Area Ate sampler caJtbrat1an Record
Method: Ket Gas Met•c •
Mont~ l Oite: Sampler No. ____ _
8aroaetrlc Pressure (Jnchts Df Mercury) Ftlter Type: __________ ___
Air Temperature: Dry Bulb 0f' Meter Air Temp, Dry Bu1b_°F
Wet Bulb 0r Vet Bulb_ °F
HumtditY.---------------Calibrated b1, _________________ __
Cale.
Mater
VolUIII Estimate Tt•a EJPK (s)nm) (sac.)
static Pressure
UZQ
Act. ,,1.
at Sat Vet Bulb •Le
Cale. Std
Yolumt slpm Ft
caJcuJattans;
Egutr,Jeota:
Vtth wet-gas meter, the actual met1r volUIIII ts at JODI h111tdtty.
A correction back to actual humtdt~ n11d1 to•• dona t, get actual air d1n1tty and volu1111 s1111P1ed.
1• H20 • 0.01,s'Hgs 28.317 ljters • l cubtc fDOt Std. Atr • 701F, 21.tz•Hg I.P. • 0.075 lbs/ft danstt,. ·
...... '
ltror...r1UN
.:tion 111
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• 11u.cau,1u.l .• H!\\ tOAC
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. -I 1. • f of nust Cnnr.,ntratlon
fn r.u Stre~:1s
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..
VAPOR PRESSURES Or W>.tTER . In lnc!.11 of Marcu'f
3.W
PAGIJJ OF UI
o I
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-5-
I o
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 08/20 Revision: EFR 3
Page 1 of 13
4.
4.1
EXPOSURE CALCULATIONS AND RECORD MAINTENANCE
PERSONNEL EXPOSURE CALCULATIONS
4.1.1 DACs for Conventional Ores
4.1.1.1 Solubility Classes
The solubility class, chemical form and abundance of conventional ores at the Mill, and
the resulting DACs to be used are as set out in the following table:
Table 4.1.1.1-1
Solubility Class, Chemical Form And Abundance of Conventional Ores
Location DAC Unat Th-230 Ra-226 Pb-210
Ore-Grind
6.00E-11 DAC is specified in 10 CFR Part 20
Leach 2.8E-10 % Ore, % Ore, % Ore, % Ore,
% Precipitation % Precipitation % Precipitation % Precipitation
CCD l.2E-ll Class D ClassW 1 Class W 1 Class D 1
Sulfate Sulfate Sulfate Sulfate
25 % 25 % 25% 25 %
sx l.2E-11 Class D Class W 1 Class W 1 Class D 1
Sulfate Sulfate Sulfate Sulfate
25% 25% 25 % 25%
Precipitation 5.00E-10 Class D 2
Diuranate NA NA NA
100%
Yellowcake 2.20E-11 Class Y: 90 %
Packaging and Class W: 10
%
Oxide NA NA NA
100%
Tailings l.70E-11 Class Y Class Y 2 Class W 1 Class W 1
Oxide Oxide Oxide Oxide
4% 32% 32% 32%
1 10 CFR Part 20, Appendix B
2 NUREG/CR-0530, PNL-2870, D.R. Kalkwarf, 1979, "Solubility Classifications of Airborne Products from Uranium Ores
and Tailings Piles"
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 08/20 Revision: EFR 3
Page 2 of 14
4.1.1.2 Application of Conventional Ore DA Cs to Workplace Locations
The Conventional Ore DACs will be applied as follows to the various locations in the
Mill site:
Table 4.1.1.2-1
Application of Conventional Ore DA Cs to Workplace Locations
Type ofDAC DAC (µCi/ml) Individual Location
Ore/Grind 6.00E-11 Ore Scalehouse
Ore Storage
Maintenance Shop
Warehouse
Lunch Room
Change Room
Administration Bldg
Ore/Grind 6.00E-11 Dump Station
Ore/Grind 6.00E-11 SAG Mill
SAG Mill Control
Shifter's Office
Operations Lunch Rm
Filter Press
Leach 2.80E-I0 Leach Tank Area
CCD l.20E-l l CCD Circuit Thickeners
sx l.20E-l l SX Building South
Boiler
Ore/Grind 6.00E-11 Control Room
Yellowcake Precipitation 5.00E-10 YC Precipitation &Wet
Storage
Yellowcake Packaging 2.20E-1 l North YC Dryer Enc
South YC Dryer Enc
YC Pkg Enclosure
YC Drying & Packaging
Area
Packaged YC Staging
Area
Tailings l.70E-ll Truck Shop
Tailings
Yellowcake Precipitation 5.00E-10 Vanadium Circuit
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 08/20 Revision: EFR 3
Page 3 of 14
4.1.2 DACs for Alternate Feed Materials and Other Ores
In determining the applicable DACs for any other ore that the RSO may determine
requires one or more stricter DACs, or for any alternate feed materials, the following
procedures will be followed:
a) Ore/Grind DAC
If the generator of the alternate feed material or other ore is regulated by the NRC
or an Agreement State under a source material or 1 le.(2) byproduct material
license and such regulatory authority has approved a DAC in connection with
handling the material in the same form as it will be received at the Mill, then that
DAC may be used as the Ore/Grind DAC. If such a DAC has not been so
approved, then a DAC will be calculated based on the mixture rule set out in
Section 4.1.3.3 below if the solubilities and relative activities of radionuclides in
the mixture are known or can be determined. If not known or determined, the
mixture will be assumed to be comprised entirely of the most restrictive
radionuclide and solubility class, until the relative activities and solubilities of the
radionuclides in the mixture become known or determined.
b) Leach
The Leach DAC will be a DAC equal to one half of the Ore/Grind DAC and one
half of the Yellowcake Precipitation DAC.
c) CCD
The CCD DAC will be calculated based on the mixture rule set out in Section
4.1.3.3 below if the solubilities and relative activities of radionuclides in the
mixture are known or can be determined. If not known or determined, the mixture
will be assumed to be comprised entirely of the most restrictive radionuclide and
solubility class, until the relative activities and solubilities of the radionuclides in
the mixture become known or determined, provided that solubility class of
uranium can be assumed to be Class D Sulfate.
d) sx
The SX DAC will be the same as the CCD DAC.
e) Yellowcake Precipitation
The Yellowcake precipitation DAC will be the same as for conventional ores, that
is 5.00E-10.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Date: 08/20 Revision: EFR 3
Page 4 of 14 Book: Radiation Protection Manual, Section 4
f) Yellowcake Packaging
The yellowcake packaging DAC will be the same as for conventional ores, that is
2.20E-1 l.
g) Tailings
The tailings DAC will be the same as for conventional ores, that is 1.70£-11,
unless it is expected that the addition of tailings from the alternate feed material or
other ore will significantly impact the radiological make-up of the exposed
tailings, in which case the mixture rule set out in sections 4.1.3.2 (where the
radionuclide with the most restrictive DAC is assumed to comprise 100% of the
tailings) and 4.1.3.3, as applicable will be applied.
Once calculated, the foregoing DACs will be applied to the areas set out in Table 4.1.1.2-
2 above.
DACs will be calculated in accordance with the foregoing procedure prior to receipt or
handling of the alternate feed materials or other ore. If additional characterization
information becomes available at a later date, the DACs may be adjusted to reflect such
additional characterization information.
4.1.3 DACs for Mixtures
Both uranium ore and uranium mill tailings consist of a mixture of radionuclides each
with their individual DAC's. Unless otherwise specified or determined in accordance
with Section 4.1.1 or 4.1.2 above, the DAC for a mixture is as follows:
4.1.3.1 Ore Prior to Leach
6E-11 uCi of gross alpha from U-238, U-234, Th-230, and Ra-226 per ml of air, or 3E-11
uCi of natural uranium per ml of air
4.1.3.2 Tailings When the Concentration of the Radionuclides in the Mixture is
Unknown
6E-12 uCi/ml = DAC for Th-230
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Date: 08/20 Revision: EFR 3
Book: Radiation Protection Manual, Section 4 Page 5 of 14
4.1.3.3 Tailings or Other Mixture When the Identity and Concentration of Each
Radionuclide is Known
.The DAC for the mixture is calculated by the following (see Regulatory Guide 8.30, page
2).
DA Cm = [ _f 1 + f2 + ... + f0_ }1
DAC1 DAC2 DACn
where DACm = DAC for the mixture of radionuclides 1 through n.
DAC1 = DAC for the first radionuclide in the mixture.
DAC0 = DAC for the nth, the last, radionuclide in the mixture.
fi = Fraction of alpha activity from the first radionuclide in
the mixture.
f0 = Fraction of alpha activity from radionuclide n in the
mixture.
For example:
Ra-226
Th-230
80 pCi/g
20 pCi/g
DACm = _Jill_ +
[ 100
3E-10
DAC = 3E -10 µCi/ml
DAC = 2E -12 µCi/ml
20
100 ] -1
2E-12
=
=
[ 2.67E9 + l.OOEl 1 ] -I
1
=
l.OE11
9.7E-12 µCi
ml
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
4.1.4 Sampling Time
Date: 08/20 Revision: EFR 3
Page 6 of 14
Calculate the sampling time required to detect 10% of the DAC by solving for sampling
time in the following equation:
LLD
(Sampling Time) (Flow Rate = 0.1 DAC
of Sampler)
For example:
To detect 10% of the DAC for U-nat, a 40 1pm air sampler would have to operate 57
minutes, assuming the sample counter has a lower level of detection of 10 dpm above
background, i.e.:
(10 DPM) ( pCi ) (E-6 µCi)
2.22 DPM pCi =
(X min.) (40 lit) 103ml
min. lit
X = 56.8 minutes
2E-12 µCi
ml
4.1.5 Dose Calculations (10 CFR 20.1201-20.1202)
1. Analytical results of airborne particulate samples may be obtained in several different
units that need to be converted into mg soluble natural uranium to determine the
weekly exposures and into µCi-hr/ml or WL-hr to determine annual exposures. The
following table presents a summary of the conversions that may be necessary. The
first row of the table presents the operations to be performed in the conversions.
Enter the measured weight or activity, the sampler flow rate, the sampling time, and
the exposure time into the first four columns. Divide the values in column 1 by the
values in column 2 and column 3, and then multiply by the values in columns 4 and 5
to obtain the units in column 6, or:
(Column 1) (Column 4) (Column 5) = Column 6
(Column 2) (Column 3)
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
UNIT CONVERSION TABLE
I 2 3 4
OPERATION DIVIDE DIVIDE MULTIPLY
MEASURED SAMPLER SAMPLING EXPOSURE
VALUE FLOW RATE TIME TIME
µg soluble L/min mm hrs
U-natural
pCi soluble L/min mm hrs
U-natural
pCi L/min min hrs
gross alpha
µg L/min min hrs
U-nat
ill ----hrs
mL
Radon
For example:
(10 p,g Soluble U-nat) (1 0 hrs) (1.2) = 2 mg Soluble U-nat
(2 L/min) (30 min)
See notes for a description of the unit conversions.
Date: 08/20 Revision: EFR 3
Page 7 of 14
5 6
MULTIPLY ANSWER
CONSTANT ANSWER
1.2 mg soluble
U-natural
1.77 mg soluble
U-natural
E-9 µCi-hrs
ML
6.77E-10 µCi-hrs
ML
E7 WL-hrs
2. The table on the following page is divided into four quadrants. Different quadrants
are for soluble uranium, insoluble uranium, tailings dust, and radon. Select the proper
quadrant for the type of airborne particulate being sampled. Enter the area, particulate
concentration, and hours of exposure in the labeled columns of the selected quadrant.
3. The protection factors are whole numbers, e.g., 10, 50, 1,000. Divide 1 by the
protection factor and enter the quotient in the fourth column of each quadrant, e.g., for
a protection factor of 1,000, enter 1/1,000 or 0.001 in the column. The 1/PF values
are unit-less.
4. Enter the product of the airborne concentration, the hours of exposure, the time, and
1/PF in the fifth column of each quadrant. Add these values and enter the total at the
bottom of the column.
5. On the dose calculations form which follows, enter the total for Soluble Uranium in
the equation and calculate the corresponding mg. If a value exceeds 10 mg, an over-
exposure may have occurred. If verified by a high uranium in urine results, an over-
exposure has probably occurred and needs to be reported to the NRC.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 08/20 Revision: EFR 3
Page 8 of 14
6. Enter the totals for SolubJe Uranium, In oJub1e Uranium. Tailings Du t, and Radon in
their respective equations. Perform the indicated calculations, add the fractions
together, and record as the subtotal. (Use the DAC for Th-230 or the DAC for
tailings dust to determine the contribution of tailings dust to the subtotal.) If a
subtotal exceeds 1, an over-exposure may have occurred. If verified by a high
uranium in urine result, an over-exposure has probably occurred and needs to be
reported to the NRC.
7. Enter the TLD determinations of whole body dose as the Deep Do e Equivalent on
the form. If the Deep Dose Equivalent exceeds 5 rems, an over-exposure may have
occurred and needs to be reported to the NRC.
8. If the Deep Dose Equivalent exceeds 0.5 rem and the subtotal exceeds 0.1, calculate
the Total Effective Dose Equivalent by adding the Deep Dose Equivalent to the
product of 5 rems times the subtotal and enter on the form. If the total effective dose
equivalent exceeds 5 rems, an over-exposure may have occurred and may have to be
reported to the NRC.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 08/20 Revision: EFR 3
Page 9 of 14
DOSE CALCULATIONS (10 CFR 20.1201 + 20.1202)
Name Soc. Sec. No. Co. l.D. No. Week Year
AREA SOL. U HR 1 i:!Ci-HR AREA INSOL. U HR 1 i:!Ci-HR
µCi/ML PF ML µCi/ML PF ML
TOTAL ---------TOTAL ------------
AREA TAILINGS HR 1 i:!Ci-HR AREA RADON HR 1 WL-HR
DUST PF ML WL PF µCi/ML
TOTAL ---------TOTAL ---------
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 08/20 Revision: EFR 3
Page 10 of 14
DOSE CALCULATIONS (10 CFR 20.1201 + 20.1202)
Name Soc. Sec. No. Co. I.D. No. Week
Weekly Soluble
Uranium
Annual Soluble
Uranium
Annual Insoluble
Uranium
Annual Tailings
Dust
(µCi-hr) (l.77E9)
(mL)
( !!Ci-hr)
mL
(2000 hr) (5E-10)
( µCi-hr)
mL
(2000 hr) (2E-ll)
( (!Ci-hr)
mL
(2000 hr) ( *)
Limit
* = DAC for Th-230 = 6E-12;
or= DAC for tailings dust.
Annual Radon with ( WL-hr)
Daughters Present (2000 hr) (0.33 WL)
=
=
=
=
=
Subtotal
Limit
Deep Dose Equivalent = TLD Whole Body Dose in rem =
Limit
If the Deep Dose Equivalent is> 0.5 rem
and
the Subtotal is> 0.1, then
Year
______ mg
10mg
1
______ rem
5 rem
Total Effective
Dose Equivalent
= Deep + Committed Effective
Dose Equivalent
= ( rem) + (5 rem) (
Dose Equivalent
Subtotal) =
Limit
______ rem
5rem
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Date: 08/20 Revision: EFR 3
Book: Radiation Protection Manual, Section 4 Page 11 of 14
DOSE CALCULATIONS (10 CFR 20.1201 + 20.1202)
Notes:
1. PF = Respiratory Protection Factor.
2. The 10 mg soluble uranium per week limit in 10 CFR Part 20.1201 is more
restrictive than the (40 hour) (DAC) limit for natural uranium, thus compliance is
based on 10 mg per week.
3. The conversion of uCi-hr/mL to mg natural uranium is the product of:
(air concentration) (hours of exposure) (breathing rate for light work)
(conversion of minutes to hours) ( specific activity of natural uranium)
( conversion of ug to mg) which is:
4.
(µCi-hr) (2E4 ml) (60 min) ( µg ) (E-3 mg) =
mL min hr 6.77E-7 uCi µg
(µCi-hr) (l.77E9)
mL = mg U natural
Thus to obtain mg natural uranium, multiply the µCi-hr/ml by l.77E9.
Soluble Uranium DAC (Class D) =
Insoluble Uranium DAC (Class Y) =
Thorium-230 DAC (Class Y)
Radon with Daughters DAC =
Tailings Dust DAC is a Site Specific Value =
5E-10 µCi/ml
2E-11 µCi/ml
= 6E-12 µCi/ml
3E-8 µCi/ml = 0.33 WL
µCi/ml
5. Description of unit conversions:
a. ug soluble U-nat -"7 mg soluble U-nat
( µg ) (E-3 mg) (60 min) (hr exposure) =
(_L_) (min sampler) (E3 ml) µg hr
min L
( u.g ) (hr exposure) (1.2) = mg soluble U-nat.
Cl) (min sampler)
min
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
b. pCi soluble U-nat ~ mg soluble U-nat
Date: 08/20 Revision: EFR 3
Page 12 of 14
( pCi ) (E-9 mCi) ( mg) (2E4 ml) ~
(_L_) (min sampler) (E3 ml) pCi 6.77E-7 mCi min
min L
(60 min) (hr exposure)
hr
=
( pCi ) (hr exposure) (1.77) = mg soluble U-nat.
(_L_) (min sampler)
min
c. pCi gross alpha ~ µCi-hr
( pCi ) (E-6 µCi) (hr exposure) =
(_L_) (min sampler) (E-3 ml) pCi
min L
( pCi ) (hr exposure) (E-9)
(_L_) (min sampler)
min
d. µg U-nat ~ µCi-hr
ml
= µCi-hr
ml
( µg ) (6.77E-7 µCi) ( hr exposure) =
(_L_) (min sampler) (E3 ml) µg
min L
( µCi ) ( hr exposure) (6.77E-10) = µCi-hr
(_L_) (min sampler) ml
min
e. µCi of Radon-222 ~ WL
ml
(µCi) (E6 pCi) (E3 ml) ( L-WL) =
ml µCi L E2 pCi
(µCi) (E7) = WL
ml
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
4.2 Personnel Exposure Files
Date: 08/20 Revision: EFR 3
Page 13 of 14
Energy Fuels Resources (USA) Inc. will generate and maintain individual exposure
records for each employee that works at the White Mesa Mill. The record system will be
designed to meet the specifications of the Federal Code of Regulations 10 CFR Part 20.
When an employee is hired, a file will be generated specifically for that individual. All
records that are to be in the radiation exposure file will be maintained during the term of
employment. When the employee terminates, all records will be preserved until the
Nuclear Regulatory Commission authorizes their disposition.
Personnel exposure records will be maintained at the mill site and will be accessible only
to the employee and the Radiation Protection staff. No copy of the exposure history will
be furnished to anyone outside of the Radiation Protection Department without a signed
consent form from the employee.
Contents of the exposure file:
Each personnel exposure file will contain the following records:
1. Information Sheet -Each information sheet will include the following information:
A. Employee's full name
B. Birth date
C. Social Security number
D. Date of hire
E. Date of termination
2. Record of Urinalyses -A multiple entry log of all urinalyses conducted at this work
site will include the following information:
A. Employee's full name
B. Sample dates
C. Sample identification number
D. Concentration of uranium in µg/1
E. An entry for any quality assurance "spikes" entered in µg/1
3. Internal personnel Exposure Records -These will be calculated and prepared using
the forms above or by the computer and the printout will be used as the permanent
record in the exposure file. The internal exposure records will contain the following
information:
A. Employee's full name
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
B. Social Security number
C. Birth date
Date: 08/20 Revision: EFR 3
Page 14 of 14
D. Exposure to airborne uranium expressed in both µCi and percent MPC
E. Any breathing zone samples collected for airborne uranium to be expressed in
µCi
F. Radon daughters expressed in working levels (WL) and period of exposure
(date)
4. External Exposure Record (OSL, Dosimeter) -The date received from the Dosimeter
contractor will be posted to the Dosimeter record in the exposure file. The following
information will be included on the Dosimeter record:
A. Employee's full name
B. Birth date
C. Social Security number
D. Period of exposure (dates)
E. Exposure in millirems (MR) for a given period
F. Total accumulated exposure while at the White Mesa Mill
G. Identification number of the Dosimeter badge
5. Record of Exposure from Previous Employment (NRC form 4 or similar) -A record
of occupational exposures that occurred prior to employment at the mill must be
obtained for each employee. If no such exposure record is available, the employee
must sign a statement to that affect. If previous exposure records were kept, a copy
must be secured and placed in the individual's file.
6. Reports of Over-exposure -If an individual has been found to be over-exposed, the
Radiation Safety Officer will draft a letter of explanation. The report will explain the
circumstances and/or reasons for the over-exposure. It will also state any actions
taken to correct the problem or to prevent future over-exposures. The report must be
placed in the individual's exposure file.
White Mesa Mill -.Standard Operating Procedures
SOP PBL-RP~S
Book 9: Radiation Protection Manual. Section 5
5. RAl>IATION WORK PERMITS
5.1 General
Date: 12/12 Revision: EFR 2
Page I of2
A Radiation Work Permit ('·RWP'·) system has been established for non-routine activities
where there is a potentiaJ for a significant radiation exposure, or for certain routine
activities where there is a potential to spread radioactive materials.
S~ificaUy •. an RWP is requited for:
a) All non-routine maintenance work, or work for which there is no effective
operating procedure, which may. by the determination of the Radiation Safety
Officer, exceed 25% of the R3l3-15 limits;
b) All routine wor)c, not covered by an operating procedure, that could invqive
the spread of radioactive materials; and
c) The receipt, handling or processing of any alternate feed material 01 other
radioactive material, .which has been determined by the Radiation Safety Officer~
not to faU within an existing operating procedure.
An RWP may also be used on a temporary basis for routine activities in lieu of an
operating procec,fure, while an operating procedure is being developed for the activity.
5.2 AU Non-Routine Activities Require hdiation Safety Officer Review
All non~routine activities require review by the Radiation· Safety Officer. The Rfl(liation
Safety Officer will ad".1se the Mill Mana.get on a regular basis of any·activities that
require an RWP.
5.3 Radiation Work Permit
The RWP is a form that describes the work to be performed, the location, duration.and
personnel involved; and the radiological controls needed, such as respirator. urine
samples, breathing zone monitoring, time linutations for the activity, etc. The form must
also have an.area for the Radiation Safety Officer, or his designee's_. signature. A copy .of
a form of '.RWP is attached.
$,4 Prf)~edure for Ob1-ining • b,dlatlon WoJ'k Pe.rmit
The procedure for obtaining an RWP is:
a) When RWP--type work i$_ to be performed, tbe Shift Fore.man, Maintenai'U:e
Supetintendent or other supervisoty petSortnel ·shall complete the top portion of
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-5
Date: 12/12 Revision: EFR 2
Book 9: Radiation Protection Manual. Section 5 Page 2 of 2
the RWP, which will provide information on the specific work locations,
estimated work duration, type of work to be performed, and personnel utilized,
and present it to the Radiation Safety Officer;
b) The Radiation Safety Officer will indicate the radiological controls needed
based on the information given and the safety of personnel. The Radiation Safety
Officer or his designee will provide the necessary surveillance and respiratory
protection equipment;
c) No work can be perfonned until the Radiation Safety Officer or his designee
has approved the RWP;
d) Any maintenance or RWP jobs done in the yellowcake dryer or packaging
enclosures will require a member of the Radiation Staff to be present for the
duration of the job;
e) All supervisors will be given training in and copies of the requirements for
using RWPs, with the permits remaining on file for five years; and
f) Any supervisor found to be knowingly and willfully violating these
procedures will be issued a written warning, and the situation will be reviewed by
appropriate management for remedial action.
Energy Fuels Resources (USA) Inc.
RADIATION WORK PERMIT
RWP# --------
Requestor: Date: -----------------------Job Location Rad Tech: -----------------------Job Description ---------------------------
Radiological Monitoring and Sampling
At start __ Intermittent Continuous ___ _
(A) Dust (B) Radon Daughters (Cl Beta-Gamma, ____ _
(0) Beta/Gamma -During (if additional cleanup is required)---------
Breathing Zone # Minutes ran pCi ___ _
Breathing Zone #2 (if applicable) Minutes ran pCi. ___ _
Bloassays ©
Date Bloassay Is Due
Rubber boots __ _ Rubber suits __ _
Protective Equipment
Rubber Gloves __
Tyvex __ Hoods __ _ Respirators __ _
Respirator Fit Testing
Name
ALARA Considerations
Estimated Job Duration:
Type Irritant Size
Full or PAPA Smoke
--.......,..---=------Standby Workers: ____ Showers Required
Cleanup
Proper Worn Fitted By
Fit (Initials)
Number of Workers: --------Time Limitations ------
Estimated exposure'"'":---------------------------
APPROVED BY: Date: -----------------------Au lh or I zed Signature
Name In Out In Out In Out In Out In Out Total Time
Job Status : Completed Changed Cancelled
Supervisor Completion Review: _______________ Date: ___________ _
Permit Terminated Date: Time: By: ----------------------RS O Review By: Date: --------
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
6.0 RELEASE SURVEYS
6.1 GENERAL
Date: 10/19 Revision: EFR 4
Page 1 of9
This Section contains the following procedures for the release of equipment and product drums
from the Mill: (1) restricted release of exclusive use vehicles; and (2) unrestricted release of
tractors, trailers, intermodal containers ("IMCs") and other vehicles, other equipment and product
drums.
Items can be released from the Mill's restricted area provided that those items meet certain
requirements as spelled out in NRC Regulatory Guide 8.30 Rev. 1, Health Physics Surveys in
Uranium Recovery Facilities and NRC's Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted use or Termination of Licenses for Byproduct,
Source, or Special Nuclear Material, May 2002.
Release surveys will be conducted to make sure that no contaminated equipment is released from
the facility. This Section 6 sets out the surveying procedures to be used in order to verify that the
equipment or product drum meets the applicable release criteria prior to exiting the Mill's restricted
area.
6.2 SURVEY EQUIPMENT
Release surveys are performed using a variety of detecting instruments, as listed in Appendix 1
and specified below. Each instrument is checked using a calibrated alpha or beta/gamma source,
as applicable, for proper function and operation prior to use, as described in Sections 6.3 .1 (c) and
6.3.2(b) below.
In the case of alpha detecting instruments, adjustments to the surface area being measured must
also be made to convert from the particular detector's surface area to the reference surface area of
100 cm2• Therefore when converting a measurement to the units of dpm/100 cm2, an area
adjustment factor must be applied to the measurement. For example, for the Ludlum instrument
with a 43-1 detector of 75 cm2 surface area, multiply the value by 1.33 (i.e. 100 cm2 divided by
75cm2).
The beta/gamma detecting instruments used at the Mill read directly in rnrem/hour.
Each instrument has a manufacturer's user's manual which describes the function, use and capability
of each instrument. These manuals must be understood by the surveyor before any surveying proceeds.
6.3 PRE-SURVEY PROCEDURES
6.3.1 Alpha Surveys
At the outset, prior to performing an alpha survey:
a) Tum the meter on and check the meter battery condition;
White Mesa Mill ....., Standara Operating Procedures
SOP PBIAlP-6
BoQk 9: Radiation Protection Manual, Section 6
P.ate: 10/19 Revision: EFR 4
Page 2 of9
b) Check the alpha detector mylar surface for pinholes~ etc. Replace if necessary and repeat
calibration;
c) As specified in Section 3. 2,perform a function check using a calibrated alpha source.
d) The ability of the alpha meter to detect alpha radiation will be compromised if the surface
area to be surveyed is wet. If an area to be surveyed for alpha contamination is wet, then,
prior to surveying:
{i) Wait fur the area 'to dry on its own:
(ii) Wipe the area dry with a toweli or
(iii) Use a hand-held torch or similar device to dry the. area.
6.3.Z Beta/Gamma Surveys
a) Tum the meter on and check the meter battery condition;
b) As specifi~d in Section 3.1.4.l. perform a function check using~ calibrated beta/gamma
source.
c) If the check is acceptable, proceed to monitoring.
6.4 RESTRICTED RELEASE
Exclusive use vehicl~. i.e., vehicles that are part of a dedicated run between the Mill and another
site may be released -under a restricted release. Under a restricted release, the exterior ofthe vehicle
will be surveyed for total activity,. Provided tbat the cargo area is covered, the inside of the cargo
area need not be surveyed for restricted release.
6.4.1 Re.stricted Release Standards
Alpha (combined fixed and removable)
Average 2?400 dpm/100cm2
Beta/Gamnui
Max.imum at each accessible surfaee o.s mrem/hr;
6.4~2 Restricted Release Procedure
Applies to an area of not more than 100 cm1
On external surface
A restricted rel~e, survey can be performed on. but :is not limited to, ore ·u-ucks, IMCs, &J;ld closed
bo:x trailers tAAt have been designated ·as exclusive use-conveyances,
White Mesa Mill -Standard Oper,ating Proccdµres
SOP PBL-RP~6
Book 9: Radiation Protection Manual, Section 6
Date: 10/19 ~evision: EFR 4
Page 3 of9
1. The radiation technician will start by obtaining the proper relea.i;e form (see Section 6.6 of this
procedure for the various release.forms). The .technician will then obtain the needed information
to complete the release form. This information will usually be the tractor trailer identification
markings. There should be one number for the tractor and one for the trailer.
2. As a safety precaution~ the technician will have the driver exit the vehicle prior to approaching
the equipment. If the driver does not leave the vehicle. the technician will contact the RSO to
have the driver removed from the vehicle,
3. The survey will begin by taking the required radiation detection instrumentation and addressing
the tractor.
a) The tractor survey should begin by surveying the tire-s. This will consist of slowly moving
the detector approximately 1/4 inch off of the surface of the tire. While doing this, the
technician should be watching the needle movement on the detector. Also, the technician
should be looking at the treads of the ti.re for any rocks or other objects protruding from
the tire. Any such rocks should be removed from the tread. The technician will then place
the rocks and any other objects into a bu.cket behind the Guardhouse to be taken up to the
ore storage area at the end of each shift;
b) After the tread is completed. the outside and inside facing surface$ of the tire should be
surveyed in the same manner;
c) After the tire ha& been surveyed and observed, the technician should then survey the interior
of the wheel well. Here too~ the detector should be held appro.ximateJy J/4 inch off of the
surface of the tractor. At the same time, the technician should be observing the wheel well
for any visible contamination. If visible contamination is found, the tractor must be sent
back to either secondary decontamination or back to the decontamination pad for another
washing. If no visible contamination is found, then the technician should move to the next
tire and start the process over.
d) The procedures set out in paragraphs a), b) and c) should be repeated for every tire on the
tractor.
e) The technician will then survey the tractor Itself, by siowly moving the detector, at a
distance ·of approximately 1/4 inch, over the sides and/or underneath th~ carriage of the
ttacto~. Suffici~nt measurements mu~t be tak;en in the mo~t apptoprjate locatj9qs to yieJd a
representative ~ssessment of the contamination levels. For tractors, this means at least 3
measurements must be taken on each side of the tractor for a total of at 1e8$t 6
measurements. In addition, the technician should look for any visible contamination, noting
in particular any areas where ore may collect. If any visible contamination. is found, the
tractor mUst be-redirected to either secondary decontamination or back to the
decontamination pad;
White MQsa Mill -Standard Operating Procedures
SOP PBL-RP-6
Book 9: RadiatiQn Protection Manual, Sccticm 6
Date: 10/19 Revision::EFR 4
Page 4 of9
4. After the tractor is completed. the techoicfan should move to the trailer and IMC, if applicable.
a) The trailer's tires and wheel wells will be surveyed in the same manner as the tractor's
tires and wheel wens, as set out in Sections 5.4.2 (5) (a), (b), (c) and (d);
b) The trailer itself should be surveyed by slowly moving the detector, at a distance of
approximately 1/4 inch; over the sides, bottom and if possible the tops of the unit. Sufficient
m~asurements must be taken in the most appropriate locations to yield a representative
ass.essment of the contamination levels. For ore tnlcks and other end dump trailers, see the
locations specified on the Equipment Survey for Restricted Release form attached to the
Mill's End Dwnp Trailer Acceptance, Handling & Release procedure No.: PBL-9, and for
IMCs see the survey locations specified on tbe Intermodal Container Survey for Restricted
Release form attached to the Mill1s lntennodtil Container Acceptance, Handling &. Release
procedure No.: PBl-2. for the locations to be surveyed. Copies of those forms are attached
to this proc~dure;
c) The technician should be aware that there may be numerous areas where material may
collect, Th~ tecbnician should observe all of these locations for visible contaminfltion. On
ore trucks, the technician should make sure to look under the support legs. tear bumper,
along the edge of the end dump tailgate and the mud flaps; These areas tend to be collection
places for ore as it is being unloaded.; and
d) If imy visible contamination is found, the unit must be redirected to either secondary
decontamination or back to the decontamination pad. ,
S. After the ~bnician bas surveyed all tires and wheel wells, and the sides; bottom and top (if at
all possjble) of the trailer or IM:C with the radiation detection instrumentation, and the surveys
satisfy the criteria in Section 6.4.1 and there is no visible contamination, the technician will
report to the guardhouse and document the findings on the appropriate paperwork which has
already been determined. ···
6. The technician will then make sure the driver sutveys him or herself following proper individual
scanning methods. At that point, the technician will authorize the ddver to reenter the vehicle.
The technician will then open the gate and the vehicle will~ allowed to exit the· facility.
6.5 {JNRESTRICTED RELEASE
VebJcles,. tfaiJers, IMCs, other eqajpment and product drums may be released Jrom the Mill's
restricted area oh an unrestricted' basis only jf $Utveyi:; are performed as described below and the
release criteria specified in Section 6.5, l are satisfied.
6.5.t Unrestricted Release Criteria
Alpha (ftxed and. remC)vable):
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-6
Book 9~ Radiation Protection Manual, Section 6
Av~rage
Maximum
Removable
Average
Maximum
5,000 dpm/100cm2 alpha
15,000 dprn/100 cm2 alpha
1,000 dpm/1 00 cm2 alpha
0.2 mrem/hr.
LO mrem/hr.
Date: 10/19 Revision: EFR 4
Page S of9
Average. over no more than 1 m2
Applies to an area of not more than 100 cm2
Determined by smearing with dry filter or
soft absorbent paper. applying moderate
pressure, and assessing the amount of
radioactive material on the smear.
Average at 1 cm
Maximum at l cm
6.S.2 Unrestricted Release of Tractors, Trailers, lntennodal Container$ and Other Vehicles
1. The radiation department will be notified at least 24 hours prior to the time that an
unrestricted release is required for any tractor trailer that has been hauling under a dedicated
haul.
2. For unrestricted release, separate alpha and beta/gamma surveys will be performed. For the
alpha survey, use a Ludlum Model 177 with a 43-1 75cm2 probe, or the equivalent. For the
beta/gamma survey; use a Ludlum Model 3 with a 44-6 probe, or the equivalent.
3. Perform the pre-survey procedures-described in Section 6.3 above.
4. An unrestricted release for a trailer will start with surveys of the exterior with the
appropriate radiation detection instrumentation. This wi11 include an alpha survey and a
beta/gamma survey.
a) The technician will first survey the tires, wheel welJs, sides, bottom and top of the trailer
for alpha using the same techniques mentioned under Section 6,4.2 above. The tractor (or
any other non-conveyance vehicle) wm also be surveyed in the same manner as set out in
Section 6.4.2 .. However,
(i) instead of applying the testricted release standards specified in Section 6.4.1 above to
the surveys of the tractor and trailer, the criteria for unrestricted release specified in
Section 6.5. l above for alpha will apply. The alpha meter will measure the· total alpha
(both fixed and removable). If the total alpha reading is less than the standard for
removable alpt)a alone, then the release standard will have beeQ met. However, if the
total alpha activity exceeds the standard for removable alpha alone then additional
swipes will be performed at the llocation.s that exceeded. the· standard to determine the
removable component of the total alpha contamination (se~ paragraph (6)(a) below);
and
b) The technician will then repeat the survey described in a) using the beta/gamma meter and
will apply the unr<'stricted Ielease criteria specified in Section 6.5.1 for beta/gamma. This
will be d~.me by slowly moving the·detector over fue same areas that were surveyed wilt\ the
alpha detector. The technician will hold the inst.r1'ment approximately 1 cm above the
surface. The technician will survey the same general areas as specifted in the ~lease fonns.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
Date: 10/19 Revision: EFR 4
Page 6 of9
If a survey fails to meet the standards set out in Section 6.5.1 above, or if there is any visible
contamination, then the trailer or JMC must be sent back to the decontamination wash station. If
the material wm not wash out, then more advanced methods of decontamination will be used.
This could include, but is not limited to, sandblasting of the trailer or Th1C to remove
contamination.
5. For an unrestricted release, the interior of the trailer, intermodal container or closed box
trailer, must also be surveyed. The survey will consist of dividing the trailer into sections.
Each section will be surveyed in the same manner, as follows:
a) Step one will have the technician using the alpha probe and slowly moving the probe
over the trailer or IM:C. The technician should keep the probe approximately 1/4 inch
from the surface of the trailer. Sufficient measurements must be taken in the most
appropriate locations to yield a representative assessment of the contamination levels.
The number and locations of these readings is listed on the release forms ( for end dump
trailers, see the Equipment Survey for Restricted Release form attached to the Mill's
End Dump Trailer Acceptance, Handling & Release procedure No.: PBL-9, and for
IMCs see the survey locations specified on the Intermodal Container Survey for
Restricted Release form attached to the Mill's Intermodal Container Acceptance,
Handling & Release procedure No.: PBl-2, for the locations to be surveyed. Copies of
those forms are attached to this procedure);
b) b) The technician will document the alpha readings in the section by indicating them
on the appropriate paperwork. If a survey fails to meet the standards set oat in Section
6.5.1 above, or if there is any visible contamination, then the trailer or IMC must be
sent back to the decontamination wash station. If the material will not wash out, then
more advanced methods of decontamination will be used. This could include, but is not
limited to, sandblasting of the trailer or IMC to remove contamination; and
c) After the alpha survey work is completed, the beta/gamma survey will proceed. This
will be done by slowly moving the detector over the trailer section as the technician
had done with the alpha detector. The technician will hold the instrument
approximately 1 cm above the surface of the trailer or Th1C. The technician will survey
the same general areas as specified in the release forms and that were surveyed for
alpha contamination. This information will then be documented on the form in its
proper location. If a survey fails to meet the standards set out in Section 6.5.1 above,
then the trailer or IMC must be sent back to the decontamination wash station. If the
material will not wash out, then more advanced methods of decontamination will be
used. This could include, but is not limited to, sandblasting of the trailer or IMC to
remove contamination.
6. After the technician has completed both the alpha and the beta/gamma surveys, the technician
will perform a removable alpha survey on the trailer. This will be done by:
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
Date: 10/19 Revision: EFR 4
Page 7 of9
a) Swiping any area on the inside or outside of the conveyance that was found by the surveys
to be over the facility's removable alpha release requirements. The alpha survey will detect
both fixed and removable alpha contamination. Because the piece of equipment will not
have any visible contamination (any piece of equipment that has visible contamination will
have been sent back for re-decontamination), the swipe will be used to determine if the
removable alpha exceeds the removable alpha limit; and
b) Even if no areas are found by meter survey to be over the limit for removable alpha
contamination, the technician should pull removable swipe samples from the inside of the
conveyance at a minimum of 10% of the sections in the trailer, using the procedures set out
in Section 2.3.3.3. Each removable swipe should cover 100 square centimeters.
These removable samples will then be taken to the radiation department for reading. If a swipe
fails to meet the standards set out in Section 6.5.1 above for removable alpha contamination, then
the trailer or IMC must be sent back to the decontamination wash station. If the material will not
wash out, then more advanced methods of decontamination will be used. This could include, but
is not limited to, sandblasting of the trailer or IMC to remove contamination.
7. After the completion of the surveys described above, the technician will document his or her
findings on the appropriate paperwork. If all data collected is within the facility's release
requirements, the technician will then place a red sticker on the driver's side, front panel of the
trailer or IMC. The sticker will be dated and signed by the releasing technician. The technician
will then file the paperwork in the radiation department files under the corresponding release
surveys.
8. The driver will then perform an appropriate individual survey. Once that survey has been
completed, the technician will open the gate and allow the tractor trailer to leave the facility.
6.5.3 Unrestricted Release of Equipment
An equipment release is the same as an unrestricted release of tractors, trailers, IMCs and other
vehicles specified in Section 6.5.2 (4) above, except that the item to be released is a piece of
operating equipment rather than a feed material haulage conveyance.
1. The technician will first be notified by the individual or group who wants the piece of
equipment to be released from the site. These groups or individuals may need the
equipment to go off site for repair, exchange or sale. The equipment must first go through
a decontamination process before it arrives at the front gate for surveying. The
decontamination may include, but is not limited to, a water wash, sand blasting, acid wash,
etc., as necessary in the circumstances.
2. The same survey instruments will be used as specified in Section 6.5.2 (2) above.
3. Perform the pre-survey procedures specified in Section 6.3 above.
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
Date: I0/19 Revision: EFR 4
Page 8 of9
4. The technician must visually observe aH sections, top, bottom and all sides of the piece of
equipment to make sure that there is no visible contamination. The technician needs to also
observe that there is no oil, grease or other material that may mask contamination. The
piece of equipment should be free of all such material prior to being released. If any such
contamination is observed, the piece of equipment must be sent back for re-
decontamination.
5. Prior to commencing the surveys, the technician will take a photograph of the piece of
equipment to be released.
6. The technician will then survey the piece of equipment using the same methods described
in Section 6.5.2 (4). Sufficient measurements must be taken in the most appropriate
locations to yield a representative assessment of the contamination levels. Because each
piece of equipment may be different or unique, tbe technician will use his or her judgment
as to the survey locations. The technician will describe the locations surveyed on the release
form.
7. If any areas surveyed are found to be over the facility's removable release requirements,
then a swipe will be performed using the procedures set out in Section 2.3.3.3. The alpha
survey will detect both fixed and removabJe alpha contamination. Because the piece of
equipment will not have any visible contamination (any piece of equipment that has visible
contamination will have been sent back for re-decontamination), the swipe will be used to
determine if the removable alpha exceeds the removable alpha limit;
8. If at any time, either visual contamination is observed or contamination is found by one of
the radiation detection instruments or a swipe to exceed the unrestricted release standards,
the piece of equipment must be sent back for additional decontamination. If at any time the
technician sends a piece of equipment back for additional cleaning, the technician should
document this and why he or she sent it back on the comment section of the equipment
release form.
9. After the piece of equipment has been successfully cleaned and surveyed, the technician
will allow the piece of equipment to be released from the Mill's restricted area.
10. The technician will place the form and the photograph in the equipment release book in the
radiation department.
6.5.4 Release of Product Drums
AH uranium and vanadium product drums and any other product drums will be released for
unrestricted release only and must satisfy the standards set out in Section 6.5.1 above, if the
material is being shipped as a non-exclusive use shipment. Otherwise, 49 CFR Part 173.443, Table
9 limits apply. In addition, vanadium product drums must also satisfy the release criteria specified
in the Mill's Release and Shipping of Vanadium Blackflake procedure No. PBL-15.
White Mes~ Mill -Standard Operali!)g Procedures
SOP PBL-RP-6
Book.9: Radiati:on Protection Manual1 Secdon 6
Date: 10/19 Revi$ion: EFR4
Page 9 of9
1. The same survey instruments will be used as specified in Section 6.5.2 (2) above.
2. Perfe>rm ~he pre~survey proce~ures specified jn Se~tion 6,3 ~hove,
3. The technician will perform an alpha scan of the drum by slowing moving the alpha
detector, at a. distance of appl'Qximately 1A inch, over the sides and top of the drum.
Sufficient measurements must be taken in the most approp(iate locations to yield a
representative assessment of the contamination levels. For product drums this means that
all drums must be surveyed. Each druni will be surveyed on at least 2 different locations
on the Jid and an average reading for the lid recorded. The technician will then measure at
least 4 different locations on the sides of the drum and get an average reading for the drum
itself. The technician will survey any area that is discolored, dented or creased to verify
that there is no contamination present. If a survey fails to meet the standards set out in
Section 6.5. l or 49 CFR Part l73A43, above (or irt the Release arid Shipping of Vanadium
Blackface procedure), then the drum must be cleaned. If the drum still does not pass the
survey, the drum is to be replaced. That means that Operations will collect the
contaminated drum and return it to the packing area and will repack the material into a new
drum, The old drum will then be taken io the Tai1ings ~a-to be crushed and disposed of.
4. In addition to the alpha surveys, all product drums must also be swiped for alpha
contamination using the procedures set Qut in Section 23.3.3. If a ·product drum fails to
meet the removabJe alpha standards set out in Section6.5. l or 49 CFR Part 173.443 above
for any swipe, then the drum must be cleaned. If the drum still does not pass the survey.
the drum is to be replaced. That means that Operations will collect the contaminated dcum
and return it to the packing area and will repack the material into a new drum. The old
drom will then be taken to the-Tailings area to be crushed and disposed of.
5. After the alplla survey work is completed, the beta/gamma survey will proceed. This will
be done by slowly moving the detector over the drum as the technician bad done with the
alpha detector, The detector will be placed at 1 cm from the drum and then moved slowly
over the same Jocations on the lid and drum as were surveyed by the alpha meter. The
highest reading will be documented for the areas. This inforrnation will then be.
documented on the form in its proper location. If a product drum fails to meet th~ standards
set out in Section 6.S.1 or 49 CFR Part 173.443. If the drum still does not pass the survey.
the drum is to be replaced. That means that Operations will collect the contaminated drum
and return it to the packing area and will repack the material into a new drum. The old
drum will then be taken to the Tailings area to. be crushed and disposed of.
6.6 FORMS
Attached are the various release survey forms Jo tpis section.
Energy Fuels Resources (USA) Inc.
Equipment Survey for Re1trlcted R.ieaae
Date: TrallerlD: ___________ SurveyedB_y_: _______ ~
4l9IU9o I
24
25
26
27
28
29
30
31
32
33
34
35
38
1nstrunen1:
SN:
Cal. Daw.
TRUCK# __ Oufa"'-Loeallon•
26
25
Tank #1
27
TIIUII AlfflOVlblt Ae11K1Vabte
Alpha Alpha a..G1mm1 Beta
Top
Bottom
Inside
Total Aaniovlbla Aamovlbll
Alplll Alpha 1...a.mma Beta
dpmltOOGm• domltOOcm' dDIIIIIOOcm1 Gamm• 4PPIUPo I dPmltoocm• dPmltOOcffl' domltoocm• Olmma
37
38
39
40
41
42
43
44
-45
46
47
48
49
lnatturnent Data
~A,,.,...11
Model:
SN:
Cal. Dela:
ror., s.,.v.mnu
Modal I:
SN:
Ca~ DIie:
Fin:Uon Chllclc: .Y ... I ... N __ Function CMck.· .... V ... I ... N ___ _ Source:
Th 230 0 f 9390 '*"71
811g:
Efflclengy;
~llkg:
Alpha lff:
Bela 8kg:
Beta ell:
Reaclng:
8kg:
Truck
end Tire SUrv•v
0 0 2
3 00
5 00
00 4
00 6
,,._,,A ... -1:
2:
3:
4:
5:
6:
Truck Ext.:
TRAILER
7 00 OOa
9 00 0010
11 00 0 012
Tola! Alphll
Bell-Gamma
J.aallao dpm
7
8
9
10
11
12
Chasals Ext
Comment•=------------------------lllfflOlllllle alpha· 1000 dpmf111Grm1
Allld alp ... -1000 dprn/100Dm1 IY8f'IOI
1IOOO dprnl1~mulmum
1h19 • GaMml -0.211rnw • 111111 IVWIII
1.0 mr/hr • 1cm m1111lmu111
Fmnt
19
LSlde 28
13 14 15 18
22
1 8 g 10
21
1 2 3 4
20 Tdmde
Talll Rtnlovnte
Alpla ~ ....
f MIIIAP I dllfflltllOGml ctom/1-Ollfflllll
1
2
3 • 5
8
7
a
8
10
11
12
18
14
15
18
17
18
18
Tollll Alplla
lnlwntt1:
8N
Cl~ DIie:
Elllcilny.
Elf. Ch«;lr V I H
............... ~--.. ..,..._ .... ..,,,......,...
1 .... --1_. ..... _
11ta-a...• D.tlllllllr' e 10m ._....
1,1 IMIII' e 1Clffl aal8lum
Energy Fuela Resource• (USA) Inc.
Eq1.1lpmant S.,nv•y fQr UnrHtrlcled ._. ...
Container ID: -------~rvayed·-~--------
Oulfllfe LoNdon•
R SICl8
17 18
11 12
5 8
-1DOGln'
Looatlanl
20
21
22
23
24
25
2e
'D
28
29
30
:fl
32
33
34
35
38
37
Rall&
,,._,. A,lplla
Modil1
8N:
CIL Ditla:
Eltlllilnor,
Ell. Ohlcll YIN
28
fton1
27 37
34
26 38
33
35
25
32
24
Total Rlinhlllf• .. Alpha his
dlllllltooom' 11am11DOaJn1 OamlM
ln11nUMnl Dela
TOlal~
Modlllr
8N:
ca Dllr.
Sollnlt:
Rftdlng:
Bltg
29
30
31
,
3
5
Loallon
1:
2:
3.
4:
5:
8:
Truak Ext.:
7
9
11
.LaMllla
1
' 1
1
8
0
0 ,
2
ChlulaExt.
Truck
1ndTl1'9911MY
0 02
00 004
00 OOs
Total ...
.Alpltt a.-. ......
TIIAUR 11REI
00 OOa
00 0 0 10
00 0012
Total .....
Nfllla Cllmffll ...
1,
Cammenta: ____________________ ~
Licensing
State
Date: _______ _
Daily Vehicle Scan for Vehicles Leaving the Restricted Area
License/ Operator
Container#
Removable alpha· 1,000 dpm/100cm2
Fixed alpha. 5,000 dpm/100cm2 average
15,000 dpm/100cm2 maximum
Beta-Gamma • 0.2 mr/hr @ 1 cm average
1.0 mr/hr @ 1 cm maximum
Truck/Tires
Total Alpha Rem.Alpha
dpm/100cm2 dpm/100cm2
Alpha Meter
Model#
SN ____ _
Cal. Date. ___ _
Efficiency:. ___ _
Eff. Check: YIN
Beta/Gamma
/311
mr/hr
Beta-Gamma
Model#
SN ____ _
Done By
Cal Date _____ _
Cs-137 #2
Readin,.__ ___ _
Bkg, ____ _
Comments :---------------------------------
EnerllY Fuels Resources (USA) Inc,
White Mesa Mill
Radiation Survey of Equipment Released for Unrestricted Use
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with the following procedure.
l. Monitor for Gross alpha contamination with the appropriate survey meter.
2. If calculated assay exceeds 1,000 dpm/100cm2, then perform swipe analysis at applicable points.
3. Decontaminate if a removable alpha exceeds 1,000 dpm/100cm2 or fixed alpha exceeds 5,000 dpm/100cm2•
4. Release equipment or material if alpha contamination and Beta-Gamma levels are below the following
limit:
Removable alpha -J ,000 dpm/100cm2
Fixed alpha-5,000 dpm/I00cm2 average
15,000 dpm/100cm2 maximum
Beta-Gamma-0.2 mr/hr @tern average
1.0 mr/hr @ 1cm maximum
Released from White Mesa Mill to:--------------------------
Released by (print name):----------
Date: ------
Signature:----------
List of Equipment Total Alpha dpm/100cm2 Removable Alpha Beta/Gamma mr/hr
dpm/100cm2
I,
2.
3,
...
C
s.
Instrument Function checks
Alpha Meter: Beta-Gamma Meter: Removable Alpha:
Inst. Model SN ___ _ Inst. Modcl SN ___ _ Inst. Model. ____ SN'----
Cal. Date: ___ _ Cs-137 Source SN. ___ _ Cal. Date:-------Bfticiency: __ _ Inst. Response ___ _ Bf.f~iency: ___ _
Eff. Check : Y / N Cal. Date:-----Eff. Check: ___ _
Was a copy of this document offered to the recipient? Yes or No Signature ofrecipient ----------
Comments: _____________________________________ _
Date:
Surveyed By:
Total
Alpha
Instrument:
SN
Cal. Date:
Function Check:
Th 230 @ 19,390 dpm:
Bkg:
MDA
Total
Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
Background:
Note:
Energy Fuels Resources (USA) Inc.
Lot#
Source Material Assay
&
Radiological Survey of Vanadium
Removable
Alpha
Model:
SN:
Cal. Date:
Alpha Bkg
Alpha eff:
MDA:
Total
Gamma
Model#:
SN:
Cal. Date:
Avg. Reading:
Laboratory assay results for this lot of vanadium product are attached.
Comments: -----------------------------
... DATE LOT NO. ------------------
BACKGROUND~~~-E FF IC IE NC Y FACTOR
J"•um Total Alpha Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
.mber dpm/100cm1 dpm/100cm2 Tot,s Sides
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
18
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
Average Gamma Dose Rate/Lot _______ _
~lmum Gamma Dose Rate/Lot _____ _
DATE
BACKGROUND
ln"Uffl
.Jmber
34
35
36
37
38
39
40
41
42
43
44
45
4.6
47
48
49
50 , 51
52
53
54
55
56
57
58
59
60
61
62
6·3
64
65
86
I '· ,
LOT NO. ------
EFFICIENCY FACTOR
Total Alpha Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
dpm/100cm1 dpm/100cm• Tops Sides
•
Energy Fuels Resources (USA) Inc.
While Mesa MIil
.--a,iE;:..:RaYFUELS RESOURCES
6425 S. Highway 191, PO Box 809
Blanding, UT 84511
USA
SHIPMENT SURVEY
CONTRACT NO.
TRACTOR NO.
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
MDA
LOT NO.
Tel: 435-678·2221
Fax: 435-678·2224
TRUCK CARRIER
TRAILER NO.
ALPHA SURVEY INSTRUMENTS
TOTAL REMOVABLE
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
ALLOWABLE LIMITS AS OUTLINE IN 49 CFA PART 173.443, TABLE 9
GAMMA SURVEY (49 CFR 173.441 (b) (1))
INSTRUMENT NO. MEASURED IN MILLIREMS/ HOUR
SERIAL NO.
CALIBRATION (MR/HR)
TRAILER SURFACE 200 MR/HR ALLOWABLE
SIX FEET DISTANCE 10 MR/HR ALLOWABLE
DRIVERS SEAT 2 MR/HR ALLOWABLE
SLEEPER 2 MR/HR ALLOWABLE
ALL DRUMS WERE INSPECTED PRIOR TO LOADING. ALL DRUMS WERE TIGHTL V
SEALED. NONE LEAKED AND THERE WAS NO LOOSE MATERIAL IN THE VEHICLE.
INSPECTOR SIGNATURE DATE
Energy Fuels Resources (USA) Inc.
DRUM CONTAMINATION SURVEY Page2
Type of Shipment:-------Lot#: ___ _ Date: __ _
Total Alpha Removable Alpha f,/y
Drum dpm/100cm2 dpm/100 cm2 Average
# Too Sides Bottom TOD Sides Bottom mrem/hr
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
• If total Alpha is greater than or equal to 1.000 dpm/100 cm2, a removable smear is required.
Alpha Meter
Modal#: _____ _
SN#: _____ _
Cal. Date: ____ _
Effk:llncy;_· ---~-
Eff. Check: Y / N
Removable Alpha
Model#:-----SN #: _____ _
Cal. Data:-----Efflclency: ____ _
Eff. Che·ck: V / N
Beta/Gamma Mater
Model#: ____ _
SN#: _____ _
Cal. Date: ____ _
Check Date: ___ _
Cs 137SN#2 Reading: ____ _
Bkg: _____ _
Paga3
Total Alpha Removable Alpha ply
Drum dprn/100 cm2 dpm/100cm2 Average
# Too Sides Bottom TDD Sides Bottom mrem/hr
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
Comments:
APPENDIX 1
Energy Fuels Resources (USA) Inc.
White Mesa Mill Radiation Detection Instrument List
Type of Radiation Monitored with
Model Serial Number Instrument
Model 177 116481 Alpha
Model 177 322900 Alpha
Model 177 322883 Alpha
Model 177 159117 Alpha
Model 177 159170 Alpha
Model 177 189581 Alpha
Model 177 185038 Alpha
Model 177 264740 Alpha
Model 177 264743 Alpha
Model 177 264616 Alpha
Model 177 159172 Alpha
Model 177 264571 Alpha
Model 177 247816 Alpha
Model 3 337582 Beta/Gamma
Model 3 245368 Beta/Gamma
Model 3 164493 Beta/Gamma
Model 3 158587 Alpha
Model3 283110 Beta/Gamma
Model 3 158588 Alpha
Model 3 337622 Beta/Gamma
Model 3 266392 Alpha
Model 3 319068 Alpha
Model 3 257131 Alpha
Model3 266292 Alpha
Model 3 237483 Alpha
Model 3 337536 Alpha
Model 3 235288 Alpha
Model 3 337521 Alpha
Model2 12859 Beta/Gamma
Model2929 146781 Alpha/Beta/Gamma
Model2929 216270 Alpha/Beta/Gamma
Model2200 17534 Alpha
Modet19 160104 Beta/Gamma
Model 3030 247394 Alpha/Beta/Gamma
Model 3030 241568 Alpha/Beta/Gamma
Model19 339357 Beta/Gamma
Model 19 253133 Beta/Gamma
rev. Nov. 22 2019
APPENDIX 2
Enerav Fuels Resources (USA) Inc.
White Mesa MIii Radiation Detedlon Instrument
Check Source Ust
lsotop Soura 5erlal No. DPMor11CI
Thorlum-230 5994~ 19,390
Plutonlum-239 c.s. 2039 38,000
Ceslum-137 CS-7A#2 SµCI
Strontium Yttrium-90 98SR4700903 39,300
Source Type
Alpha
Alpha
Beta/Gamma
Beta/Gamma
White Mesa Mill -Standard Operating Procedures
SOP PBL-RP-7
Book 9: Radiation Protection Manual, Section 7
1.0 TRAINING AND DOCUMENTATION
Date: 11/10/2020 Revision: EFR 01
Page 1 of 1
The radiation protection program at the Mill consists of several layers of controls to ensure conditions are
maintained As Low As Reasonably Achievable ("ALARA") and to achieve corporate and regulatory
agency compliance. The radiation protection program is documented in this Radiation Protection Manual
("RPM").
Radiation Safety Technicians ("RSTs") receive training to complete the monitoring activities in this
manual. The training consists of a combination of procedural review as well as hands on training with
meters and instrumentation associated with Sections 1 through 6 of this RPM. In addition to technical
training, RSTs receive training on the documentation of radiation protection program activities. The
documentation training applies to all activities contained in this RPM and is detailed below.
1.1 DOCUMENTATION
The importance of documenting accurately and clearly cannot be over emphasized. The documentation of
results from scans and procedures completed by the RST, and the review of such is fundamental to EFRI's
license and regulatory requirements.
1.2 GUIDELINES FOR DOCUMENTATION
The first step in establishing accurate information is ensuring that all information pertaining to a procedure
or scan is collected and accurately recorded. EFRI has established SOPs to maintain compliance to
regulatory requirements. Attached to the SOP are forms to help in gathering all information needed to fulfill
the requirements. The RST is required to make sure the form being used is the most current revision in the
SOP. Notify the RSO if the most current version is not being used and discard all versions of old form
when an SOP is updated.
After it has been verified that the correct form is being used for a survey, the RST will complete the survey
and document the findings on the form. All spaces on the form should be completed. If there is no
information for a space enter either a dash, NA, or some indication why the space was left blank. Double
check your work. The procedure or scan is not complete until all information is recorded.
RPM forms are collected and reviewed by a designated RST on a set frequency. During the reviews the
forms are checked for completeness, clarity, and accuracy. The RST picking the forms up checks them and
then initials the form after the review. The RST initial indicates that the form is complete. If the RST finds
incomplete forms the issue is forwarded to the RSO or designee for resolution.
In addition to the RST reviews, the RSO or designee reviews the forms for completeness and accuracy on
a monthly basis.
1.3 RSO REVIEWS
From observation, most errors occur when the RSTs are split between several tasks that occur
simultaneously. It is important that the RSO routinely observes the RST during surveys to ensure the SOPs
are being followed accurately and to give suggestions for improvements on the scanning process. Annual
observations by the RSO of the RSTs performing the tasks in the RPM, are also required. More frequent
observations may be performed if needed as indicated by the above referenced documentation reviews.
No.: PBL-1 ENERGY FUELS RESOURECS (USA) INC.
Rev. No.: R-6 STANDARD OPERA TING PROCEDURES Page 1 of 4
Date: April 1, 2014 Title: Safety and Environmental Review Panel
1.0 Purpose:
The State of Utah Radioactive Materials License (the "License") for the White Mesa uranium
mill is a Performance-Based License (PBL). The PBL essentially allows Energy Fuels
Resources (USA) Inc. ("EFR") to evaluate and implement certain changes in the licensed
operation without applying for and receiving a formal amendment to the NRC license. The
following procedure outlines the procedural steps to follow when making changes to the
operations pursuant to the License or a Performance-Based License Condition ("PBLC").
2.0 Changes Allowed Under the License or PBLC:
Under Performance-Based Licensing, EFR may make changes in licensed activities under
certain conditions as outlined in the license. Essentially, EFR may:
(1) Make changes in the facility or process, as presented in the license application,
(2) Make changes in the procedures presented in the application, or
(3) Conduct tests or experiments not presented in the application, without prior approval
of the Executive Secretary of the State of Utah Radiation Control Board (the "Executive
Secretary''), if EFR ensures that the following conditions are met:
• The change, test or experiment does not conflict with any requirement specifically
stated in the License (excluding material referenced in a PBLC), or impair EFR's
ability to meet all applicable regulations.
• There is no degradation in the essential safety or environmental commitments in
the license application, or provided by the approved reclamation plan;
• The change, test, or experiment is consistent with the conclusions of actions
analyzed and selected in the Environmental Assessment (EA) of February 1997.
Otherwise, EFR is required to submit an application for a license amendment from the
Executive Secretary. The determinations whether the above conditions are satisfied for a
particular proposed change will be made by a Safety and Environmental Review Panel
(SERP), described as follows.
F:\Mill SOP Master Copy\Book lO_pBL Sops\EFR\SERP\PBL-l_Sop rev 6.doc
No.: PBL-1 ENERGY FUELS RESOURECS (USA) INC.
Rev. No.: R-6 STANDARD OPERA TING PROCEDURES Page 2 of 4
Date: April 1, 2014 Title: Safety and Environmental Review Panel
3.0 Safety and Environmental Review Panel (SERP):
EFR will form a SERP to evaluate each potential change under the License or PBLC. The
SERP will be responsible for reviewing the changes, tests, or experiments to determine
whether an amendment to the License is required.
The SERP shall consist of a minimum of three individuals. One member of the SERP shall
have expertise in management and shall be responsible for managerial and financial approval
changes; one member shall have expertise in operations and/or construction and shall have
responsibility for implementing any operational changes; and, one member shall be the
corporate radiation safety officer (CRSO), or equivalent, with the responsibility of assuring
changes conform to radiation safety and environmental requirements. Additional members
may be included in the SERP as appropriate, to address technical aspects such as health
physics, groundwater hydrology, surface-water hydrology, specific earth sciences, and other
technical disciplines. Temporary members or permanent members, other than the three
above-specified individuals, may be consultants or other staff members.
4.0 SERP Review Procedure:
In their documented review of whether a potential change, test, or experiment (hereinafter
called "the change") is allowed under the License or PBLC, without a License amendment, the
SERP shall consider the following:
(1) Current License Requirements: The SERP will conduct a review of the most current
License conditions to assess which, if any, conditions will have impact on or be impacted by
the potential SERP action. If the SERP action will conflict with a specific License
requirement, then a license amendment is necessary prior to initiating the change.
(2) Impacts on regulations: The SERP will determine in the change, test, or experiment
conflicts with applicable regulations (example: UAC R313-15 requirements). If the SERP
action conflicts with NRC regulations, a license amendment is necessary.
(3) Environmental Assessment: The SERP will review whether the change, test, or
experiment is consistent with the conclusions regarding actions analyzed and selected iq. the
Environmental Assessment of February 1997. If the change causes substantive safety or
environmental impacts that have not previously been evaluated in the environmental
report/assessment, the proposed action must be evaluated to determine if the change would
authorize or result in:
• A significant expansion of the Mill site;
• A significant change in the types of effluents;
• A significant increase in the amounts of effluents
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\SERP\pBL-l_Sop rev 6.doc
No.: PBL-1 ENERGY FUELS RESOURECS (USA) INC.
Rev. No.: R-6 STANDARD OPERATING PROCEDURES Page 3 of 4
Date: April 1, 2014 Title: Safety and Environmental Review Panel
• A significant increase in individual or cumulative occupational radiation exposure; or
• A significant increase in the potential for or consequences from radiological accidents,
in which case an environmental report would be required. If an environmental report is
required, a License amendment would be necessary for the proposed action.
(4) Financial Surety: The SERP will review the proposed action to determine if any
adjustment to the financial surety arrangement or approved amount is required (Condition No.
9.5 of the license). If the proposed action will require an increase to the existing surety
amount, the financial surety instrument must be increased accordingly. The surety estimate
must also be updated either through a license amendment or through the course of the annual
surety update to the Executive Secretary. The Executive Secretary incorporates the annual
surety update by license amendment.
(5) The SERP will assure that there is no degradation in the essential safety or
environmental commitment in the License application, or as provided by the approved
reclamation plan.
5.0 Documentation of Review Process:
(1) After the SERP conducts the review process for a proposed action, it will document its
findings, recommendations and conclusions in a written report format. All members of the
SERP shall sign off in concurrence on the final report. If the report concludes that the action
meets the appropriate License or PBLC requirements and does not require a License
amendment, the proposed action may then be implemented. If the report concludes that a
License amendment is necessary prior to implementing the action, the report will document
the reasons why, and what course EFR plans to pursue. The SERP report shall include the
following:
• A description of the proposed change, test or experiment (proposed action).
• A listing of all SERP members conducting the review, and their qualifications (if a
consultant or other additional member).
• The technical evaluation of the proposed action including all aspects of the SERP
review procedures listed above.
• Conclusions and recommendations.
• Signatory approvals of the SERP members.
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\SERP\pBL-l_Sop rev 6.doc
No.: PBL-1 ENERGY FUELS RESOURECS (USA) INC.
Rev. No.: R-6 STANDARD OPERA TING PROCEDURES Page4of4
Date: April 1, 2014 Title: Safety and Environmental Review Panel
• Any attachments such as all applicable technical, environmental or safety
evaluations, reports or other relevant information including consultant reports.
(2) All SERP reports and associated records of any changes made pursuant to the License
or PBLC shall be maintained through termination of the License.
3) On an annual basis, by March 31st, EFR will furnish to the Executive Secretary a
report that describes all changes, tests or experiments made pursuant to the License or PBLCs
during the calendar year. The report will include a summary of the SERP evaluation of each
change.
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\SERP\PBL-l_Sop rev 6.doc
No.: PBL-2 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-8 ST AND ARD OPERATING PROCEDURES Page 1 of 5
Date: December 12, Title: Intermodal Container Acceptance, Handling & Release
2018
1.0 Purpose
The following procedure applies to acceptance, handling, and release of intermodal
containers from Energy Fuels Resources (USA) Inc. (EFR) White Mesa Mill (Mill). EFR
receives material for processing, in either bulk or non-bulk packaging. This procedure
addresses one form of bulk packaging -intermodal containers (IMCs). This procedure
may be amended, subject to approval by EFR's Safety and Environmental Review Panel
(SERP), from time to time as appropriate to address the individual requirements of
specific feed materials, or projects.
2.0 Ore Receiving
1. Check truck scale for zero balance at the beginning of each shift.
2. Inspect the inbound IMC prior to entry for the items listed on the Intermodal
Container Inspection Form (copy attached) as they apply to current project and
IMC container design. Notify Mill management of any discrepancies as soon as
practicable.
3. Inspect all copies of the Bill of Lading (BOL) to ensure that the shipment is
destined for the White Mesa Mill and that all shipping documentation is in order
(see Section 8.2). If any discrepancies are noted notify the Mill management
immediately. Do not dump the container until all paperwork discrepancies
are corrected.
4. Document inbound IMC according to project requirements.
5. Allow entry onto the scales.
3.0 Ore Dumping
Enter the loaded IMC information into the scale program on the computer.
1. After weighing the IMC, proceed to the designated ore storage area and dump the
material.
2. After dumping the material, return the IMC back across the scales for an empty
weight.
3. After weighing the IMC proceed to the designated area, within the Restricted
Area, for decontamination.
4. Use a front-end loader or similar equipment to push material into a designated
pile. Depending on license requirements material may need cover placed over it.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-2 IMC\Clean Rev 8\PBL-2 IMC SOP rev 8.doc
No.: PBL-2 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-8 ST AND ARD OPERA TING PROCEDURES Page 2 of 5
Date: December 12, Title: Intermodal Container Acceptance, Handling & Release
2018
5. Once a pile 1s considered complete, label the pile with the appropriate
designation.
4.0 Decontamination and Release of IMCs
All trailers and trucks will be decontaminated after unloading prior to leaving the
Mill. Shippers or transporters will notify EFR whether a specific trailer is to be released
for restricted or unrestricted use. Any trailers that are to be released for restricted use
will be decontaminated according to the requirements contained in DOT Part 49 CFR
173.428 or 173.443. Any trailers that are to be released for unrestricted use will be
decontaminated according to the requirements found in Table 2 of the Nuclear
Regulatory Commission's (NRC's) Regulatory Guide 8.30 Rev. 1 "Health Physics
Surveys in Uranium Recovery Facilities" or NRC document "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued
April 1993. Trailers requiring repair will be decontaminated for unrestricted release, to
facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired
without undergoing full decontamination if repaired within the restricted area of the Mill.
5.0 Decontamination and Release of IM Cs for Restricted Use
1. The truck and trailer with the empty IMC is directed to the decontamination pad.
2. Decontaminate the exterior of each truck, IMC, chassis and tires thoroughly,
using a high-pressure water wash.
3. After washing, move truck and IMC along the decontamination route. The
decontamination route is a graveled roadway specifically designed for
decontaminated equipment to exit the restricted area. Do not leave the
decontamination route. If it becomes necessary due to environmental conditions
or residual mud in the tires etc., additional instruction will be relayed by mill
personnel. At this point there should not be any visual residual mud on the tires,
chassis or exterior surface of the container.
4. Proceed along the decontamination route to the final scanning area.
5. Contact a Radiation Technician to perform a radiological contamination survey of
the IMC. If the Radiation Technician indicates select areas on the IMC that
require further decontamination, decontaminate those areas as necessary.
6. The Radiation Technician or RSO will scan the IMC, chassis, tires and truck in
various locations as shown on the IMC Container Survey for Restricted Release
(attached) and document the scan readings on the Container Survey for Restricted
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-2 IMC\Clean Rev 8\PBL-2 IMC SOP rev 8.doc
No.: PBL-2 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-8 STANDARD OPERA TING PROCEDURES Page 3 of 5
Date: December 12, Title: Intermodal Container Acceptance, Handling & Release
2018
Release. The contamination survey will be performed using appropriate
radiological instrumentation for total activity in accordance with DOT
transportation regulations. The release standards to be met for restricted release
are contained in U.S. Department of Transportation (DOT) Part 49 CFR 173.428
or 173.443.
7. If the IMC, chassis or tires do not meet the radiological release survey
requirements or shows visual contamination, the IMC and truck will return to the
decontamination pad for further decontamination. The Radiation Technician or
RSO will fill out the IMC survey for Restricted Release form (copy attached) to
document that the IMC has been authorized for release for restricted use. These
forms are filed in the Radiation Department. The Radiation Technician or RSO
will place a white sticker on the IMC that says, "EMPTY".
8. A Radiation Technician, or the RSO, will scan the designated decontamination
route and staging area(s) on a quarterly basis. The survey readings will be
recorded and kept on file in the Radiation Department.
6.0 Decontamination and Release of IM Cs for Unrestricted Use
1. Trucks hauling an IMC that will need a unrestricted release will normally drop the
IMC in a specified area within the Restricted Area. An appropriate piece of
equipment will pick up the empty IMC, from the staging area within the
Restricted Area, and transport it to the decontamination pad.
2. Open the tailgate and decontaminate each IMC using a high-pressure water wash.
Make sure to thoroughly wash the inside and outside of each IMC.
After the IMC is decontaminated, use the designated on-site equipment to move the IMC
to the designated area for clean IMC's.
3. Contact a member of the Radiation Department staff to conduct the appropriate
radiological survey of the IMC as delineated in Section 2.6 of the White Mesa
Mill Radiation Protection Manual. The release standards to be met for
unrestricted release are contained in Table 2 of the Nuclear Regulatory
Commission's (NRC's) Regulatory Guide 8.30 Rev. 1 "Health Physics Surveys in
Uranium Recovery Facilities" dated 2002, or NRC document "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted
Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" dated April 1993.
4. The Radiation Technician will perform a radiological contamination survey of the
IMC. If the Radiation Technician indicates select areas on the IMC that require
further decontamination, decontaminate those areas as necessary.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-2 IMC\Clean Rev 8\PBL-2 IMC SOP rev 8.doc
No.: PBL-2 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-8 STANDARD OPERA TING PROCEDURES Page 4 of 5
Date: December 12, Title: Intermodal Container Acceptance, Handling & Release
2018
5. If the IMC does not meet the radiological release survey requirements and/or has
visual contamination, the IMC will be returned to the decontamination pad for
further decontamination. If the IMC meets the radiological release survey and
visual inspection requirements, the Radiation Technician will place a red sticker
on the IMC that says, "THIS CONTAINER HAS BEEN FULLY
DECONTAMINATED AND SURVEYED FOR "UNRESTRICTED USE" BY:
(FILL IN NAME OF RADIATION TECHNICIAN)". The RSO or Radiation
Technician that performed the release survey will then sign the red sticker and
date it. In addition, the RSO or Radiation Technician will fill out a
Decontamination Final Release Form (a copy of which is attached) to document
that the IMC has been cleared for unrestricted release. The form includes a
schematic diagram of the IMC with points to be scanned and locations on the
schematic to fill in survey values for each IMC. The Decontamination Release
Form will be turned in to the Mill Administration Office for filing and
distribution.
After an IMC has been released, the IMC will be moved to the designated staging area
for empty IMCs.
7.0
7.1
7.2
Hazard Identification and Safety
Required Personnel Protective Equipment {PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses, steel-
toed shoes, and high visibility vests are required as a minimum. These must be
worn in all areas of the Mill with the exception of the Administration Building.
lndu trial Hazards and Safety
1. Use caution when chassis are backing onto the Ore Pad.
2. Ensure that all personnel within 50 feet of the IMC is aware that dumping is about
to commence.
3. Operators must use caution during the dumping process. Move at least 25 feet
away from the rear of the IMC during the initial dumping operation.
4. Do not place any part of your body inside the IMC when the chassis is being
tipped and the tailgate is open. The IMC could be lowered or accidentally fall at
any time, which would cause the tailgate to close rapidly and result in injury.
Only work under the tailgate after it has been properly blocked open.
5. Be aware of high-pressure wash water.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-2 IMC\Clean Rev 8\PBL-2 IMC SOP rev 8.doc
No.: PBL-2 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-8 STANDARD OPERATING PROCEDURES Page 5 of 5
Date: December 12, Title: Intermodal Container Acceptance, Handling & Release
2018
6. Be aware of slippery conditions on the ore pad during periods of inclement
weather.
7. Be aware of the potential for ice build-up on and around the decontamination pad
during periods of cold weather.
8. Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off of the equipment.
9. Always use a ladder when entering and/or exiting the interior of an IMC
8.0 Paperwork Tracking
1. Each IMC will have a unique sequential project number assigned to it at the
generating facility. This number will be entered onto the Bill of Lading (BOL)
and attached to the IMC prior to shipment from the generation site.
2. Upon arrival at the White Mesa Mill, the truck driver will turn in all of his/her
paperwork to the receiving personnel who will verify that the BOL number, IMC
number and project number assigned to the shipment match on all copies of the
BOL. If there are any discrepancies in any of the numbers notify Mill
management immediately. Only original paperwork will be accepted. If the
original paperwork does not come with the IMC, notify Mill management
immediately. Receiving personnel will sign the BOL, acknowledging receipt of
the material at the Mill, if all of the paperwork is in order. Depending on
contractual and/or sampling requirements, final acceptance or rejection of certain
alternate feed materials may be contingent on analytical results.
3. Each IMC will be transported across the scale at the Mill prior to and after being
unloaded. The appropriate information will be entered into the project database.
All copies of the SWTs and BOLs will be forwarded to the Mill Records Manager
on a daily basis or other frequency specified by Mill Management, from time to
time.
4. The records manager for the project will compile and reconcile the BOL's and
SWTs for distribution. The records manager will forward a summary of all
receipts to the EFR's corporate office on a monthly basis, or at other frequencies
as determined for the specific project.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-2 IMC\Clean Rev 8\PBL-2 IMC SOP rev 8.doc
ENERGY FUELS RESOURCES (USA) INC.
DECONTAMINATION FINAL RELEASE
I have verified that tractor NA and/or container ------~~-----
----------Container Number
auth01ized for final release.
Radiation Department
R: \radiation\F orms \decon. doc
Tractor Number
has been checked for any contamination and has been
Radiation Technician
Title Date
·'
)
1
2
3
4
5
6
7
..
8
9
10
11
Number
Container Number
Chassis Number
Correct Paperwork
Decontaminated
Tarps
Tarp Tie Downs
Tarp Support Bows
Bow Attachment
Brackets
Lifting Lugs
Structural Damage
Latch Mechanisms
Tires
Mudflaps
Additional Comments
Date
Driver& Trk Num.
WHITE MESA MILL
INTERMODAL CONTAINER INSPECTION FORM
Incoming
Incoming
Outgoing
Outgoing
Energy Fuels Resources (USA) Inc.
Equipment Survey for Unrestricted Release
Date: Container ID: ---------
Inside Locations
Surveyed B_,_y_: ----------
Outside Locations
Front
19
L. Side 23
13 14 15 16
7 8
1 2
Total Removable
Alpha Alpha
Location# dpmf100cm dpm/100cm2
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 VIN
Removable alpha -1,000 dpm/1 OOcm2
22
9 10
21
3 4
20
Tailgate
Beta
Gamma
Fixed alpha -5,000 dpm/100cm2 average
15,000 dpm/100cm2 maximum
Beta -Gamma -0.2 mr/hr@ 1cm average
1.0 mr/hr@ 1cm maximum
A Side
17 18
11 12
5 6
dpm/100cm2
Location#
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Removable Alpha
Model:
SN:
Cal. Date:
Efficiency:
Eff. Check VIN
28
Front
27 37
34
26 36
33
35
25
32
24
Total Removable
Alpha Alpha Beta
dpm/100cm2 dpm/100cm2 Gamma
Instrument Data
Total Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
Bkg
29
30
31
3
5
Truck
and Tire Survey
0
00
00
Total
Alpha
02
004
006
Beta-
Gamma
Location ~-d~Jp~m-~--~
1 =----1----l
2: 1----+----l
3: I-----+----<
4: ,__ ______ _,
5:1------+----l
6: 1----+----l
Truck Ext.: ~---~--~
TRAILER TIRES
7 00 0 0 8
9 00 0 0 10
11 00 0 012
Total Beta-
Location Alpha Gamma
dpm
7
8
9
10
11
12
Chassis Ext.
Comments :-------------------------------
Energy Fuels Resources (USA) Inc.
Equipment Survey for Restricted Release
Date: Trailer ID:
Inside Locations TRUCK# __ _
Surveyed B~y_: ---------
Outside Locations
Tota/Alpha
Instrument:
SN:
Cal. Date:
Efficiency:
Efficiency check: Y / N
28
Front
27 37
34
26 36
33
35
25
32
24
Total Removable
Alpha Alpha
Location# dpm/100cm• dpml100cm•
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Removable Alpha
Model:
SN:
Cal. Date:
Efficiency
Ell. Check: YIN
29
30
31
Beta
Gamma
Instrument Data
Total Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
BKG:
Truck
and Tire Survey
0 0 2
3 00 004
5 00 006
Total Beta-
Location Alpha Gamma
dpm
1:
2:
3:
4:
5:
6:
Truck Ext.: .__ __ _._ __ _,
TRAILER TIRES
7 00 0 Os
9 00 0 Q10
11 00 0012
Total Beta-
Location Alpha Gamma
dpm
7 i-----+-------1
8 >-----+----I 9 >-----+----I 10 >-----+----I 11 1--------+-----1
121--------,1--------, Chassis Ext ,.._ _ _,,.._ _ _,
Comments =-------------------------------
Removable alpha -1,000 dpm/100cm2
Fixed alpha -5,000 dpml1 OOcm2 average
15,000 dpm/100cm2 maximum
Beta -Gamma -0.2 mr/hr@ 1cm average
1.0 mr/hr@ 1cm maximum
ELECTRONIC CODE OF FEDERAL REGULATIONS
e-CFR data is current as of December 6, 2018
Title 49 --> Subtitle B --> Chapter I --> Subchapter C --> Part 173 --> Subpart I --> §173.428
Title 49: Transportation
PART 173-SHIPPERS-GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
Subpart I-Class 7 (Radioactive) Materials
§173.428 Empty Class 7 (radioactive) materials packaging.
A packaging which previously contained Class 7 (radioactive) materials and has been emptied of contents as far as
practical, is excepted from the shipping paper and marking (except for the UN identification number marking requirement
described in §173.422(a)) requirements of this subchapter, provided that-
(a) The packaging meets the requirements of §173.421 (b), (c), and (e) of this subpart;
(b) The packaging is in unimpaired condition and is securely closed so that there will be no leakage of Class 7 (radioactive)
material under conditions normally incident to transportation;
(c) The outer surface of any uranium or thorium in its structure is covered with an inactive sheath made of metal or some
other substantial material;
(d) Internal contamination does not exceed 100 times the limits in §173.443(a);
(e) Any labels previously applied in conformance with subpart E of part 172 of this subchapter are removed, obliterated, or
covered and the "Empty" label prescribed in §172.450 of this subchapter is affixed to the packaging; and
(f) The packaging is prepared for shipment as specified in §173.422.
[Arndt. 173-244, 60 FR 50307, Sept. 28, 1995, as amended by Arndt. 173-244, 61 FR 20752, May 8, 1996; 64 FR 51919, Sept. 27, 1999;
69 FR 3677, Jan. 26, 2004; 80 FR 72928, Nov. 23, 2015]
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ELECTRONIC CODE OF FEDERAL REGULATIONS
e-CFR data is current as of December 6, 2018
Title 49 ----> Subtitle B ----> Chapter I --> Subchapter C ----> Part 173 -+ Subpart I ----> §173.443
Title 49: Transportation
PART 173-SHIPPERS---GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
Subpart I-Class 7 (Radioactive) Materials
§173.443 Contamination control.
(a) The level of non-fixed contamination must be kept as low as reasonably achievable on the external surfaces of each
package, conveyance, freight container, and overpack offered for transport, and the internal surfaces of each conveyance,
freight container, and overpack in which inner packages or receptacles of Class 7 (radioactive) materials are offered for
transport.
(1) Excluding the interior surfaces of the containment system of packages and the internal surfaces of a conveyance,
freight container, tank, or intermediate bulk container dedicated to the transport of unpackaged radioactive material in
accordance with §173.427(c) and remaining under that specific exclusive use, the level of non-fixed contamination may not
exceed the limits set forth in Table 9 and must be determined by either:
(i) Wiping an area of 300 cm2 of the surface concerned with an absorbent material, using moderate pressure, and
measuring the activity on the wiping material. Sufficient measurements must be taken in the most appropriate locations to yield
a representative assessment of the non-fixed contamination levels. The amount of radioactivity measured on any single wiping
material, divided by the surface area wiped and divided by the efficiency of the wipe procedure (the fraction of non-fixed
contamination transferred from the surface to the absorbent material), may not exceed the limits set forth in Table 9 at any time
during transport. For this purpose the actual wipe efficiency may be used, or the wipe efficiency may be assumed to be 0.10; or
(ii) Alternatively, the level of non-fixed contamination may be determined by using other methods of equal or greater
efficiency.
(2) A conveyance used for non-exclusive use shipments is not required to be surveyed unless there is reason to suspect
that it may exhibit contamination.
Table 9 is as follows:
TABLE 9-NON-FIXED EXTERNAL RADIOACTIVE CONTAMINATION LIMITS FOR PACKAGES
Maximum permissible limits
Contaminant Bqlcm2 uCilcm2 d1Jmlcm2
1. Beta and gamma emitters and low toxicity alpha emitters 4 10-4 240
2. All other alpha emitting radionuclides 0.4 10-s 24
(b) In the case of packages transported as exclusive use shipments by rail or public highway only, except as provided in
paragraph (d) of this section, at any time during transport the non-fixed contamination on the external surface of any package,
as well as on the associated accessible internal surfaces of any conveyance, overpack, or freight container, may not exceed ten
times the levels prescribed in paragraph (a) of this section. The levels at the beginning of transport may not exceed the levels
prescribed in paragraph (a) of this section.
(c) Except as provided in paragraphs (a) and (d) of this section, each conveyance, overpack, freight container, tank, or
intermediate bulk container used for transporting Class 7 (radioactive) materials as an exclusive use shipment that utilizes the
provisions of paragraph (b) of this section, §173.427(b)(4), or §173.427(c) must be surveyed with appropriate radiation
detection instruments after each exclusive use transport. Except as provided in paragraphs (a) and (d) of this section, these
items may not be returned to Class 7 (radioactive) materials exclusive use transport service, and then only for a subsequent
exclusive use shipment utilizing one of the above cited provisions, unless the radiation dose rate at each accessible surface is
0.005 mSv per hour (0.5 mrem per hour) or less, and there is no significant non-fixed surface contamination as specified in
paragraph (a) of this section. The requirements of this paragraph do not address return to service of items outside of the above
cited provisions.
(d) Paragraphs (b) and (c) of this section do not apply to any closed transport vehicle used solely for the exclusive use
transportation by highway or rail of Class 7 (radioactive) material with contamination levels that do not exceed ten times the
levels prescribed in paragraph (a) of this section if-
(1) A survey of the interior surfaces of the empty vehicle shows that the radiation dose rate at any point does not exceed
0.1 mSv/h (10 mrem/h) at the surface or 0.02 mSv/h (2 mrem/h) at 1 m (3.3 feet) from the surface;
(2) Each vehicle is marked (e.g. stenciled) with the words "For Radioactive Materials Use Only" in letters at least 76
millimeters (3 inches) high in a conspicuous place on both sides of the exterior of the vehicle; and
(3) Each vehicle is kept closed except for loading or unloading; and
(4) Each vehicle is placarded in accordance with subpart F of part 172 of this subchapter.
(e) If it is evident that a package of radioactive material, or conveyance carrying unpackaged radioactive material, is
leaking, or if it is suspected that the package, or conveyance carrying unpackaged material, may have leaked, access to the
package or conveyance must be restricted and, as soon as possible, the extent of contamination and the resultant radiation
level of the package or conveyance must be assessed. The scope of the assessment must include, as applicable, the package,
the conveyance, the adjacent loading and unloading areas, and, if necessary, all other material which has been carried in the
conveyance. When necessary, additional steps for the protection of persons, property, and the environment must be taken to
overcome and minimize the consequences of such leakage. Packages, and conveyances carrying unpackaged material, which
are leaking radioactive contents in excess of limits for normal conditions of transport may be removed to an interim location
under supervision, but must not be forwarded until repaired or reconditioned and decontaminated, or as approved by the
Associate Administrator.
[79 FR 40616, July 11, 2014]
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'
l
l
GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQ{WMENT
PRIOR TO RELEASE FOR UNRF.STRICTED USE
OR TERMINATION OF LICENS~ FOR BYPRODUCT, SOURCE.
· OR SPECIAL NUCLEAR MATERIAL
,. j,• .-~,
U.S. Nuclear Regulatory Commission
Division of Fuel Cycle, Medical, Academic,
and Commercial Use Safety
Washington, DC 20555
April 1993
1•:-1~' • ... ,
1 '
\'
. rJ ..
I
(
'The instructions in this guide, in conjunction with Table 1, specify the
radionuclides and radiation exposure rat.e limits which should be used in
decontamination and survey of surfaces or premises and equipment prior to
abandonment or release for unrestricted use. The limits in Table l do not
apply to premises, equipment, or scrap containing induced radioactivity for
which the radiologicaJ considerations pertinent to their use may be
different. The release of such facilities or items from regulatory control is
considered on a case-by-case basis. ·-
1. The licensee shall make a reasonable effort to eliminate residual
contamination.
2. Radioactivity on equipment or surfaces shall not be covered by paint,
plating, or other covering material unless contaminatiQn levels, as
detennined by a survey and documented, are below the limits specified in
Table 1 prior to the application of the covering. A reasonable effort
must be made to minimize the contamination prior to use of any covering.
3. The radioactivity on the int.erior surfaces of pipes, drain lines~ or
ductwork shall be determined by making measurements at all traps, and
other appropriate access points, provided that contamination at these .
locations is likely to be representative of contamination on the interior
of the pipes, drain lines, or ductwork. Surfaces of premises, equipment,
or scrap which are likely to be contaminated but are of such si7.e,
construction, or location as to make the surface inaccessible for pUI])Oses
of measurement shall be presumed to be contaminated in excess of the limits.
4. Upon request, the Commission may authorize a licensee to relinquish .
possession or control of premises, equipment, or scrap having surfaces
contaminated with materials in excess of the limits .specified. This may
include, but would not be limited to, special circumstances such as razing
of buildings, transfer of premises to another organization continuing work
with radioactive materials, or conversion of facilities to a long-term
storage or standby status. Such requests must:
a. Provide detailed, $pecific infonnation describing the premises,
equipment or scrap, J7!dioactive contaminants, and the nature, ext.ent
and degree of residual surface contamination.
b. Provide a detailed health and safety analysis which reflects that the
residual amounts of materials on surface areas, together with other
considerations such as prospective use of the premises, equipment,
or scrap, are unlikely to result in an unreasonable risk to the health
and safety of the public .
. · • '. ~-lfmi# llliiW . -· . ·10 r •
J
2
5. Prior to release of premises for unrestricted use, the licensee shall
make a comprehensive radiation survey whi.ch establishes that contamination is
within the limits specified in Table 1. A copy· of the survey report shall be
filed with the Division of Fuel Cycle Safety and Safeguards, U.S. Nuclear
Regulatory Commission, Washington, D.C. 20555, and also the Administrator
of the NRC Regional Office having jurisdiction. The reports should be tiled at
least 30 days prior to the planned date of abandqnment~ The survey report shall:
a. Identify the premises.
b. Show that reasonable effort has been made to eliminate residual
contamination.
c. Describe the scope of the survey and general procedures followed.
d. State the findings of the survey in units specified in the
instructions.
Following review of the report, the NRC will consider visiting the
facilities to confinn the survey.
,.
.t;[ ! ,-:-;. -
TABLE l
ACCEPTABLE SURFACE CONTAMINATION LEVELS
NUCUDES" AVERAGEb•r MAXIMUMbdr REMOV ABLEb O r
U-nat, U-23S, U-238, and
associated decay products
5,000 dpm a/100 cm2 15,000 dpm a/100 cm2 1,000 dpm a/100 cm2
Transuranics, Ra-226, Ra-228,
Th-230, Th-228, Pa-231, Ac-227,
1-125, 1-129
100 dpm/100 crn1 300 dpm/100 cm2 20 dpm/100 crn2
Th-nat, To-232, Sr-90, Ra-223,
Ra-224, U-232, 1-126, 1-131,
1-133
1,000 dpm/100 cm2 3,000 dpm/100 cm2 200 dprn/100 cm2
•
Beta-gamma emitters (nuclides
with decay modes other than
alpha emission or spontaneous
fission) except Sr-90 and
others noted above.
5,000 dpm {j-y/100 cm2 15,000 dpm f3'Y/100 cm2 1,000 dpm {j-y/100 cm2
Where surface contamination by both alpha-and beta-gamma-emitting nuclides exists, the limits established for alpha-and beta-gamma-emitting
nuclides should apply independently.
As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as detennined by correcting the counts per
minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be
derived for each such object.
• Toe maxim~ contamination level applies to an area of not more than ·100 cm2 •
The amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with dry filter or soft absorbent
paper. applying moderate pressure, an.d assessing the amo\lllt of radioactive material on the wipe with an appropriate instrument of known efficiency.
Wbeo removable contamination on objects of less surface. area is detennined, the pertinent levels should ~ reduced proportionally and the entire
-surface should be wiped.
The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad/hr at
1 cm and 1.0 mrad/hr at 1 cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.
~-l~~~~~~~~~:::::::::::::::=======~~~
No.: PBL-3 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-5 STANDARD OPERATING PROCEDURES Page 1 of 2
Date: December 17, Title: Tailings Capacity Evaluation
2018
1.0 Purpose:
The State of Utah Division of Waste Management and Radiation Control ("DWMRC")
license for the White Mesa uranium mill ("Mill") is a Performance-Based License ("PBL").
The PBL allows Energy Fuels Resources (USA) Inc. ("EFRI") to evaluate and implement
certain changes in the licensed operation without applying for and receiving a formal
amendment to the DWMRC license. The following procedure outlines the steps to follow
when accepting additional conventional ore or alternate feed materials, to ensure that the
currently permitted capacity of the Tailings Management System is not exceeded. This
Standard Operating Procedure (SOP) is in conformance with the Mill's DWMRC License.
2.0 Tailings Capacity Determination Procedure:
Whenever the Mill is considering receiving conventional ore, 1 le.(2) material, or an alternate
feed, the capacity of the Mill Tailings Management System will have to be evaluated to
ensure that sufficient volume is available to store the projected incremental volumes of
tailings material, as well as the projected volumes of waste material from final reclamation of
the Mill facility, based on the approved Reclamation Plan. This evaluation will be performed
on an annual basis by the Mill Manager, or his designee, and approved by the President and
CEO of EFRI, or his designee. The Tailings Capacity Determination will be completed by
January 31 utilizing the volumes of conventional ore, 1 le.(2) material and alternate feed
materials projected to be received in EFRI' s approved operating budget for the that year.
The procedure for determining whether there is sufficient capacity is described as follows
and documented on the attached Tailings Capacity Form.
2.1 For the initial evaluation, the base volume ("BV") available will be based on the
remaining capacity in the active tailings cell, as determined by the Mill Manager
from land surveys and production records. For each subsequent evaluation, the
previous evaluation will produce a current remaining tailings capacity value, which
will become the new BV for each active tailings cell.
2.2 Mill Management will maintain a Tailings Capacity Evaluation Record ("TCER")
book, in which all evaluation forms and supporting calculations will be maintained.
Refer to the TCER to obtain the BV value to be used in each subsequent evaluation.
2.3 The volume of tailings discharged to the active tailings cells between the date of the
BV and the evaluation date will be estimated based on the Mill's production reports.
No.: PBL-3 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-5 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 17, Title: Tailings Capacity Evaluation
2018
2.4 The amount of ll(e).2 in-situ waste material deposited into the tailings system
between the date of the BV and the evaluation date will be summarized. The
quantities of material will be listed by supplier and will be based on the Scale House
Weigh Tickets from each shipment.
2.5 The BV, minus the quantities in items 2.3 and 2.4 above, will become the current
tailings capacity. This number will be used as the BV (item 2.1 above) for the
subsequent evaluation.
2.6 The amount of alternate feed material or conventional ore committed to be processed
and deposited into the tailings system will be summarized. The maximum projected
quantities of material will be listed by supplier and stated in dry tons, i.e. less the
estimated moisture content. Maximum 11 ( e ).2 material commitments will be
summarized and estimated by supplier and converted from cubic yards to dry tons.
2.7 The sum of the quantities estimated in item 2.6 above will be subtracted from the
current tailings capacity calculated in item 2.5 above, to determine the remaining
capacity available.
2.8 The remaining available volume in each of the active tailings cells will be converted
to an equivalent volume in dry tons using a factor of 86 dry pounds cubic foot of
available storage, or 2,322 dry pounds per cubic yard ( 1.16 dry tons per cubic yard).
This factor was calculated in the Tailings Capacity Evaluation prepared in May of
2000. The factor was subsequently confirmed from drilling conducted in preparation
of the Tailings Data Analysis Report, MWM, April 2015.
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 1 of 7
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
1.0 Purpose
The following procedure applies to acceptance of alternate feed material(s) or any other ore which
Energy Fuels Resources (USA) Inc. (EFRI) determines to potentially contain levels of thorium
that require that special procedures be followed, which are over and above those required for
routine ore processing at the White Mesa Mill (the "Mill"). Any such potential alternate feed
materials or other ores will undergo a pre-acceptance evaluation by the Mill's ALARA Committee.
Alternate Feed Materials or other ores which the ALARA Committee determines require such
special procedures will be designated as "High Thorium-Content" (or, "HTC") ores.
1.1 Background
This procedure was approved by the Nuclear Regulatory Commission (NRC) by letter dated
December 27, 2000. This procedure has been used as the baseline (reference point) for the
development of other HTC feed-specific Standard Operating Procedures (SOPs) including but not
limited to Heritage, Sequoyah, and Calcine. All feed-specific changes were as approved by EFRI's
Safety and Environmental Review Panel (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 As Low As Reasonably Achievable (ALARA).
Because this procedure was approved by the NRC as part of the License Amendment for WR Grace,
this procedure has been adopted for use by reference. An official SOP number was not assigned to
this procedure and it was not published for general staff use because the WR Grace material was not
received; however, the SOP is considered active and available in accordance with the ALARA
program requirements.
This procedure 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 this procedure, 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 herein. This SOP assumes thorium content comparable to the
WR Grace alternate feed materials or greater. The protections in this 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 herein 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.
The methods set forth in this SOP are based on the assumption that the HTC ore(s) will be delivered
to the Mill in 20-ton intermodal containers (IMCs). Should the delivery method be modified, EFRI
will revise this SOP (or the HTC ore specific SOP) to address the selected mode of delivery.
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 2 of 7
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
2.0 Ore Receiving
For material receiving procedures, see Section 2.0 of White Mesa Mill SOP PBL-1, rev. No. R-6,
Intermodal Container Acceptance, Handling and Release.
3.0 Ore Dumping
After the IMC has been dropped off in the Restricted Area, follow the procedures specified in
White Mesa Mill SOP PBL-1. The following feed-specific procedures will be implemented for the WR
Grace material or materials with thorium greater than WR Grace that do not have a feed-specific SOP:
4.0
1. Stockpile size will not exceed 200 tons or 10 containers.
2. Once an ore lot pile is complete, label the pile with the appropriate ore lot number, and
cover with reinforced plastic.
3. Gross alpha air sampling will be performed continuously, as indicated in Section 7. lof this
SOP, during initial phases of material receipt in order to determine the exact frequency of
monitoring and the required PPE to be used. A Radiation Work Permit (RWP) will be
issued during the initial receipt of the HTC ore(s). The RWP will list the health physics
controls, required personal protective equipment, monitoring, and survey requirements
necessary to assess the radiological exposure potential to employees operating under the
RWP. The air sampling data collected, as described in Section 7.1 of this SOP, will also be
among the data used to ensure that the stabilization methods listed below are adequate.
4. Dust suppression measures will include the following:
a. Application of stabilizing agent(s) to the piles (for example magnesium chloride or
similar material), either prior to or in addition to being covered.
b. All piles will be wet down at least once per day until such time that they are covered.
c. All completed stockpiles will be covered with reinforced plastic.
d. All stockpiles will be inspected at least once per day to ensure the integrity of the
covermg.
e. In the event of wind speeds in excess of 20 MPH, all dumping activities will cease
immediately.
Radiation Monitoring during Ore Processing
Due to the likelihood of higher concentrations of thoron and other radiological dangers during
HTC ore processing, the following monitoring methodologies will be followed while processing
HTC ore. Based upon results of monitoring and dose calculations, recognizing that there may be a
potential for higher than normal radiological exposures, the Mill Radiation Safety Officer (RSO)
may recommend that personnel be rotated from area to area periodically in order to reduce
potential exposure.
As soon as the results of the monitoring activity, conducted in accordance with the conditions
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 3 of 7
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
indicated by the RWP, have been evaluated, the added radiological surveys applicable to the
particular HTC ore will be established, communicated to the Radiation Safety Technicians (RSTs),
conducted, and documented. Irrespective of the added surveys selected for the particular HTC ore,
the following radiological surveys will be performed routinely for the duration of the processing
of HTC ore.
4.1 Area Airborne Sampling
During initial receipt of HTC ore, weekly area airborne sampling will be conducted in the areas of
the Mill listed below. A sample will be collected at a flow rate of 40 liters per minute, or greater
and the sample will be collected at a length of time sufficient to meet the Lower Limit of Detection
necessary to determine if procedures are appropriate. After sufficient data has been collected and
reviewed by the RSO and ALARA Committee, area airborne sampling frequency may be reduced
to once every two weeks during the processing of HTC mill feed.
1. Ore feed area.
2. Leaching area.
3. Central Control Room.
4. Solvent Extraction Building.
5. Precipitation area.
6.
The above samples will be analyzed for gross alpha.
4.1.4 DAC Determination
A composite feed sample will be analyzed for radioscopic composition for U-Nat and Th-Nat. A
composite of two air samples from each of the above locations will also be analyzed for U-Nat and
Th-Nat. The composite air sample results will be compared to the feed material results. These data
comparisons will be used by the RSO to establish the appropriate derived air concentration (DAC)
for each location listed above, and the U-Nat to Th-Nat ratio for analysis using gross alpha
counting. If gross alpha counting of air samples using the U-Nat to Th-Nat ratios indicate an
airborne radioactive dust concentration of 25% of the thorium DAC or uranium DAC, or the
geometric mean of the mixture, in any of the areas listed above, then the air sample frequency will
be increased to weekly in those areas only. Alternatively, the appropriate DAC determination may
be accomplished by applying the provisions of Section 4.1.2 of the Mill's Radiation Protection
Manual (DA Cs for Alternate Feed Materials and Other Ores).
4.2 Breathing Zone Sampling
a. Breathing zone air samples will be collected once per month on select individuals who
perform routine work tasks associated with processingoperations.
b. Breathing zone air samples will be collected from individuals who perform work tasks
under anRWP.
c. In addition to the above sampling under (a) and (b), further breathing zone samples
will be collected from individuals at the discretion of theRSO.
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 4 of 7
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
4.3 Environmental Sampling
a. Continuous air samples are collected on a weekly basis in the following areas during
processing of HTC feed material.
l. Ore pad area (BHV-5).
2. Tailings area (BHV-4, BHV-6, and BHV-7).
4.4 Tailings Management
Tailings resulting from processing HTC ore will be deposited in an area of the tailings system
that will ensure that the material is fully submerged beneath pond liquid and/or tailings slurry
from non-HTC ore until such time as the first layer of interim cover or random fill is placed
on the tailings system. This will minimize the potential for thoron gas to escape to the
atmosphere. Mill Management and the RSO will coordinate efforts to ensure that operations
personnel are provided direction regarding placement of HTC tailings. In addition, the weekly
tailings inspections reports will document the placement of HTC tailings during the preceding
week.
4.5 Surveys For External Radiation
a. All employees working with HTC material will wear a personal Optically Stimulated
Luminescence detectors (OSL) badge. The badges will be collected quarterly and the
results entered on individual exposure forms.
b. Beta/gamma dose rate measurements will be performed weekly in all areas of the mill
operations. These data will be used to perform monthly dose rate calculations.
c. Monthly OSL badges will be worn by individuals who perform work tasks that are
anticipated to exhibit the highest potential dose rate exposures, such as those assigned
to RWP tasks and workers performing initial receipt and handling of the HTC ore,
prior to establishment of HTC ore-specific DAC values.
4.6 Surveys for Radon-222, Radon-220 and Their Daughters
Monthly measurements of radon daughter concentrations for both Ra-222 and Ra-220 will be
conducted in those areas of the Mill listed above in Section 4.1 of this SOP. If radon daughter
concentrations from either the uranium or thorium parent is greater than 25% of the limit (0.08
working level for Ra-222 or 0.25 working level for Ra-220) the sampling frequency will be
increased to weekly in areas where these levels are routinely encountered. All ventilation
systems in the Mill will be checked daily by the radiation safety staff.
5.0 Decontamination and Release ofIMCs
For intermodal release procedures, see White Mesa Mill Standard Operating Procedure PBL-
1, rev. No. R-1, lntermodal Container Acceptance, Handling and Release.
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 5 of 7
Rev. No.: R-1 ST AND ARD OPERATING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
6.0 Hazard Identification and Safety
In addition to the usual safety procedures required for work at the Mill, the following
safety procedures are to be followed for projects involving HTC ore.
6.1 Required Personnel Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed
shoes are required as a minimum. These must be worn in all areas of the Mill with the
exception of the Administration Building.
The following are required while handling HTC material.
1. Coveralls. Coveralls must be laundered on a daily basis!
2. Leather or rubber gloves.
3. Rubber Boots or Booties.
Respiratory protection as directed by the RSO or specified in an RWP. Respiratory
protection will be used during initial receipt and handling of HTC ore(s) and until HTC
ore-specific DAC values are set. In addition, all individuals who work in areas where
there is a likelihood that the airborne concentration DAC limits for either uranium, radon,
thoron or thorium will exceed 25% of the DAC will be required to wear respiratory protection, as
directed by the RSO (See section 7.1.2), below
6.2 Industrial Hazards and Safety
1. Use caution when chassis are backing onto the Ore Pad.
2. Ensure that all personnel within 50 feet of the area where the IMC is offloading.
3. Any individual assisting in unloading must be at least 25 feet away from the rear of the
IMC during the initial dumping operation.
4. Do not place any part of your body inside the IMC when the chassis is being tipped and
the tailgate is open. The IMC could be lowered or accidentally fall at any time, which
would cause the tailgate to close rapidly and result in injury. Only work under the tailgate
after it has been properly blocked open._
5. Be aware of high-pressure wash water.
6. When the crane is in operation, make sure all personnel, except the persons in charge of
the tag lines, are 50 feet away from the IMC being moved. The persons in charge of the tag
lines should never be underneath the IMC that is being moved.
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 6 of 7
Rev. No.: R-1 ST AND ARD OPERA TING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
7.0
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails.
Do not jump off of the equipment.
Radiological and Environmental Concerns
Environmental radiation monitoring is routinely performed at the Mill at sufficient frequency
(quarterly and semiannually) that any potential impact to the public and or the environment would
be identified. In addition to the environmental air monitoring samples collected continuously at
the Mill and analyzed for radioisotopes U-Nat, Ra-226, Th-230, Th-232 and Pb-210, the air
samples collected during receipt, handling, processing, and disposal of HTC ore will also be
analyzed for Ra-228 and Th-228. The RSO will evaluate the resulting data and compare the results
to their respective effluent concentration limits contained in 10 CFR Part 20, Appendix B, and will
retain records of these evaluations at the Mill for NRC inspection.
7.1 Airborne Radiation Protection
Posting requirements will be determined based on NRC regulations as specified inlO CFR
20.1902.:Air sampling results on the ore pad, will be used to determine the posting requirements
for HTC ore.
1. If the area is above 5 mR/hr, then the area will be posted as a '' Radiation Area''.
2. The area will be posted as an "Airborne Radioactivity Area" if the air sampling is
greater than 25% above the DAC.
3. All personnel involved with material handling during a project involving HTC ore will be
required to wear a full face respirator, until such time that review of the air samples by
the RSO and ALARA committee indicate that this level of protection is not needed.
Employees will be notified of any changes to the respiratory protection requirements
during an HTC project.
a. All individuals who work in areas where there is a likelihood that the airborne
concentration DAC limits for either uranium, radon, thoron or thorium will exceed 25%
of the DAC will be required to wear respiratory protection. As directed by written
communication from the RSO, one of the following respirators will be selected:
i.
ii.
iii.
Full Face Respirator
Powered Air Purifying Respirator
Self Contained Breathing Apparatus (SCBA)
No.: PBL-4 ENERGY FUELS RESOURCES (USA) INC. Page 7 of 7
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, 2000, Title: High Thorium Content Ore Management
Updated July 8, 2020
4. Personal air monitoring will be conducted as per Section 1 of the White Mesa Mill
Radiation Protection Manual and Section 4.2 above.
Continuous air sampling will be conducted around the perimeter of the ore pad. At the
onset of an HTC ore project, sample filters from the continuous air samplers will be
collected and analyzed for gross alpha, Ra-222 and Ra-220 on a weekly basis. This
frequency may be relaxed upon approval of the site RSO and the ALARA Committee.
2. Real time thoron monitors will be placed around the periphery of the ore pad for the
duration of the HTC ore project. These monitors will be changed out according to the
frequency recommended by the manufacturer and analyzed forRa-220 .
7.2 Urinalysis
1. All personnel involved with the dumping, stockpiling or processing of HTC ore and RST's
involved in monitoring described in this SOP will submit a urine sample every two weeks at a
minimum, or at a greater frequency if so directed by the provisions of an RWP. These samples
will be analyzed for uranium and thorium content. Evaluation and corrective actions will be
conducted pursuant to guideline provisions contained in Regulatory Guide 8.22 Bioassay at
Uranium Mills. In vivo lung counting may be implemented if circumstances suggest an
overexposure or uptake of either isotope has occurred. In vivo counting will be conducted at
the discretion of the RSO and ALARA Committee.
7 .3 Personal Hygiene
1. All personnel involved with the dumping, stockpiling or processing of HTC ore will be
required to wear designated coveralls. These coveralls will be changed and laundered on a
daily basis.
2. All personnel involved with the dumping stockpiling or processing of HTC ore will be required
to shower before leaving the restricted area at the end of their shift.
3. All personnel will survey their hands, boots and clothing for surface contamination prior to
eating or leaving the restricted area.
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES Page 1 of3
Date: November Title: KF Carbonate Digest Node
18, 2015
NODE #1
KF Drum Dumping
1. Hazard Assessment
Process Material in Component
Parameter KF Uranium Slurry
Flashpoint, (°F)
TLV -TWA (mg/m3) 2.5
STEL (mg/m3) NL
Radioactivity, pCi/g 5,000
Temperature, °C Amb Amb Amb
Pressure, psig 0-100 0-100
Health Rating 2 3 3
Phase Rating 0 0 1
Quality Rating 3 -3
Radioactive Rating -1 -
Health Rating 5 4 7
A
Assessment Description: This material is very basic and can be very fine. Dusting and
contamination should be avoided REMEMBER KF material is a strong base and can cause
skin and eye burns. KF material is also radioactive and you must follow established health
physics controls. Keep the material wet at all times and if any solution gets on you wash it
off with copious amounts of water.
2. Flowsbeet
3. Operating Instructions
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES Page 2 of 3
Date: November Title: KF Carbonate Digest Node
18,2015
The various types of material in the drums must be closely monitored to make certain that only
KF material is dumped into the circuit
• Get approval from your supervisor to start the circuit
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Tum on the drum dumper, weigh scale and the conveyor belt.
• Read the label to confirm KF material.
• Undo the lid carefully and report any unusual pressure release.
• Weigh and record the drum weight.
• Take a sample of the drum
• Add the appropriate amount of water as per operating instructions.
• Place the drum in the drum dumper.
• Transfer the material to the KF slurry holding tanks as described in the operating
instructions.
• Always keep your area clean and ensure your work area is free of hazardous
obstructions.
• Always read and follow all parameters listed on the SDS.
4. Personal Protective Equipment
Whenever working in, around or on this process circuit YOU MUST wear PPE which
includes at minimum Tyvex coveralls, rubber boots and gloves, eye glasses, face shield and
may include full face respirators. Additional PPE may be required as defined by a Radiation
Work Permit.
5. Mobile Equipment
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of3
Date: November Title: KF Carbonate Digest Node
18,2015
• Only trained and authorized persons may operate mobile equipment.
• All mobile equipment shall be inspected by the operator and any safety defects corrected
before the equipment is used. If safe to do so, the equipment may be driven to the shop
for repairs. Otherwise, the equipment must be towed or repaired at the location.
• Audible backup alarms shall be in operating condition.
• Walk around any piece of equipment before starting or moving it. Make certain no one is
in a dangerous position and there are no obvious defects or hazards.
• Use caution when entering or exiting equipment. Be sure to use the ladders and hand
rails. Do not jump off the equipment.
• Seat belts shall be used at all times when equipment is in motion.
• Equipment shall be operated at a reasonable speed consistent with road and weather
conditions, subject to a maximum speed limit of 15 mph.
• Keep the cabs of equipment clean. Loose items that could jam controls or create other
hazards are not allowed.
• Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your supervisor
has released it.
• All gasoline engines must be shut off when refueling.
• Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms
where required.
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of2
Date: November Title: KF Carbonate Digest Node
18,2015
NODE#2
KF Slurry, Decant and KF Storage
1. Hazard Assessment
Process Material in Component
Parameter KF Uranium KF Storage U in KF Storage
Flashpoint, °F --
TLV-TWA mg/m3 2.5
STEL mg/m3 NL
Radioactivity, pCi/g 5,000
Temperature, °C Amb Amb Amb Amb
Pressure, psig 0-100 0-100 0-100 0-100
Health Rating 3 2 3 3
Phase Rating 1 1 1 1
Quantity Rating 3 -3 -
Radioactive Rating -3 . 1
Hazard Rating 7 6 7 5
Assessment Description: The addition of water to the KF results in a slurry solution that is very
basic, contains fluoride, and is very dangerous. REMEMBER KF material is a strong base
and can cause skin and eye burns. KF material is also radioactive and you must follow
established health physics controls. Keep the material wet at all times and if any solution
gets on you wash it off with copious amounts of water.
2. Flowsheet
3. Operating Instructions
• Get approval from your supervisor to start the circuit. This material will be coming from
the drum dumping station.
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES Page 2 of2
Date: November Title: KF Carbonate Digest Node
18,2015
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Always keep your work area clean and ensure your area is free of hazardous obstructions.
Always read and follow all parameters listed on the SDS. This means that you must read
and understand the information on the SDS and if you don't, ASK YOUR
SUPERVISOR.
• Monitor the tank level and agitation requirements as per operating instructions.
• Make certain a sample is taken when the tank is fu 11 as per operating instructions.
• Confirm that the appropriate chemicals (e.g. water) are added to the tank according to
operating instructions.
• Settle solids by turning off agitator and allowing the solids to drop to the bottom of the
tank. Notify the CCD operator that the decant solution is ready for transfer.
• Set up the decant pump and confirm the solids level is not reached during the decantation
process. This means do not transfer any visible solids as practicable to the CCD unless
instructed by specific operating instruction from the metallurgical department or by your
shift supervisor.
• Notify the CCD operator that the decant solution is ready for transfer.
• If conditions are not at operating parameters, notify your foreman before starting up. This
means that if you determine that there is something unusual about your operating circuit
notify your shift supervisor.
4. Personal Protective Equipment
Whenever working in, around or on this process circuit YOU MUST wear PPE. Additional
PPE may be required as defined by a Radiation Work Permit.
No.: PBL-5 ENERGY FUESL RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: July 1, 2013 Title: KF Carbonate Digest Node
Hazard Assessment Worksheet Node #3
Equipment Component KF Carbonate Digest Node
Individual Equipment No. -
Parameter per Tank Process Material in Component
PFD Na2C03 H202
Quantity in Equipment (lb) 73,500 100
Concentration (%) 11 50
Flashpoint, °F ----
TLV -TWA mg/m.:i
STEL mg/mj
Radioactivity, pCi/g 0 0
Temperature, °C 85°C Amb
Pressure, psig 0 0-20
Health Rating
Health Hazard
Assessment Description: This solution ofNa2C03 will be made up in place in one of the leach tanks
from the dry soda ash in super sacks. All personnel should avoid breathing soda ash dust or any
other contact with the dust from the soda ash. The soda ash is a strong base and can cause chemical
bums. Also, the H20 2 is a powerful oxidizing agent and can rapidly cause chemical bums to
anything it touches. Operators and anyone in the area should wear proper PPE to protect from
these chemicals. In case of any contact, wash the area of contact off with generous amounts of
water.
Steam Steam
Operating Instructions
This node deals with the carbonate digestion of the residue remaining after slurry is KF
solids are washed in the CCD circuit.
• Obtain approval from your supervisor to run the carbonate digestion step of
processing on the slurried solids from CCD.
• Make a safety inspection of all lines and equipment.
fo.: PBL-5
Rev. No.: R-3
Date: July 1, 2013
ENERGY FUESL RESOURCES (USA) INC.
ST AND ARD OPERATING PROCEDURES
Title: KF Carbonate Digest Node
Page 2 of 3
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed on
the MSDS. This means that you must read and understand the information
on theMSDS and if you don 't, ASK YOUR SUPERVISOR.
• Add water to the slurried solids obtained from CCD in one of the leach tanks to
the tank level as instructed by your supervisor, then turn on agitation. Add soda
ash from super sacks to the contents of the leach tank to a Na2C03 concentration
of 100 g/l or as instructed by your supervisor. Add steam to the contents of the
leach tank to a temperature of 80°C, or as instructed by your supervisor. Add any
required hydrogen peroxide to the leach tank as instructed by your supervisor.
• Maintain digestion conditions and agitation in the leach tank for 3 hours or as
instructed by your supervisor.
• Make certain any required sample is taken when the tank agitator is on and the
digestion has been completed.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 ST AND ARD OPERA TING PROCEDURES
Date: June 17, 2013 Title: KF Caustic Precipitation Node
Hazard Assessment Worksheet Node#5
Equipment Component
Individual Equipment No.
KF Caustic Precipitation Node
Page 1 of 3
Parameter per Tank Process Material in Component
PFD Uranium Sodium NaOH
Carbonate
Quantity in Equipment (lb) 3,500 85,000 14,500
Concentration (%) 11 50
Flashpoint, °F ------
TLV-TWA ppm
STEL oom
Radioactivity, pCi/g
Temperature, °C 70 70 Amb
Pressure, psig 0-20 0-20 0-20
Health Rating
Health Hazard
Assessment Description: A uranium-rich precipitate is formed by N aOH addition to the
solution from the carbonate digestion of the KF water leach residue in this processing
step. The liquid in the tank is strongly basic. Any splashing or contact with the skin
should be avoided. These materials can cause skin and eye burns. The solution and
the precipitate that is formed are also radioactive and you must follow established
health physics controls. If any of the solution or precipitate gets on you, wash it off
with generous amounts of soap and water.
NaOH NaOH
Decant to
TailingsCell 1
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: June 17, 2013 Title: KF Caustic Precipitation Node
Operating Instructions
This node deals with formation of a uranium-rich precipitate by addition of
NaOH to thecarbonate leached slurry ..
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Maintain agitation of the carbonate leach slurry and shut off steam.
• Make sure you are wearing all appropriate PPE for handling 50%
NaOH (caustic) solution.
• To the agitated contents of the precipitation tank carefully add 50%
NaOH (caustic) solution until the pH of the contents of the tank
reaches at least 13.0 or as instructed by your supervisor. Measure the
pH of the tank contents with pH paper obtained from the lab. Do not
measure the pH using an ordinary pH meter and probe -these may not
give correct pH readings in this solution.
• After the contents of the tank reach the target pH, continue for about 4
hours to agitate the tank contents at the target temperature and
continue to carefully add small volumes of the 50% NaOH solution to
the tank as necessary to maintain the target pH or as instructed by your
supervisor.
• After aboutan hour, the precipitation reaction should be complete.
Verify that the precipitation of uranium is complete by taking a sample
of the agitated slurry and analyzing an aliquot of the filtered solution
for U308. If the concentration ofU308 is at or below a designated
concentration specified by your supervisor the precipitation may be
considered complete. At this point add to the slurry in the
precipitation tank the amount of flocculant (Hychem 314) as instructed
by your supervisor. Maintain agitation briefly after flocculant addition
to mix the flocculant into the contents of the tank. Then tum off
agitation and allow the solids to settle to the bottom of the tank.
• Once solids in the leach tank have settled sufficiently, operate the
decant pump and transfer the clear solution from the top of the tank to
tailings as instructed by your supervisor. Make sure that none of the
settled solids are transferred with the clear solution during the
decantation process.
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: June 17, 2013 Title: KF Caustic Precipitation Node
• After decanting all possible clear solution from the leach tank, add
water and repulp and wash the precipitate solids in the leach tank, as
instructed by your supervisor. Following the repulp and wash, add
flocculant and settle the solids and decant the clear solution to tailings
as instructed by your supervisor. Make sure that none of the settled
solids are transferred with the clear solution during the decantation
process. Repeat this repulp and wash step as needed as instructed by
your supervisor.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: June 17, 2013 Title: KF Acid Re-Dissolve Node
Hazard Assessment Worksheet Node #6
Equipment Component
Individual Equipment No.
Parameter per Tank
PFD
Quantity in Equipment (lb)
Concentration(%)
Flashpoint, °F
TLV-TWA ppm
STEL ppm
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Health Hazard
KF Acid Re-Dissolve Node
Process Material in Component
Uranium Sulfuric Acid
3,500 3,400
93
----
0
25-40 25-40
0-20 0-100
Assessment Description: The re-pulped basic uranium-rich precipitate and the acidic
solution in which it will be re-dissolved should be handled with caution. Any splashing or
contact with the skin should be avoided. The acidic chemicals in the liquid can cause
skin and eye burns. The solution and the filter cake are also radioactive and you
must follow established health physics controls. If any of the solution or filter cake
gets on you, wash it off with generous amounts of soap and water.
#6 Leach
Tank
#7 Leach
Tank
ToNormalSX
and Yellowcake
Production
Solids to
Tails
No.: PBL-5 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: June 17, 2013 Title: KF Acid Re-Dissolve Node
Operating Instructions
This node deals with the acid re-dissolution of re-pulped uranium-rich solids.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Inspect valves and fittings in the acid line.
• Add water to the settled uranium-rich solids in the bottom of the leach
tank to the level as instructed by your supervisor. Tum on agitation in
the tank as soon as the level is sufficient according to your
supervisor's instructions.
• Carefully add sulfuric acid to the agitated repulped solids to bring the
pH of the slurry to 0.8 or another pH as instructed by your supervisor.
• Agitate the slurry in the tank at the target pH for a time of at least one
hour as instructed by your supervisor, adding sulfuric acid as needed to
maintain the pH at 0.8.
• After the acid-redissolved step is complete add flocculant (Hychem
655) to the agitated solids as instructed by your supervisor. Maintain
agitation briefly after flocculant addition to mix the flocculant into the
contents of the tank. Then turn off agitation and allow the solids to
settle to the bottom of the tank. Once the solids in the leach· tank have
settled sufficiently, operate the decant pump and transfer as much of
the clear solution as possible from the top of the tank to a designated
holding tank. Make sure that none of the settled solids are transferred
with the clear solution during the decantation process.
• After decanting all possible clear solution from the leach tank, add
water and repulp and wash the solids in the leach tank, as instructed by
you supervisor. Following the repulp and wash, add flocculant and
settle the solids and decant the clear solution a designated holding
tank. Repeat this repulp and wash step as needed as instructed by your
supervisor. The solution in the holding tank can then be transferred as
needed to the SX circuit to be combined with the feed stream into
normal SX processing and other downstream yellowcake production as
described in existing SOPs.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which may include hard hat, coveralls, rubber boots and gloves, safety
glasses with side shields, and whatever level of respiratory protection
No.: PBL-5
Rev. No.: R-3
Date: June 17, 2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 3 of 3
Title: KF Acid Re-Dissolve Node
is deemed appropriate by the Radiation Safety Officer, and may
include a face shield or safety goggles.
No.: PBL-7 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERA TING PROCEDURES Page 1 of 4
Date: April 1, 2014 Title: Mill Waste Disposal
1. Purpose
License Condition 10.4 authorizes disposal of material and equipment ("Mill Waste")
generated at the White Mesa Mill (the "Mill"). The following procedure applies to
disposal of Mill Waste at the Mill. This procedure may be amended, subject to approval
by Energy Fuels Resources (USA) Inc. 's ("EFR's") Safety and Environmental Review
Panel (SERP).
2. Disposal Site
The disposal area for Mill Waste comprises approximately 10 acres in tailings Cell 3 and
is shown as the shaded area on the attached Figure 1.0.
The disposal area is composed of coarse tailings material deposition, providing adequate
cover over the liner to prevent liner rupture. Disposal will occur in those areas in the
designated disposal area where the elevation is significantly below the final deposition
elevation of 5 615 feet.
3. Mill Waste Authorized for Disposal
Mill Waste includes all non-tailings wastes generated at the Mill site. Some examples of
Mill Waste are:
• All trash from office buildings and plant buildings, which includes all typical
trash items as well as such things as light bulbs, NiCd batteries, discarded office
equipment, etc;
• Discarded Mill equipment, including mobile equipment, pumps, structural tanks,
structural steel, piping, rubber tank liners, conveyor belting etc.;
• Rubber (seals, gaskets, pump liners);
• Wood items;
• Product, feed and reagent drums, crushed to eliminate void spaces;
• Wastes generated by the Radiation Safety Department (e.g., filters, bioassay
containers, etc.);
• Wastes generated by the Mill's laboratory;
• Discarded clothing and respirator cartridges generated within the Mill;
• Debris from conventional ores and alternate feed materials;
• Clean up materials from spills or other on-site or offsite contamination generated
from Mill activities; and
• Any other waste materials generated within the Mill site boundary and
surrounding property in connection with Mill activities.
No.: PBL-7 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERA TING PROCEDURES Page 2 of 4
Date: April l, 2014 Title: Mill Waste Disposal
4. Placement and Covering of Mill Waste
4.1. Placement
Mill Waste will be placed in the designated disposal area and compacted in a manner to
minimize void spaces and nesting and to enhance compaction, as follows:
(a) Mill Waste will be placed at the edge of the tailings Cell cover, where the
cover ends and the beaches begin. The Mill Waste will then be pushed over
the edge of the tailings Cell cover where the tailings beaches begin;
(b) Heavy items, or those with sharp or protruding surfaces, will be placed in an
area of the cell containing a sufficient thickness of deposited tailings to ensure
that no damage will occur to the Cell's liner and drain system;
(c) The maximum lift thickness for Mill Waste placed over tailings shall be 4-feet
thick. Subsequent lifts shall be less than 2-feet thick;
( d) Each lift will be compacted by tracking of heavy equipment, such as a Cat D-6,
at least 4 times prior to placement of subsequent lifts;
(e) All Mill Waste with void spaces will be crushed, filled or sectioned in an effort
to minimize these void spaces and to enhance compaction;
(f) All equipment shall be dismantled, crushed, or sectioned as required to
minimize void spaces. Solid metals, concrete, masonry, and wooden members
will be cut into pieces no greater than 10-feet long and no more than 27 cubic
feet in volume. Structural steel members, pipe and other long items will be cut
or broken into 10-foot lengths or smaller;
(g) Large structural tanks will be dismantled or filled with tailings solids to
minimize void spaces. Large structural tanks that are not dismantled will
require written approval by the Mill Manager or Radiation Safety Officer, prior
to disposal;
(h) Barrels containing waste other than soil or similar material shall be emptied
into the disposal area and the barrels crushed. Barrels containing soil or
similar material shall be verified to be full prior to disposal. Barrels not
completely full shall be filled with tailings or soil. All empty barrels shall be
crushed prior to placement;
(i) To the extent necessary to minimize the migration of waste, small items such
as coveralls, office waste, and other lightweight materials will be placed in
plastic trash bags or other containers. These plastic bags or other containers
will then be disposed of in layers with the rest of the materials; and
No.: PBL-7 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of 4
Date: April 1, 2014 Title: Mill Waste Disposal
(j) If necessary, random fill or tailings will be used to fill voids in and around the
Mill Waste.
4.2. Covering
Random fill cover will be advanced along the disposal areas as needed, to minimize the
migration of Mill Waste. The random fill will be taken from stockpiles at the site, and
will contain varying sizes of rocks intermixed with soil. The waste and cover material
will be compacted with at least one pass of the construction equipment. The disposal
area will be considered full when the entire disposal site reaches the final authorized
tailings deposition elevation of 5615 feet. The disposal area will then be covered with an
interim random fill cover in the same manner as other areas of the tailings cell once the
final tailings deposition elevation is reached in those other areas.
5. Inspections and Documentation
The Mill Waste disposal area will be inspected on a daily basis during daily tailings
inspections, in order to ensure that the materials are sized and disposed of properly. Any
observations of concern will be noted on the daily tailings inspection forms.
If no observations of concern are noted during the daily inspections, the weekly tailings
inspection form will document any unusual conditions of the disposal areas each week.
6. Hazard Identification and Safety
The following safety procedures apply to all activities covered by this SOP:
6.1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed
shoes are required at a minimum. These must be worn in the restricted area of the Mill.
6.2. Industrial Hazards and Safety
(a) Use caution when any trailers are backing to the disposal area.
(b) Ensure that all personnel within 50 feet of the area where an end dump trailer
is about to dump its load are aware that unloading is about to commence.
Move at least 25 feet away from the rear of the trailer during the initial
unloading operation.
(c) Drivers must use caution during the unloading process and be aware of any
overhead hazards.
No.: PBL-7 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERA TING PROCEDURES Page 4 of 4
Date: April 1, 2014 Title: Mill Waste Disposal
( d) Do not place any part of your body inside the trailer when the trailer is being
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
(e) Use caution when entering or exiting equipment. Be sure to use the ladders
and hand rails. Do not jump off the equipment.
(f) Always use a ladder when entering and/or exiting the interior of a trailer.
6.3. Mobile Equipment
(a) Only trained and authorized persons may operate mobile equipment.
(b) All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be
driven to the shop for repairs. Otherwise, the equipment must be towed or
repaired at the location.
(c) Audible backup alarms shall be in operating condition.
( d) Walk around any piece of equipment before starting or moving it. Make
certain no one is in a dangerous position and there are no obvious defects or
hazards.
(e) Use caution when entering or exiting equipment. Be sure to use the ladders
and hand rails. Do not jump off the equipment.
(f) Seat belts shall be used at all times when equipment is in motion.
(g) Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed limit of 15 mph.
(h) Keep the cabs of equipment clean. Loose items that could jam controls or
create other hazards are not allowed.
(i) Report all accidents to your supervisor regardless of how minor they are. If
property damage or personal injury is involved, do not move the equipment
until your supervisor has released it.
G) All gasoline engines must be shut off when refueling.
(k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain
adequate berms where required.
No.: PBL-9 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4 STANDARD OPERATING PROCEDURES Page I of 6
Date: December 18, Title: End Dump Trailer Acceptance, Handling & Release
2018
1.0 Purpose
The following procedure applies to acceptance, handling, and release of end dump trailers
at the White Mesa Mill (the "Mill"). Energy Fuels Resources (USA) Inc. ("EFR")
receives material for processing, in either bulk or non-bulk packaging. This procedure
addresses one form of bulk packaging -end dump trailers. This procedure may be
amended, subject to approval by EFR's Safety and Environmental Review Panel (SERP),
from time to time as appropriate to address the individual requirements of specific feed
materials, or projects.
2.0 Ore Receiving
1. Check truck scale for zero balance at the beginning of each shift.
2. When each truck driver enters the Restricted Area for the first time, the Scale
house operator will provide hazard training for the driver. The driver will be
provided with the Safety Training Form ( copy attached). All drivers will be
required to read the Safety Training Form and sign and date the Safety Training
Form indicating that they understand and agree to follow EFR's safety rules and
procedures while on company property. The Scale house operator will sign the
Safety Training Form as the instructor for EFR. Completed Safety Training
Forms will be turned in to the Safety Department for future reference.
3. Inspect all copies of the Bill of Lading (BOL) to ensure that the shipment is
destined for the Mill and that all shipping documentation is in order (see Section
8.2). If any discrepancies are noted notify the Mill management
immediately. Do not empty the end dump trailer until all paperwork
discrepancies are corrected.
4. Assign next available shipment number and Mill load number to the inbound
shipment. Record the Mill load number, inbound date and both the truck and end
dump trailer numbers on the Scale house Weight Ticket (SWT).
5. Enter the loaded weight of the end dump truck and trailer on the SWT.
3.0 Ore Unloading
1. After weighing the truck and trailer, direct the driver to the specified ore storage
pad area where the material will be unloaded. Prior to unloading the tarp is
inspected for damage and then removed, if necessary. The driver is then directed
to unload the material, ensuring all personnel are clear of the trailer and the
immediate area.
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No.: PBL-9 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4 STANDARD OPERATING PROCEDURES Page 2 of 6
Date: December 18, Title: End Dump Trailer Acceptance, Handling & Release
2018
2.
3.
4.
5.
4.0
After unloading the material replace the tarp, unless the trailer is being
decontaminated for unrestricted release.
After the tarp has been replaced on the trailer, direct the driver back to the scales
for an empty weight.
Record the empty weight on the appropriate SWT.
Use a front-end loader or similar equipment to push material into the designated
ore lot pile.
Decontamination and Release of End Dump Trailers and Tmcks
All trailers and trucks will be decontaminated after unloading prior to leaving the
Mill. Shippers or transporters will notify EFR whether a specific trailer is to be released
for restricted or unrestricted use. Any trailers that are to be released for restricted use
will be decontaminated according to the requirements contained in DOT Part 49 CFR
173.428 or 173.443. Any trailers that are to be released for unrestricted use will be
decontaminated according to the requirements found in Table 2 of the Nuclear
Regulatory Commission's (NRC's) Regulatory Guide 8.30 Rev. 1 "Health Physics
Surveys in Uranium Recovery Facilities" or NRC document "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued
April 1993. Trailers requiring repair will be decontaminated for unrestricted release, to
facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired
without undergoing full decontamination if repaired within the restricted area of the Mill.
5.0 Decontamination and Release of Equipment for Restricted Use
1. After the tarp has been replaced on the trailer and the empty weight obtained, the
driver will be directed to the decontamination pad.
2. Decontaminate the exterior of each trailer, truck and tires thoroughly, using a
high-pressure water wash.
3. After the truck and trailer are decontaminated, the driver will be directed to the
gate, along the decontamination route. The decontamination route is a graveled
roadway specifically designed for decontaminated equipment to exit the
Restricted Area. If it becomes necessary due to environmental conditions or
residual mud in the tires etc., direct the driver to proceed along the
decontamination route to the secondary wash station. Wash any visual residual
mud off of the tires, or exterior surface of the truck and trailer. Otherwise, direct
the driver to proceed along the decontamination route to the tertiary
decontamination and final scanning area.
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No.: PBL-9 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4 STANDARD OPERATING PROCEDURES Page 3 of 6
Date: December 18, Title: End Dump Trailer Acceptance, Handling & Release
2018
4. Contact a Radiation Technician to perform a radiological contamination survey
for restricted release of the truck and trailer. If the Radiation Technician indicates
areas on the truck or trailer that require further decontamination, decontaminate
those areas as necessary.
5.
6.
7.
8.
9.
6.0
1.
2.
The Radiation Technician or RSO will scan the trailer, truck, and tires in various
locations as shown on the Equipment Survey for Restricted Release ( copy
attached) and document the scan readings on the Equipment Survey for Restricted
Release. The contamination survey will be performed using appropriate
radiological instrumentation for total activity in accordance with DOT
transportation regulations. The release standards to be met for restricted release
are contained in U.S. Department of Transportation (DOT) Part 49 CFR 173.428
or 173.443 (copies attached).
If the trailer, truck or tires do not meet the radiological release survey
requirements or shows visually observable contamination, the truck and trailer
will either be returned to the secondary decontamination pad for further
decontamination or will be washed again at the tertiary decontamination area.
The Radiation Technician or RSO will fill out the Equipment Survey for
Restricted Release form (copy attached) to document that the truck and trailer has
been authorized for release for restricted use. These forms are filed in the
Radiation Department. The Radiation Technician or RSO will place a white
sticker on the trailer that says, "EMPTY".
After a truck and trailer have been released, the driver will perform a visual
inspection of the truck, trailer and tires.
Leaving his truck outside of the Restricted Area, the driver will return to the Scale
House to pick up the documentation for the empty trailer.
Decontamination and Release of Equipment for Unrestricted Use
After the empty weight of the trailer has been obtained, the driver will be directed
to the decontamination pad. The tarp will not be replaced on the trailer or, if
necessary, the tarp shall be removed.
Open the trailer tailgate, elevate the trailer ensuring that there are no overhead
hazards and decontaminate the trailer using a high-pressure water wash. Make
sure to thoroughly wash the inside and outside of the trailer. The truck and tires
shall also be washed.
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No.: PBL-9 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4 STANDARD OPERATING PROCEDURES Page4 of6
Date: December 18, Title: End Dump Trailer Acceptance, Handling & Release
2018
3. After the truck and trailer are decontaminated, the driver is directed to follow the
decontamination route. The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the Restricted Area.
If it becomes necessary due to environmental conditions or residual mud in the
tires etc., the driver is instructed to proceed along the decontamination route to the
secondary wash station. Wash any visual residual mud off of the tires, or exterior
surface of the container. Otherwise, the driver is instructed to proceed along the
decontamination route to the tertiary decontamination and final scanning area.
4. Contact a member of the Radiation Department staff to conduct the appropriate
radiological survey for unrestricted release of the truck, trailer and tires. The
release standards to be met for unrestricted release are contained in Table 2 of the
Nuclear Regulatory Commission's (NRC's) Regulatory Guide 8.30 Rev 1 "Health
Physics Surveys in Uranium Recovery Facilities" dated May 2002, or NRC
document "Guidelines for Decontamination of Facilities and Equipment Prior to
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source,
or Special Nuclear Material" dated April 1993. The RSO will prepare a
memorandum detailing the applicable standard on Table 1 for each project. The
RSO will also provide the training of the Radiation Technicians required.
5. The Radiation Technician will perform a radiological contamination survey of the
truck and trailer. If the Radiation Technician indicates areas that require further
decontamination, decontaminate those areas as necessary.
6. If the truck, trailer and tires meet the radiological release survey and visual
inspection requirements, the Radiation Technician will place a red sticker on the
trailer that says, "THIS CONTAINER HAS BEEN FULLY
DECONTAMINATED AND SURVEYED FOR "UNRESTRICTED USE" BY:
(FILL IN NAME OF RADIATION TECHNICIAN)". The RSO or Radiation
Technician that performed the release survey will then sign the red sticker and
date it. In addition, the RSO or Radiation Technician will fill out a
Decontamination Final Release Form (copy attached) to document that the truck
and trailer have been cleared for unrestricted release. The Decontamination
Release Form will be turned in to the Mill Administration Office daily for filing
and distribution.
7. After a truck and trailer have been released, the driver will do a visual inspection
of the truck and trailer.
8. Leaving his truck outside of the Restricted Area, the driver will return to the Scale
House to pick up the documentation for the empty trailer.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-9 End Dump\Clean Rev 4\PBL-9 End Dump SOP Rev
4.doc
No.: PBL-9 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4 STANDARD OPERATJNG PROCEDURES Page 5 of 6
Date: December 18, Title: End Dump Trailer Acceptance, Handling & Release
2018
7.0 Hazard Identification and Safety
7 .1 Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required at a minimum. These must be worn in all areas of
the Mill with the exception of the Administration Building.
7 .2 Industrial Hazards and Safety
1. Use caution when the trailers are backing onto the Ore Pad.
2. Ensure that all personnel within 50 feet of the area where the end dump trailer are
aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
3. Drivers must use caution during the unloading process and be aware of any
overhead hazards.
4. Do not place any part of your body inside the trailer when the trailer is being
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
5. Be aware of high-pressure wash water.
6. Be aware of slippery conditions on the ore pad during periods of inclement
weather.
7. Be aware of the potential for ice build-up on and around the decontamination pad
during periods of cold weather.
8. Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off of the equipment.
9. Always use a ladder when entering and/or exiting the interior of an end dump
trailer.
8.0 Paperwork Tracking
1. Each trailer will have a unique sequential project number assigned to it at the
generating facility. This number will be entered onto the Bill of Lading (BOL)
and attached to the trailer prior to shipment from the generation site.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-9 End Dump\Clean Rev 4\PBL-9 End Dump SOP Rev
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No.: PBL-9 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4 STANDARD OPERA TING PROCEDURES Page 6 of 6
Date: December 18, Title: End Dump Trailer Acceptance, Handling & Release
2018
2. Upon arrival at the Mill, the truck driver will turn in all of his/her paperwork to
the DOT Transportation expert who will verify that the BOL number, trailer
number and project number assigned to the shipment match on all copies of the
BOL. The DOT Transportation expert will also verify that the actual trailer
number matches the BOL Trailer Number. If there are any discrepancies in
any of the numbers notify Mill management immediately. Only original
paperwork will be accepted. If the original paperwork does not come with the
trailer, notify Mill management immediately. The DOT Transportation expert
will sign the BOL, acknowledging receipt of the material at the Mill, if all of the
paperwork is in order. Depending on contractual and/or sampling requirements,
final acceptance or rejection of certain alternate feed materials may be contingent
on analytical results.
3. Each trailer will be transported across the scale at the Mill prior to and after being
unloaded. The appropriate information will be entered into the project database.
All copies of the SWTs and BOLs will be forwarded to the Mill Records Manager
on a daily basis or other frequency specified by Mill Management, from time to
time.
4. The Mill Records Manager will compile and reconcile the BOL' s and SWTs for
distribution.
W:\Environmental\SOP\Book 10 -PBL\2018\PBL-9 End Dump\Clean Rev 4\PBL-9 End Dump SOP Rev
4.doc
ELECTRONIC CODE OF FEDERAL REGULATIONS
e-CFR data is current as of December 6, 2018
Title 49 -, Subtitle B -, Chapter I -> Subchapter C -> Part 173 -> Subpart I -> §173.428
Title 49: Transportation
PART 173-SHIPPERS-GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
Subpart I-Class 7 (Radioactive) Materials
§173.428 Empty Class 7 (radioactive) materials packaging.
A packaging which previously contained Class 7 (radioactive) materials and has been emptied of contents as far as
practical, is excepted from the shipping paper and marking (except for the UN identification number marking requirement
described in §173.422(a)) requirements of this subchapter, provided that-
(a) The packaging meets the requirements of §173.421 (b), (c), and (e) of this subpart;
(b) The packaging is in unimpaired condition and is securely closed so that there will be no leakage of Class 7 (radioactive)
material under conditions normally incident to transportation;
(c) The outer surface of any uranium or thorium in its structure is covered with an inactive sheath made of metal or some
other substantial material;
(d) Internal contamination does not exceed 100 times the limits in §173.443(a);
(e) Any labels previously applied in conformance with subpart E of part 172 of this subchapter are removed, obliterated, or
covered and the "Empty" label prescribed in §172.450 of this subchapter is affixed to the packaging; and
(f) The packaging is prepared for shipment as specified in §173.422.
[Arndt. 173-244, 60 FR 50307, Sept. 28, 1995, as amended by Arndt. 173-244, 61 FR 20752, May 8, 1996; 64 FR 51919, Sept. 27, 1999;
69 FR 3677, Jan. 26, 2004; 80 FR 72928, Nov. 23, 2015]
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ELECTRONIC CODE OF FEDERAL REGULATIONS
e-CFR data is current as of December 6, 2018
Title 49 ----> Subtitle B ----> Chapter I ----> Subchapter C ----> Part 173 ----> Subpart I ----> §173.443
Title 49: Transportation
PART 173-SHIPPERS-GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
Subpart I-Class 7 (Radioactive) Materials
§173.443 Contamination control.
(a) The level of non-fixed contamination must be kept as low as reasonably achievable on the external surfaces of each
package, conveyance, freight container, and overpack offered for transport, and the internal surfaces of each conveyance,
freight container, and overpack in which inner packages or receptacles of Class 7 (radioactive) materials are offered for
transport.
(1) Excluding the interior surfaces of the containment system of packages and the internal surfaces of a conveyance,
freight container, tank, or intermediate bulk container dedicated to the transport of unpackaged radioactive material in
accordance with §173.427(c) and remaining under that specific exclusive use, the level of non-fixed contamination may not
exceed the limits set forth in Table 9 and must be determined by either:
(i) Wiping an area of 300 cm2 of the surface concerned with an absorbent material, using moderate pressure, and
measuring the activity on the wiping material. Sufficient measurements must be taken in the most appropriate locations to yield
a representative assessment of the non-fixed contamination levels. The amount of radioactivity measured on any single wiping
material, divided by the surface area wiped and divided by the efficiency of the wipe procedure (the fraction of non-fixed
contaminatlon transferred from the surface to the absorbent material), may not exceed the limits set forth in Table 9 at any time
during transport. For this purpose the actual wipe efficiency may be used, or the wipe efficiency may be assumed to be 0.1 O; or
(ii) Alternatively, the level of non-fixed contamination may be determined by using other methods of equal or greater
efficiency.
(2) A conveyance used for non-exclusive use shipments is not required to be surveyed unless there is reason to suspect
that it may exhibit contamination.
Table 9 is as follows:
TABLE 9-NON-FIXED EXTERNAL RADIOACTIVE CONTAMINATION LIMITS FOR PACKAGES
Maximum porm/sslble limits
Contaminant Bolcm2 uC/lcm2 dnmlcm2
1. Beta and gamma emitters and low toxicity alpha emitters 4 10-• 240
2. All other alpha emitting radionuclides 0.4 10-5 24
(b) In the case of packages transported as exclusive use shipments by rail or public highway only, except as provided in
paragraph {d) of this section, at any time during transport the non-fixed contamination on the external surface of any package,
as well as on the associated accessible internal surfaces of any conveyance, overpack, or freight container, may not exceed ten
times the levels prescribed in paragraph (a) of this section. The levels at the beginning of transport may not exceed the levels
prescribed in paragraph (a) of this section.
(c) Except as provided in paragraphs (a) and (d) of this section, each conveyance, overpack, freight container, tank, or
intermediate bulk container used for transporting Class 7 (radioactive) materials as an exclusive use shipment that utilizes the
provisions of paragraph (b) of this section, §173.427(b)(4), or §173.427(c) must be surveyed with appropriate radiation
detection instruments after each exclusive use transport. Except as provided in paragraphs (a) and (d) of this section, these
items may not be returned to Class 7 (radioactive) materials exclusive use transport service, and then only for a subsequent
exclusive use shipment utilizing one of the above cited provisions, unless-the radiation dose rate at each accessible surface is
0.005 mSv per hour (0.5 mrem per hour) or less, and there is no significant non-fixed surface contamination as specified in
paragraph (a) of this section. The requirements of this paragraph do not address return to service of items outside of the above
cited provisions.
(d) Paragraphs (b) and (c) of this section do not apply to any closed transport vehicle used solely for the exclusive use
transportation by highway or rail of Class 7 (radioactive) material with contamination levels that do not exceed ten times the
levels prescribed in paragraph (a) of this section if-
(1) A survey of the interior surfaces of the empty vehicle shows that the radiation dose rate at any point does not exceed
0.1 mSv/h (10 mrem/h) at the surface or 0.02 mSv/h (2 mrem/h) at 1 m (3.3 feet) from the surface;
(2) Each vehicle is marked (e.g. stenciled) with the words "For Radioactive Materials Use Only" in letters at least 76
millimeters (3 inches) high in a conspicuous place on both sides of the exterior of the vehicle; and
(3) Each vehicle is kept closed except for loading or unloading; and
(4) Each vehicle is placarded in accordance with subpart F of part 172 of this subchapter.
(e) If it is evident that a package of radioactive material, or conveyance carrying unpackaged radioactive material, is
leaking, or if it is suspected that the package, or conveyance carrying unpackaged material, may have leaked, access to the
package or conveyance must be restricted and, as soon as possible, the extent of contamination and the resultant radiation
level of the package or conveyance must be assessed. The scope of the assessment must include, as applicable, the package,
the conveyance, the adjacent loading and unloading areas, and, if necessary, all other material which has been carried in the
conveyance. When necessary, additional steps for the protection of persons, property, and the environment must be taken to
overcome and minimize the consequences of such leakage. Packages, and conveyances carrying unpackaged material, which
are leaking radioactive contents in excess of limits for normal conditions of transport may be removed to an interim location
under supervision, but must not be forwarded until repaired or reconditioned and decontaminated, or as approved by the
Associate Administrator.
[79 FR40616, July 11, 2014]
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I
GUIDELINES FOR DECONTAMINATION OF FACil.ITIES AND EQUIPMENT
PRIOR TO RELEASE FOR UNRESTRICTED USE
OR TERMINATION OF LICENSFS FOR BYPRODUCT, SOURCE,
· OR SPECIAL NUCLEAR MATERIAL
. .,
"'i .• ~,
U.S. Nuclear Regulatory Commission
Division of Fuel Cycle, Medical, Academic,
and Commercial Use Safety
Washington, DC 20555
April 1993
, 1';"'1•• ... ,
/
l
The instructions in this guide, in conjunction with Table 1, specify the
radionuclides and radiation exposure rate limits which should be used in
decontamination and survey of surfaces or premises and equipment prior to
abandonment or release for unrestricted use. The limits in Table I do not
apply to premises, equipment, or scrap containing induced radioactivity for
which the radiological considerations pertinent to their use may be
different. The release of such facilities or items from regulatory control is
considered on a case-by-case basis. ·-
1. The licensee shall make a reasonable effort to eliminate residual
contamination.
2. Radioactivity on equipment or surfaces shall not be covered by paint,
plating, or other covering material unless contamination levels, as
detennined by a survey and documented, are below the limits specified in
Table I prior to the application of the covering. A reasonable effort
must be made to minimiz.e the contamination prior to use of any covering.
3. The radioactivity on the interior surfaces of pipes, drain lines; or
ductwork shall be determined by making measurements at all traps, and
other appropriate access points, provided that c.ontaminatioo at these .
locations is likely to be representative of contamination on the interior
of the pipes, drain lines, or ductwork. Surfaces of premises, equipment,
or scrap which are likely to be contaminat.ed but are of such size,
construction, or location as to make the surface inaccessible for purposes
of measurement shall be presumed to be contaminated in excess of the limits.
4. Upon request, the Commission may authorize a licensee to relinquish .
possession or control of premises, equipment, or scrap having surfaces
contaminated with materials in excess of the limits specified. This may
include, but would not be limited to, special circwnstaoces such as razing
of buildings, transfer of premises to another organization continuing work
with radioactive materials, or conversion of facilities to a long-term
storage or standby status. Such requests must:
a. Provide detailed, specific information describing the premises,
equipment or scrap, ~oactive contaminants, and the nature, extent
and degree of residual· surface c.ontamination.
b. Provide a detailed health and safety analysis which reflects that the
residual amounts of materials on surface areas, together with other
considerations such as prospective use of the premises, equipment,
or scrap, are unlikely to result in an unreasonable risk to the health
and safety of the public.
1 0iti~
)
2
5. Prior to release of premises for unrestricted use, the licensee shall
make a comprehensive radiation survey whi,ch establishes that contamination is
within the limits specified in Table 1. A copy· of the survey report shall be
filed with the Division of Fuel Cycle Safety and Safeguards, U.S. Nuclear
Regulatory Commission, Washington, D.C. 20555, and also the Administrator
of the NRC Regional Office having jurisdiction. The reports should be filed at
least 30 days prior to the planned date of abandcmment The survey report shall:
a. Identify the premises.
b. Show that reasonable effort has been made to eliminate residual
contamination.
c. Describe the scope of the survey and general procedures followed,
d. State the findings of the survey in units specified in the
instructions.
Following review of the report, the NRC will consider visiting the
facilities to confirm the survey.
,1:1,tl
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I
i J .... · .. t::. ~
... :.:J
NUCUDES"
U-nat, U-235, U-238, and
associated decay products
Transuranics, Ra-226, Ra-228,
Th-230, Th-228, Pa-231, Ac-227,
1-125, 1-129
Th-nat, Th-232, Sr-90, Ra-223,
Ra-224, U-232, 1-126, 1-131,
1-133
Beta-gamma emitters (nuclides
with decay modes other than
alpha emission or spontaneous
fission) except Sr-90 and
others noted above.
TABLE 1
ACCEPTABLE SURFACE CONTAMINATION LEVELS
A VERA GE"• 1 MAXIMUMbdr
5,000 dpm cx/100 cm2 15,000 dpm odlOO cm2
100 dpm/100 cm1 300 dpm/100 cm2
1,000 dpm/100 cm2 3,000 dpm/100 cm2
5,000 dpm fJ'Y/100 cm2 15,000 dpm f3'Y/100 cm2
REMOVABLEb•I
1,000 dpm cx/100 cm2
20 dpm/100 cm2
200 dpm/100 cm1
1,000 dpm fJ'Y/100 cm2
Where surface contamination by both alpha-and beta-gamma-emitting nuclides exists, the limits established for alpha-and beta-gamma-emitting
nuclides should apply independently.
'
As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as detennined by correcting the counts per
minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be
derived for each such object.
The maxim~ contamination level applies to an area of not more than ·100 cm2•
The amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with dcy filter or soft absorbent
paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrw:nent of known efficiency.
When n.movable contamination on objects of less surface area is determined, the pertinent levels should be reduced pro~rtionally and the entire
-surface should be wiped.
The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad/hr at
1 cm and 1.0 mrad/hr at 1 cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber .
------------------------------------------
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 ST AND ARD OPERATING PROCEDURES Page 1 of 13
Date: February 1, Title: 11 e.(2) Byproduct Disposal
2018
1.0 Purpose
Energy Fuels Resources (USA) Inc. ("EFR") receives l le.(2) byproduct material ("byproduct
material") from uranium in-situ leach operations for disposal under License Condition 10.5. The
following procedure applies to acceptance, handling, and disposal of byproduct material at the White
Mesa Mill (the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
his designee, prior to shipment to the Mill. The byproduct material must conform to Titles 1 O and 49
of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct
material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act
("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of
the shipment at the Mill, and shall include:
1. The volume of material in cubic feet or yards, or quantity of drums and their size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
4. Results of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which
is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the
anticipated shipping date.
The Environmental Coordinator or their designee will verify, prior to receipt of any shipment of
byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the
limit of 5,000 cubic yards of byproduct material from a single source, set out in Mill License condition
10.5A
3.0 Designated Disposal Area
The Environmental Coordinator, or their designee will designate from time to time one or more
designated disposal areas ( each a "Designated Disposal Area") being a general area within a tailings
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 2 of 13
Date: February 1, Title: l le.(2) Byproduct Disposal
2018
cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following
criteria:
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that the elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
c) Each disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells 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;
7. ISL wastes will be disposed in cells that have received prior written approval from the Director
for this purpose.
8. Prior written approval must have been obtained from the Director of the Utah Radiation
Control Board (the "Director") for each Designated Disposal Area, under Mill License
condition 10.5C, and evidence of such approval must be on file at the Mill.
9. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 ST AND ARD OPERATING PROCEDURES Page 3 of 13
Date: February 1, Title: 11 e.(2) Byproduct Disposal
2018
4.0 Notification to Director
EFR shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date
for disposal of any byproduct material. Written evidence of this notification will be kept on file at the
Mill.
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
EFR's safety rules and procedures while on company property. The scale house operator will
sign the Safety Training Form as the instructor for EFR. Completed Safety Training Forms
will be turned in to the Safety Department for future reference.
2. The onsite transportation expert shall inspect all copies of the Shipping Manifest and the
transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm
with the Environmental Coordinator, or their designee that the shipment has been approved for
receipt.
3. Record the inbound date and both the truck and trailer numbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Environmental Department so that the shipment can
be escorted by Environmental personnel to the Designated Disposal Area specified by the
Environmental Coordinator.
6. Prior to transporting material to the Designated Disposal Area (pending on weather), the driver
will be instructed to open or untarp the load. The Environmental personnel and the
transportation expert will visually inspect, to the degree possible, the byproduct material to
ensure that the material matches the material description on the shipping manifest. Any
discrepancies between the byproduct material received and the manifest information will be
reported to the Environmental Coordinator.
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the
Environmental Coordinator that the material in question conforms to Section 2.0 of
this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 4 of 13
Date: February I, Title: 1 le.(2) Byproduct Disposal
2018
c. If weather conditions exist that makes the opening of the conveyance impossible at
the untarping station, the Environmental personnel may take the conveyance to a
suitable location in which to inspect the load. A suitable location will be one where
the load may be viewed where employees are safely out of the way when the
conveyance doors are opened and where if material was to fall out of the
conveyance, that contamination issues will not be incurred. An example area could
the tails impound area near the disposal site.
6.0 Byproduct Material UnJoading
1. The Environmental Coordinator will specify the specific location within the broader
Designated Disposal Area for disposal of the shipment. In designating the specific location
within the broader Designated Disposal Area for disposal of the shipment, the Environmental
Coordinator will ensure that all byproduct material will be segregated from any Mill material
and equipment disposed of in the cell pursuant to Mill license condition 10.4, and that the
byproduct material from each ISL source will be segregated from the byproduct material from
all other ISL sources.
2. Environmental personnel will escort the shipment to the designated location in the Designated
Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
( documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell ( documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is, the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 5 of 13
Date: February 1, Title: 1 le.(2) Byproduct Disposal
2018
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Environmental personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material
received and the manifest information will be reported to the Environmental Coordinator. Any
byproduct material suspected of not meeting the requirements set forth in Section 2.0 of this
SOP will be kept segregated from other waste material until a determination is made of its
acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of.
f) Beta-gamma measurements will be taken at several locations around the unloaded material.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at 2 meters, and the average measurement,
measured in mrem/hr at 2 meters, shall be recorded.
g) Measurements using a photoionization detection meter ("PIO") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Environmental Department's copy of the shipment
documentation. If organics are detected, the Environmental Coordinator must be advised, and
no compaction or covering activities relating to the shipment shall occur until specifically
instructed by the Environmental Coordinator. The Environmental Coordinator and Safety
Coordinator will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The Environmental Coordinator will also contact EFR corporate regulatory
personnel and the shipper to verify that the detected organics are lle.(2) byproduct material
from the shipper's ISL facility. Once the Environmental Coordinator has verified that the
organics are byproduct material compaction and covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activities. If
the gross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all
other unloading activities of byproduct material from that particular ISL site will require the
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 ST AND ARD OPERA TING PROCEDURES Page 6 of 13
Date: February 1, Title: l le.(2) Byproduct Disposal
2018
use of respiratory protection, until further notice by the RSO.
i) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
1) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the Environmental Coordinator, or their
designee, the byproduct material will be spread within the designated area within the
Designated Disposal Area to facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All 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 to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The Environmental Coordinator or their designee will inspect the placement of the byproduct
material prior to covering to physically verify that the procedures in this Section 7 .0 have been
adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify EFR whether a specific trailer is to be released for restricted or unrestricted
use. Any trailers that are to be released for restricted use will be decontaminated according to the
requirements contained in DOT Part 49 CFR 173 .428 or 173 .443. Any trailers that are to be released
for unrestricted use will be decontaminated according to the requirements found in Table 2 of the
Nuclear Regulatory Commission's (NRC's) Regulatory Guide 8.30 Rev. 1 "Health Physics Surveys in
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 ST AND ARD OPERATING PROCEDURES Page 7 of 13
Date: February 1, Title: 1 le.(2) Byproduct Disposal
2018
Uranium Recovery Facilities" or NRC document "Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or
Special Nuclear Material" issued May 1987. Trailers requiring repair will be decontaminated for
unrestricted release, to facilitate repairs by the transporter at the transporter's own site. Trailers may
be repaired without undergoing full decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
9.0
1.
End Dump Trailer
Intermodal Container
Standard Container Trailer
Hazard Identification and Safety
Required Personal Protective Eguipment (PPE)
SOP PBL-9
SOP PBL-2
SOP-PBL-2
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
c) Use caution when the trailers are backing to the unloading area.
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 8 of 13
Date: February 1, Title: 1 le.(2) Byproduct Disposal
2018
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
t) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Environmental Department files:
• Shipper's Manifest and Bill of Lading.
• Laboratory/activity analysis of the byproduct material performed by the Shipper.
• Completed SWT.
• 7-day notice to Director.
• Photo of the byproduct material.
• Byproduct material radiological scan information.
• Breathing zone monitoring data, if applicable.
• Equipment release forms.
All documents and photographs should be dated and the Shipper's Manifest and or Bill of
Lading number indicated on the document.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 ST AND ARD OPERATING PROCEDURES Page 9 of 13
Date: February 1, Title: l le.(2) Byproduct Disposal
2018
b) Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written
description or both. Attachment 2 or other written description will include:
• How the material was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;.
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
2. The Mill will maintain on file a copy of the Director's written approval of each Designated
Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Director on or before November 1 of the calendar year. (License Condition
IO.SF). [summary due same year]
11.0 Training
An annual basis, all onsite personnel that are involved in the receiving or disposing of this
material shall be trained in the activities associated with this procedure. This training shall be
documented and maintained on file.
\
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 10 of 13
Date: February 1, Title: l le.(2) Byproduct Disposal
2018
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Energy Fuels Resources (USA) Inc.'s, White Mesa Mill. In order to assure your safety
while on our property, we would like to acquaint you with the safety rules and procedures, which you
will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph. Energy Fuels Resources (USA) Inc.' s equipment has the right
of way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 11 of 13
Date: February 1, Title: l le.(2) Byprodu9t Disposal
2018
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: ------
Name of employee receiving the load: __________ _
Generator of the Byproduct Material: ----------
Shipper's Manifest or Bill of Lading number: -----------
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? ______ _
Have all drums with void spaces been filled with tailings sands or soil? ---------
Which tailings cell was the material placed in? --------------
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
t..
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 ST AND ARD OPERATING PROCEDURES Page 12 of 13
Date: February 1, Title: l le.(2) Byproduct Disposal
2018
Manifest or BOL #: ------
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?
Documentation of approval
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
Was the maximum lift thickness above tailings less than 4 feet
thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
Refer to drawings used to confirm.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g., survey or review)
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
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 #: -----
Are additional settlement monitors required to be placed for this generator?
If required, where were the settlement markers placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
l
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, Title: FMRI and Cabot Processing
2012
Hazard Assessment Worksheet Node #1
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV -TWA mg/mj
STEL mg/mj
Radioactivity, l)Ci/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
FMRl and Cabot Feed Preparation Node
Process Material in Component
Uranium
20-80
1 -4
--
--
--
Amb
--
2
Page 1 of 2
Assessment Description: The FMRI and Cabot materials are industrial solid by-products
of relatively fine particle size that contain uranium along with a variety of compounds,
including mainly calcium, aluminum, zirconium, iron, sodium and potassium compounds.
The FMRI or Cabot material may need to be separated from the super sacks in which it
was shipped before it is ready to feed to the process. Though the material normally
contains sufficient moisture to keep it from easily becoming airborne, there is a
possibility for minor portions of the material to become airborne as it is separated from
the super sacks. The FMRI and Cabot materials are also radioactive and you must
follow established health physics controls. If any of these materials gets on your
clothing or skin, wash it off promptly with generous amounts of soap and water.
Operating Instructions
The FMRI or Cabot material may have been stored in a pile of super sacks and, if so, it
must be kept in the super sacks for control of dust emissions until a short time before it is
to be fed to the process. Thus, either the FMRI or the Cabot material may require
preparation to separate the material from the super sacks prior to feeding for other
processmg. In this case, the preparation should be performed according to the following
procedure.
• Make sure you are familiar with the MSDS for the FMRI or Cabot material,
whichever you will be handling.
• Make a safety inspection of all equipment, including the following:
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of2
Date: December 18, Title: FMRI and Cabot Processing
2012
o Inspect parts of the equipment that normally come into contact with the
material to assure proper function.
o Inspect the operator's cab to assure that all closures for all possible
openings that could admit dust into the cab are functioning properly and
capable of being securely closed.
• When it is determined safe to do so, and in accordance with your supervisor's
instructions, mount the piece of equipment and enter the operator's cab with the
intent to operate the piece of equipment.
• Make sure the door seals tightly when it is closed and make sure all other
openings through which dust could enter are also closed.
• Fasten all restraining devices and enable all appropriate safety systems for the
piece of equipment.
• Make sure all other personnel and equipment are clear from the piece of
equipment you are about to start. Then tum the piece of equipment on.
• Proceed to operate the piece of equipment according to your supervisor's
instructions and the manufacturer's instructions to separate the super sacks and
other extraneous materials from the FMRI or Cabot material to be processed for
uranium recovery.
• When the work to be accomplished is completed or when it becomes
operationally necessary, properly secure the piece of equipment and tum it off
• Exit the operator's cab, closing the door behind you, and dismount the piece of
equipment in accordance with your supervisor's instructions.
NOTE: Whenever working around the piles of FMRI or Cabot material you
must wear appropriate PPE which may include Tyvex coveralls, rubber boots,
gloves, safety glasses, face shield or full face respirators or whatever level of
respiratory protection is deemed appropriate by the Radiation Safety Officer.
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, Title: FMRI and Cabot Processing
2012
Hazard Assessment Worksheet Node#2
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m3
STEL mg/m_j
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
FMRI and Cabot Grinding Node
Process Material in Component
Uranium
80 -400
1 -4
--
--
--
Amb
--
2
Page 1 of 2
Assessment Description: The FMRI and Cabot materials are industrial solid by-products
of relatively fine particle size that contain uranium along with a variety of compounds,
including mainly calcium, aluminum, zirconium, iron, sodium and potassium compounds.
Though the material normally contains sufficient moisture to keep it from easily
becoming airborne, there is a possibility for minor portions of the material to become
airborne as it is fed to the process. The FMRI and Cabot materials are also
radioactive and you must follow established health physics controls. If any of these
materials gets on your clothing or skin, wash it off promptly with generous amounts
of soap and water.
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of2
Date: December 18, Title: FMRI and Cabot Processing
2012
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC .
Rev. No.: R-1 ST AND ARD OPERA TING PROCEDURES Page 3 of2
Date: December 18, Title: FMRI and Cabot Processing
2012
Operating Instructions
The FMRI or Cabot material that has been prepared for feeding to uranium recovery
processing will be sitting in a pile on the ore pad. Before handling these materials
appropriate precautions should be taken to protect operators from inhaling airborne dusts
of these materials. Operators can then proceed with the grinding step as follows:
• Make sure you are familiar with the MSDS for the FMRI or Cabot material,
whichever you will be handling.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
o Inspect operator's cabs of mobile equipment to be used to assure doors
and all other openings through which dust might enter can be tightly
sealed.
• Start up the grind circuit according to standard operating procedures. Begin
feeding the prepared FMRI or Cabot material to the grizzly and continue feeding
and processing through the grind circuit, storing the ground pulp in the pulp
storage tanks, according to standard operating procedures for the grind circuit.
• When the appropriate tonnage of FMRI or Cabot material has been fed and
processed in the grind circuit, shut down the grind circuit according to standard
operating procedures.
NOTE: Whenever working in, around or on the grind circuit you must wear
appropriate PPE which may include Tyvex coveralls, rubber boots, gloves,
safety glasses, face shield or full face respirators or whatever level of respiratory
protection is deemed appropriate by the Radiation Safety Officer.
(
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, Title: FMRI and Cabot Processing
2012
Hazard Assessment Worksheet Node#3
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m3
STEL mg/m3
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
FMRJ and Cabot Leaching Node
Process Material in Component
Uranium H2S04
3,500-6,000
14,000
0.5-2.5 1.0
--
--
--
Amb Amb
--
2
Page 1 of 3
Assessment Description: The FMRI and Cabot materials are industrial solid by-products
of relatively fine particle size that contain uranium along with a variety of compounds,
including mainly calcium, aluminum, zirconium, iron, sodium and potassium compounds.
In this processing step, sulfuric acid is added to the pulp to dissolve some of the
contained uranium. Adequate caution is needed to prevent splashing of acid or acidified
pulp on any operators or equipment not designed for acid contact. The FMRI and Cabot
materials are also radioactive and you must follow established health physics
controls. If any of these materials gets on your clothing or skin, wash it off promptly
with generous amounts of soap and water.
No.: PBL-11 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-1 STANDARD OPERATJNG PROCEDURES Page 2 of 3
Date: December 18, Title: FMRI and Cabot Processing
2012
--
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: FMRI and Cabot Processing
2012
Operating Instructions
The FMRI or Cabot material, in the form of a ground pulp, is fed to the leaching step to
dissolve some of the contained uranium by reaction with sulfuric acid. Operators should
perform the leaching step as follows:
• Make sure you are familiar with the MSDS for the FMRI or Cabot material,
whichever you will be handling, and the MSDS for sulfuric acid.
• Make a safety inspection of all lines and equipment including the following:
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Make sure agitation is running in the pre-leach tanks. Transfer ground pulp of the
FMRI or Cabot material from one of the pulp storage tanks to the east pre-leach
tank at the rate of 60 tons per hour or as instructed by your supervisor.
• Add sulfuric acid in a continuous stream, if possible, to the east pre-leach tank
sufficient to maintain a free acid concentration in the east pre-leach tank of 15
grams per liter or as instructed by your supervisor.
• At times it may be necessary to add water, pond return liquid, or other materials
or reagents to the east pre-leach tank. Make these additions only as instructed by
your supervisor.
• The west pre-leach tank is operated to provide additional residence time for the
leach reactions to proceed. Normally there will be no additions ofreagents to the
west pre-leach tank. Make no additions to this tank unless instructed to do so by
your supervisor.
• Unless otherwise noted in the instructions listed above or instructions received
from your supervisor, operate the equipment of the pulp storage and pre-leach
areas according to standard operating procedures.
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 4 of 3
Date: December 18, Title: FMRI and Cabot Processing
2012
NOTE: Whenever working in, around or on the pulp storage and pre-leach
areas of the mill you must wear appropriate PPE which may include Tyvex
coveralls, rubber boots, gloves, safety glasses, face shield or full face respirators
or whatever level of respiratory protection is deemed appropriate by the
Radiation Safety Officer.
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES
Date: December 18, Title: FMRJ and Cabot Processing
2012
Hazard Assessment Worksheet Node#4
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
FMRI and Cabot Washing Node
Process Material in Component
Uranium H2S04
1200-2,500
5,000
0.2 -1.0 0.4
--
--
--
Amb Amb
--
2
Page 1 of 3
Assessment Description: The FMRI and Cabot materials are industrial solid by-products
of relatively fine particle size that contain uranium along with a variety of compounds,
including mainly calcium, aluminum, zirconium, iron, sodium and potassium compounds.
In this processing step, the acidified uranium-bearing solution is separated from the
leached solids. Adequate caution is needed to prevent splashing of acidified liquid or
pulp on any operators or equipment not designed for acid contact. The FMRI and Cabot
materials are also radioactive and you must follow established health physics
controls. If any of these materials gets on your clothing or skin, wash it off promptly
with generous amounts of soap and water.
Operating Instructions
In this processing step, the leached pulp produced from the FMRI or Cabot material is
washed in one or more CCD thickeners to separate the liquid containing the dissolved
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: FMRI and Cabot Processing
2012
uranium from the leached solids which are sent to the tailings area for disposal.
Operators should perform the washing step as follows:
• Make sure you are familiar with the MSDS for the FMRI or Cabot material,
whichever you will be handling.
• Make a safety inspection of all lines and equipment including the following:
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Transfer the leached pulp discharging from the west pre-leach tank to the head
tank for the #8 CCD thickener or another thickener as instructed by your
supervisor·.
• Add a sufficient flow of pond return liquid, process water, or a mixture of the two
liquids as instructed by your supervisor to the thickener head tank with the
leached pulp to achieve a pulp density of about 25% solids or as instructed by
your supervisor.
• Proceed to operate the #8 CCD thickener, and/or other CCD thickeners as
instructed by your supervisor, according to the standard operating procedures for
the CCD circuit thickeners. This will include adding flocculant as needed to the
thickener feed.
• Transfer the final overflow stream discharging from the CCD thickeners in use to
the clarifier for further clarification before processing in SX for uranium recovery.
• Transfer the final underflow stream discharging from the CCD thickeners in use
to the tailings sump for disposal of the leached solids in the tailings area.
NOTE: Whenever working in, around or on the CCD thickeners and the CCD
area of the mill you must wear appropriate PPE which may include Tyvex
coveralls, rubber boots, gloves, safety glasses, face shield or full face respirators
or whatever level of respiratory protection is deemed appropriate by the
Radiation Safety Officer.
( .
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES
Date: December 18, Title: FMRl and Cabot Processing
2012
Hazard Assessment Worksheet Node #5
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m3
STEL mg/m_j
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
FMRI and Cabot SX and Precipitation Node
Process Material in Component
Uranium H2S04
100-200 1,500
0.02-0.4
0.04
--
--
--
Amb Amb
--
2
Page 1 of2
Assessment Description: The solution obtained from leaching FMRI and Cabot materials
may contain varying concentrations of dissolved uranium, calcium, aluminum,
zirconium, iron, sodium and potassium compounds. In these processfog steps, the
uranium is separated from impurities and collected as a high purity yellowcake product.
Adequate caution is needed to prevent splashing of acidified liquid on any operators or
equipment not designed for acid contact. The uranium-bearing liquids are also
radioactive and you must follow established health physics controls. If any of these
materials gets on your clothing or skin, wash it off promptly with generous amounts
of soap and water.
Operating Instructions
No.: PBL-11 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: FMRI and Cabot Processing
2012
In these processing steps, the solution containing the uranium leached from the FMRI or
Cabot material is treated to extract the uranium away from impurities and later precipitate
the uranium as a purified final product of the mill. Operators should perform these steps
as follows:
• Make sure you are familiar with the MSDS for kerosene, tertiary amine, tri-decyl
alcohol, ammonia, and any other reagents to be used. Also, make sure you are
familiar with the MSDS for yellowcake.
• Make a safety inspection of all lines and equipment including the following:
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Transfer the uranium-bearing solution from the clarifier to the SX feed tank and
operate the SX circuit according to the established standard operating procedures.
• Transfer the loaded strip solution produced by the SX circuit to the yellowcake
precipitation and drying area and operate the yellowcake precipitation and drying
area according to the established standard operating procedures.
• Label and store the drums of finished yellowcake produced in the yellowcake
precipitation and drying area according to established standard operating
procedures.
NOTE: Whenever working in, around or on the SX or yellowcake precipitation
and drying areas of the mill you must wear appropriate PPE which may include
Tyvex coveralls, rubber boots, gloves, safety glasses, face shield or full face
respirators or whatever level of respiratory protection is deemed appropriate by
the Radiation Safety Officer.
No.: PBL-12 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES Page 1 of3
Date: November 1, Title: Shredded Drum Acid Leach
2013
Hazard Assessment Worksheet
Reagent Data
Leach Solution
pH <1
Temperature Ambient
Oxidizer /Reductant Strong oxidizer
Pressure Ambient
Flashpoint Not flammable
Reagent Concentrations H2S04 NaCI03
Concentration Range 40 -60 g/L 10 -20 g/L
Assessment Description: The acid/chlorate solution will be added to each drum and each drum
will be rolled on electric drum rollers in order to dissolve the uranium contained in each drum.
Any splashing or contact with the leach solution, before and after the leaching process should be
avoided as these chemicals can cause chemical bums. Also, avoid contact with organic material
(such as clothing) as sodium chlorate can react strongly with organic materials. Operators and
anyone in the area should wear proper PPE to protect from these chemicals. In case of any
contact, wash the area of contact off with generous amounts of water.
Leach
Solution
Operating Instructions
This node deals with the acid leaching of the uranium coated drum shreds.
• Obtain approval from your supervisor to run the leaching process of the drum
shreds.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
l
No.: PBL-12 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: November 1, Title: Shredded Drum Acid Leach
2013
o Inspect safety showers and eyewash fountains.
o Inspect the drum rollers and associated equipment for defects.
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the MSDS. This means that you must read and understand the
information on the MSDS and if you don't, ASK YOUR
SUPERVISOR.
. • Position each drum near a rolling station. Relieve any pressure build up in the
drum by making a ·vent hole before removing the lid. Remove the lid of each
drum.
• Inspect the drum for any abnormalities or suspicious content.
• Re-seal the drum with a "process" lid. The process lid has additional fittings
to allow for ease in processing. Make sure that the o-ring is not damaged and
that the lid seals completely to avoid leakage from the drum. Also, make sure
the center vent port is free of ice or other obstructions.
• Lower each drum onto the rolling mechanism.
• Connect the venting tubing and the reagent fill line. Fill the drum with the
specified volume of reagent solution. Close the valve and remove the reagent
fill line
• Close all guarding and safety mechanisms and turn the drum rollers on.
Allow the drums to roll for 30 minutes or as instructed by your supervisor.
• When 30 minutes is up shut off the drum rollers. Connect the drain lines and
open the valves to drain the solution into the sump. Transfer the solution from
the sump to the solution holding tank. From the holding tank the solution is
sent to the solvent extraction circuit and will be processed using normal SX,
precipitation and drying practices.
• Repeat the process if necessary as instructed by your supervisor.
• Rinse the contents of the drum with water if necessary as instructed by your
supervisor.
• Stand the drums back up and remove the "process" lids. Replace it with the
original lid and move drum to drum disposal area after which the drums will
be disposed of according to Mill Waste Disposal SOP PBL-7.
(
No.: PBL-12 ENERGY FUELS RESOURCES (USA} INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES Page 3 of3
Date: November l, Title: Shredded Drum Acid Leach
2013
• Be sure to wear appropriate PPB at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
l
No.: PBL-12 ENERGY FUELS RESOURCES (USA) lNC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES Page 1 of2
Date: November 1, Title: Shredded Drum Reagent Make-up
2013 .
Hazard Assessment Worksheet
Reagent Data
Leach Solution
pH <1
Temperature Ambient
Oxidizer/Reductant Strong oxidizer
Pressure Ambient
Flashpoint Not flammable
Reagent Concentrations H2S04 NaCI03
Concentration Range 40 -60 g/L 10 -20 g/L
Assessment Description: The acid/chlorate solution will be made up from bulk concentrated
solutions of sulfuric acid and sodium chlorate. Batches will be made up by an automated system
with reagents added in this order: water, sulfuric acid then sodium chlorate. Sulfuric acid is a
strong acid and can cause chemical bums. Sodium chlorate is a strong oxidant and can cause
chemical bums. Also, avoid contact with organic material (such as clothing) as sodium chlorate
can react strongly with organic materials. Operators and anyone in the area should wear
proper PPE to protect from these chemicals. In case of any contact, wash the area of
contact off with generous amounts of water.
Water
Reagent
Mix Ta
Operating Instructions
This node deals with the leach solution make-up.
No.: PBL-12 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-0 STANDARD OPERATING PROCEDURES Page 2 of2
Date: November 1, Title: Shredded Drum Reagent Make-up
2013
• Obtain approval from your supervisor to make a batch of leach solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the MSDS. This means that you must read and understand the
information on the MSDS and if you don't, ASK YOUR
SUPERVISOR.
• Check the level of the tank and determine if a new batch of leach solution is
needed.
• Ensure that all valves are in appropriate positions
• Initiate the batch make-up
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
(
No.: PBL713 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 1 of 4
Date: December 1 8, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node #1
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m3
STEL mg/m3
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
CaFz Drum Dumping Node
Process Material in Component
Calcium Uranium Hydrofluoric Sodium
Fluoride Acid Carbonate
600 < 12 < 0.3 4,000
60-80 <2 < 0.05 10
------
----
----
----
Amb Amb Amb 80
------
2
Assessment Description: The CaF2 material is a dry solid and can become airborne easily.
The material should be wetted with water after the drums are opened for dust-free
handling. Heating of the dry CaF2 material should be avoided as it may cause elevated
emission of HF vapors. The CaF2 material is also radioactive and you must follow
established health physics controls. If any CaF 2 gets on your clothing or skin, wash
it off with generous amounts of water.
Drums ofCaF2
~ ..-------,
Drum
Dumping
Station
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page2 of4
Date: December 18, Title: CaF2 Processing
2012
Operating Instructions
The CaF2 drums must be kept sealed or covered as much as possible until all process
components are ready for dumping the drums.
• Make sure you are familiar with the MSDS for the CaF2 material.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Tum on the drum dumper, the weigh scale, and the conveyor.
• Place a CaF2 drum in position for handling.
• Undo the drum lid carefully and report any unusual conditions to ~ur supervisor.
• Examine the contents of the drum. If the contents of the drum have solidified to
the extent that the material cannot be easily sampled or removed from the drum,
then refasten the lid and transport the drum to special handling. For all other
drums, proceed with the following steps.
• Weigh and record the drum weight.
• Take a sample of the contents of the drum and place the sample in the
appropriately marked container to make up a composite sample for all of the
drums dumped on that day. Make sure this composite sample container is marked
clearly with the sample identification and date. At the conclusion of the drum
dumping activities for the day, make sure this composite sample is transported to
the laboratory.
• Add the appropriate volume of sodium carbonate (soda ash) solution to the
dumper vessel as instructed by your supervisor.
• Add the appropriate amount of water to the contents of the drum for dust control
as instructed by your supervisor.
• Place the drum in the drum dumper and dump its contents.
• If the empty drum is in good condition, retain the empty drum and lid for possible
use in special handling and store as instructed by your supervisor.
l
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC .
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 3 of 4
Date: December 18, Title: CaF2 Processing
2012
• Repeat the process steps described above for additional drums of CaF2 material
until the target number of drums for the current batch, as instructed by your
supervisor, is reached.
• As needed, transfer the slurry of dumped CaF 2 material to the digestion tank as
instructed by your supervisor.
• Tum off the drum dumper, the weigh scale, and the conveyor.
• Clean up any spilled CaF 2 material, drum parts, tools, etc. and ensure your work
area is free of hazardous obstructions. Prepare the area to handle the next batch of
drums.
Special handling of drums of CaF2 material whose contents have solidified will be as
follows:
• Use equipment and methods as instructed by your supervisor to remove the drum
from its contents or to remove the contents from the drum.
• Use equipment and methods as instructed by your supervisor to break up the
solidified chunks of CaF2 material until the pieces are small enough to be loaded
into drums and fed to normal processing by the drum dumping station.
• Load the crushed CaF2 material into drums as instructed by your supervisor,
fasten drum lids, and transport the drums to the drum dumping station.
• For any drums that cannot be re-used, crush the drums for disposal and dispose of
the crushed drums as instructed by your supervisor.
• In all steps of special handling, use water as instructed by your supervisor to
control dust emissions.
NOTE: Whenever working in, around or on this process circuit you must wear
appropriate PPE which may include Tyvex coveralls, rubber boots, gloves,
safety glasses, face shield or full face respirators or whatever level of respiratory
protection is deemed appropriate by the Radiation Safety Officer.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 4 of 4
Date: December 18, Title: CaF2 Processing
2012
MOBILE EQUIPMENT
The forklift handling the drums of CaF 2 material will be operated according to normal
operating procedures, taking special precautions to avoid spilling or rupturing any of the
drums of the CaF 2 material.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERA TING PROCEDURES Page 1 of2
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node #2
Equipment Component CaF1 Carbonate Digestion Node
Individual Equipment No.
Parameter Process Material in Component
PFD Calcium Uranium Sodium Hydrogen
Fluoride Carbonate Peroxide
Quantity in Equipment (lb) 30,000 600 8,300 75
Concentration (%) 30 0.6 10 50
Flashpoint, °F --------
TLV-TWA mg/mj ----
STEL mg/mj ----
Radioactivity, pCi/g ------
Temperature, °C 80 80 80 Amb.
Pressure, psig --------
Health Rating
Hazard Rating
Assessment Description: Most of the contained uranium in the CaF2 material is dissolved
in the heated sodium carbonate (soda ash) solution in this processing step. The liquid in
the digestion vessel is strongly basic. Any splashing or contact with the skin should be
avoided. These materials can cause skin and eye burns. The dissolved CaF 2 material
is also radioactive and you must follow established health physics controls. If any
carbonate digestion solution gets on you, wash it off with generous amounts of
water.
Na2C03
Make-Up
Tank
Steam
Digestion
Tank
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: CaF2 Processing
2012
Operating Instructions
This node deals with digesting the CaF2 material in sodium carbonate (soda
ash) solution at 80°C for about 4 hours.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• As the digestion tank is being filled from the drum dumping station,
once the level of slurry in the digestion tank is appropriate for starting
agitation without causing splashing or spillage -then start agitation.
Continue receiving slurry from the drum dumping station until a full
batch has been received.
• Add the required volume of hydrogen peroxide solution to the
digestion tank as instructed by your supervisor. Wear appropriate PPE
for handling hydrogen peroxide.
• Add steam to the contents of the tank until the contents reach 80°C.
Continue adding steam as needed to maintain this temperature.
• Continue agitation of the tank contents at 80°C for 4 hours to complete
the necessary digestion.
• At the end of the digestion time, measure the volume of final digestion
solution in the tank and take a sample of the contents of the tank and
place the sample in an appropriately marked container. Make sure this
sample container is marked clearly with the batch number, the sample
identification and the date. Make sure this sample is collected daily by
laboratory technicians and transported to the laboratory.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and you must wear PPE which
includes at a minimum, hard hat, coveralls, rubber boots and gloves,
safety glasses with side shields, and whatever level of respiratory
protection is deemed appropriate by the Radiation Safety Officer, and
may include a face shield or safety goggles.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERA TING PROCEDURES Page 1 of 3
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node #3
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radi<:>aeti-vity; pGifg -
Temperature, °C
Pressure, psig
Health Ratin$?:
Hazard Rating
Filtration After Carbonate Digestion Node
Process Material in Component
Calcium Uranium Sodium
Fluoride Carbonate
30,000 600 8,300
30 0.6 8.3
------
--
--
·------------· -
80 80 80
------
Filter Aid
300
100
--
--
---~ --
Ambient
--
Assessment Description: This processing step involves pressure filtration of a basic slurry.
Any splashing or contact with the skin should be avoided. The basic chemicals in the
liquid can cause skin and eye burns. The solution and the filter cake are also
radioactive and you must follow established health physics controls. If any of the
solution or filter cake gets on you, wash it off with generous amounts of water. If any of
the filter cake becomes dry, respiration of the dust must be avoided. The filter press and
piping leading to it will be under pressure and should be handled carefully.
Filter
Aid
Addition Tank
H,O
Comp. Air
First Stage
Filter Press
Barren
Solids To
Tailings
Filtrate
and
Wash
Precipitation
Tank
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: CaF2 Processing
2012
Operating Instructions
In this processing step the undissolved CaF2 is separated from the dissolved
uranium by pressure filtration.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect the filter feed pump and the filter press for leaks and proper
assembly.
o Inspect safety showers and eyewash fountains.
• Add water to the filter aid addition tank for pre-coating the pressure filter
according to instructions from your supervisor. Start agitation of the tank
and then add pre-coat filter aid to the tank according to instructions from
your supervisor. Mix the contents of the tank thoroughly. Make sure you
are wearing the appropriate respirator as determined by the Radiation
Safety Officer whenever handling or working in the vicinity of filter aid in
its dry condition.
• Adjust all necessary valves and tum on the pump to transfer pre-coat filter
aid slurry from the filter aid addition tank to the filter press. Pump the
entire contents of the filter aid addition tank through the filter press. Then
tum off the pump and adjust all necessary valves to leave the pre-coated
filter press filled with water under some pressure.
• Adjust all necessary valves and tum on the pump from the digestion tank
to the filter press. Recycle filtrate back to the digestion tank until the
solution clears and then adjust the appropriate valves to send the filtrate to
the precipitation tank. Pump the contents of the digestion tank through the
filter press until the tank is empty or the pressure or flow rate indicates the
filter press chambers are full of filter cake.
• When the pressure or flow rate indicates the filter press chambers are full
of filter cake, tum off the pump from the digestion tank, adjust the
necessary valves, and run wash water through the filter press according to
instructions from your supervisor. Send the filtrate from washing to the
precipitation tank.
• When the water wash is completed, shut off the wash water, adjust
appropriate valves, and run compressed air through the filter press
according to instructions from your supervisor. Send any liquid
discharged from the filter press to the precipitation tank ..
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: CaF2 Processing
2012
• When the filter cake has been adequately dried by the compressed air, shut
off the air flow and depressurize the filter press.
• Tum on the screw conveyor system under the filter press, open the filter,
and dump and transfer all filter cake to the filter cake re-pulp tank 1.
• Add water to the filter cake re-pulp tank according to instructions from
your supervisor and agitate contents of the tank until the filter cake is fully
re-pulped. Transfer the re-pulped filter cake slurry to the tailings pond
according to instructions from your supervisor.
• Clean the filter press, close it up, and prepare it for its next filtration cycle.
• Repeat, as needed, steps for pre-coating the filter, filtering the contents of
the digestion tank and dumping and re-pulping and transferring the filter
cake until the digestion tank is empty.
• Make sure a sample is taken of the solids slurry transferred from the re-
pulp tank to tailings.
• Whenever working in, around or on this process you must avoid splashing
and any contact with the skin and YOU MUST wear PPE which includes
at a minimum, hard hat, coveralls, rubber boots and gloves, safety glasses
with side shields, and whatever level of respiratory protection is deemed
appropriate by the Radiation Safety Officer, and may include a face shield
or safety goggles.
• Always keep your work area clean and ensure your work area is free of
obstructions.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 1 of2
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node#4
Equipment Component NaOH Preci:gitation Node
Individual Equipment No.
Parameter per Tank Process Material in Component
PFD Uranium Sodium NaOH Filter Aid
Carbonate
Quantity in Equipment (lb) 600 8,300 2,500 350
Concentration (%) 0.7 10 50 100
Flashpoint, °F -----
TLV-TWA mg/mj ------
STEL mg/mj ------
Radioactivity, pCi/g ------
Temperature, °C 70 70 Amb Amb.
Pressure, psig --------
Health Rating
Health Hazard
Assessment Description: A uranium-rich precipitate is formed by N aOH addition to the solution
from the carbonate digestion of the CaF2 material in this processing step. The liquid in the tank is
strongly basic. Any splashing or contact with the skin should be avoided. These materials can
cause skin and eye burns. The solution and the precipitate that is formed are also radioactive
and you must follow established health physics controls. If any of the solution or precipitate
gets on you, wash it off with generous amounts of water.
NaOH
Steam
Precipitation
Tank
Filter
Aid
Filter Feed
Tank
Operating Instructions
This node deals with formation of a uranium-rich precipitate by addition ofNaOH to the
final solution from the carbonate digestion of the CaF2 material.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of2
Date: December 18, Title: CaF2 Processing
2012
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Maintain agitation of the filtrate solution from carbonate digestion of the CaF2
material in the precipitation tank. Add steam, if necessary, to maintain the
contents of the precipitation tank at least at 70°C (158°F).
• Make sure you are wearing all appropriate PPE for handling 50% NaOH (caustic)
solution.
• To the agitated contents of the precipitation tank carefully add 50% NaOH
(caustic) solution until the pH of the contents of the tank reaches at least 13.0 as
instructed by your supervisor. Measure the pH of the tank contents with pH paper
obtained from the lab. Do not measure the pH using an ordinary pH meter and
probe -these may not give correct pH readings in this solution.
• After the contents of the tank reach the target pH, continue for about 4 hours to
agitate the tank contents at the target temperature and continue to carefully add
small volumes of the 50% NaOH solution to the tank as necessary to maintain the
target pH.
• After about four hours, the precipitation reaction should be complete. At this
point add to the slurry in the precipitation tank the amount of filter aid as
instructed by your supervisor. Make sure you are wearing the appropriate
respirator as determined by the Radiation Safety Officer whenever handling or
working in the vicinity of filter aid in its dry condition. Then adjust the necessary
valves, tum on the pump, and transfer the contents of the precipitation tank to the
filter feed tank.
• After the batch of material has been transferred as completely as practical from
the precipitation tank to the filter feed tank then make sure the precipitation tank
agitator is turned off and that all valves, pumps, etc. have been returned to the
proper settings for starting handling of the next batch of solution from the
digestion step.
• Whenever working in, around or on this process you must avoid splashing and
any contact with the skin and YOU MUST wear PPE which includes at a
minimum, hard hat, coveralls, rubber boots and gloves, safety glasses with side
shields, and whatever level of respiratory protection is deemed appropriate by the
Radiation Safety Officer, and may include a face shield or safety goggles.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node#5
Equipment Component
Individual Equipment No.
Parameter per Tank
NaOH Precipitate Filtration Node
Process Material in Component
PFD Uranium Sodium NaOH Filter Aid
Carbonate
Quantity in Equipment (lb) 600 8,300 2,500 350
Concentration (%) 0.7 10 3
Flashpoint, °F -----
TLV-TWA mg/mj ----
STEL mg/mj ----
Radioactivity, pCi/g ----
Temperature, °C (F) 70 70 70
Pressure, psig ------
Health Rating
Health Hazard
Assessment Description: The uranium-rich precipitate formed by NaOH addition to the
solution from the carbonate digestion of the CaF2 material is separated from the solution
by pressure filtration. Make sure all pressurized lines, connections and fittings are in
good condition and not leaking. The liquid in the tank is strongly basic. Any splashing
or contact with the skin should be avoided. The chemicals in the liquid can cause skin
and eye burns. The solution and the precipitate are abo radioactive and you must
follow established health physics controls. If any of the solution or precipitate gets
on you, wash it off with generous amounts of water. The filter aid material is dusty in
the dry condition and you must avoid breathing the dust.
Filtrate and
Wash Surge
Tank
To Tails
• Cell 1
Filter Cake
Re-Pulp
Tank2
Second
Stage Filter
Press
Filter Aid
Addition Tank
Filter Cake
Acid Re-
Dissolution
Tank
0.4
--
--
--
70
--
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of3
Date: December 18, Title: CaF2 Processing
2012
Operating Instructions
This node deals with the pressure filtration processing step to recover the
uranium-rich precipitate formed by NaOH addition to the solution from the
carbonate digestion of the CaF2 material.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Inspect the filter to make sure it has been fully dumped,
cleaned, and prepared to receive fresh feed material.
• Add water to the filter aid addition tank for pre-coating the pressure
filter according to instructions from your supervisor. Start agitation of
the tank and then add pre-coat filter aid to the tank according to
instructions from your supervisor. Mix the contents of the tank
thoroughly. Make sure you are wearing the appropriate respirator as
determined by the Radiation Safety Officer whenever handling or
working in the vicinity of filter aid in its dry condition.
• Adjust all necessary valves and tum on the pump to transfer pre-coat
filter aid slurry from the filter aid addition tank to the filter press.
Pump the entire contents of the filter aid addition tank through the
filter press. Then tum off the pump and adjust all necessary valves to
leave the pre-coated filter press filled with water under some pressure.
• Adjust all necessary valves and tum on the pump from the filter feed
tank to the filter press. Recycle filtrate back to the filter feed tank until
the solution clears and then adjust the appropriate valves to send all
barren filtrate to the filtrate and wash surge tank. Pump the contents of
the filtt:Jr feed tank through the filter press until the tank is empty or the
pressure or flow rate indicates the filter press chambers are full of filter
cake.
• Tum off the pump from the filter feed tank, adjust the necessary
valves, and run wash water through the filter press according to
instructions from your supervisor. Send the filter discharge to the
filtrate and wash surge tank.
• Shut off the wash water, adjust the appropriate valves, and run
compressed air through the filter press according to instructions from
No.: PBL-13 ENERGY FUELS RESOURCES (USA) lNC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: CaF2 Processing
2012
your supervisor. Send the filter discharge liquid to the filtrate and
wash surge tank.
• When the filter cake has been adequately dried by the compressed air,
shut off the air flow and depressurize the filter press.
• Tum on the screw conveyor system under the filter press, open the
filter, and dump and transfer all filter cake to the filter cake re-pulp
tank 2.
• Add water to the filter cake re-pulp tank 2 as instructed by your
supervisor and agitate the contents of the tank until the filter cake is
fully re-pulped. Adjust appropriate valves and tum on the pump to
transfer the re-pulped filter cake slurry to the filter cake acid re-
dissolution tank according to instructions from your supervisor.
• Clean the filter press, close it up, and prepare it for its next filtration
cycle.
• Repeat pre-coating the filter, filtering the contents of the filter feed
tank, and dumping and re-pulping the filter cake and transferring it to
the filter cake acid re-dissolution tank until the filter feed tank is
empty.
• Make sure the volume in the filtrate and wash surge tank is measured
and recorded and make sure a sample of the contents of the tank is
placed in an appropriately marked sample container for analysis by the
lab. Then send the contents of the filtrate and wash surge tank to
tailings.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
• Always keep your work area clean and ensure your work area is free
of obstructions.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERATING PROCEDURES
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node#6
Equipment Component
Individual Equipment No.
Filter Cake Acid Re-Dissolution Node
Page 1 of 2
Parameter per Tank Process Material in Component
PFD Uranium Sulfuric Acid
Quantity in Equipment (lb) 1,800 1750
Concentration (%) 2-4 93
Flashpoint, °F ----
TLV-TWA ppm --
STEL oom -
Radioactivity, pCi/g 0 --
Temperature, °C (F) 25-40 25-40
Pressure, psig --0-100 --
Health Rating
Health Hazard
--
--
-
--
Assessment Description: The re-pulped filter cake of basic uranium-rich precipitate and
the acidic solution in which it will be digested should be handled with caution. Any
splashing or contact with the skin should be avoided. The acidic chemicals in the liquid
can cause skin and eye burns. The solution and the filter cake are also radioactive
and you must follow established health physics controls. If any of the solution or
filter cake gets on you, wash it off with generous amounts of water.
Steam
Filter Cake Acid
Re-Dissolution
Tank
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of2
Date: December 18, Title: CaF2 Processing
2012
Operating Instructions
This node deals with the acid digestion of re-pulped uranium-rich filter cake.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Inspect valves and fittings in the acid line.
• As the slurry of re-pulped filter cake is being transferred to the filter
cake acid re-dissolution tank, turn on agitation in the tank as soon as
the level is sufficient according to your supervisor's instructions.
• Add water to the contents of the filter cake acid re-dissolution tank
according to instructions from your supervisor and carefully add
sulfuric acid to bring the pH of the slurry to 2.0 or a lower pH as
instructed by your supervisor.
• Add steam to bring the contents of the filter cake acid re-dissolution
tank to 40°C or another temperature as instructed by your supervisor.
Agitate the slurry in the tank at the target temperature and pH for a
time of at least one hour as instructed by your supervisor, adding
steam and sulfuric acid as needed to maintain these conditions.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
(
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node#7
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Filtration After Acid Digestion of Filter Cake Node
Process Material in Component
Uranium Dilute H2S04 Filter Aid
1,800 50 1000
2-4 0.1-0.2 1-2
------
----
----
--
40 40 40
----
Assessment Description: This processing step involves pressure filtration of an acidic
slurry. Any splashing or contact with the skin should be avoided. The acidic chemicals
in the liquid can cause skin and eye burns. The solution and the ftlter cake are also
radioactive and you must follow established health physics controls. If any of the
solution or filter cake gets on you, wash it off with generous amounts of water. If
any of the filter cake becomes dry, respiration of the dust must be avoided. The filter
press and piping leading to it will be under pressure and should be handled carefully.
Filtrate
and
Wa~h
Impurity
Removal Tank
1
Comp.
Air
Impurity
Removal Tank
2
Filter Cake
Re-Pulp
Tank3
Third Stage
Filter Press
Operating Instt·uctions
Filter Cake Acid
Re-Dissolution
Tank
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of3
Date: December 18, Title: CaF2 Processing
2012
In this processing step the used filter aid is separated from the dissolved
uranium by pressure filtration.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect the filter feed pump and the filter press for leaks and
proper assembly.
o Inspect safety showers and eyewash fountains.
• Adjust all necessary valves and turn on the pump from the filter cake
acid re-dissolution tank to the filter press. Recycle filtrate back to the
filter cake acid re-dissolution tank until the solution clears and then
adjust the appropriate valves to send the filtrate to impurity removal
tank 1 or tank 2. Pump the contents of the filter cake acid re-
dissolution tank through the filter press until the tank is empty or the
pressure or flow rate indicates the filter press chambers are full of filter
cake.
• When the pressure or flow rate indicates the filter press chambers are
full of filter cake, tum off the pump from the filter cake acid re-
dissolution tank, adjust the necessary valves, and run wash water
through the filter press according to instructions from your supervisor.
Send the filtrate from washing to the same impurity removal tank.
• When the water wash is completed, shut off the wash water, adjust
appropriate valves, and run compressed air through the filter press
according to instructions from your supervisor. Send any liquid
discharged from the filter press to the same impurity removal tank.
• When the filter cake has been adequately dried by the compressed air,
shut off the air flow and depressurize the filter press.
• Tum on the screw conveyor system under the filter press, open the
filter, and dump and transfer all filter cake to the filter cake re-pulp
tank 3.
• Add water to the filter cake re-pulp tank according to instructions from
your supervisor and agitate contents of the tank until the filter cake is
fully re-pulped. Transfer the re-pulped filter cake slurry to the cake
washing tank according to instructions from your supervisor.
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: CaF2 Processing
2012
• Clean the filter press, close it up, and prepare it for its next filtration
cycle.
• Repeat, as needed, steps for filtering the contents of the filter cake acid
re-dissolution tank and dumping and re-pulping and transferring the
filter cake until the filter cake acid re-dissolution tank is empty.
• Transfer the clear supernatant liquid from the cake washing tank back
into the process to recover the contained uranium according to
instructions from your supervisor. Wash the filter cake solids in the
cake washing tank with water as instructed by your supervisor. Once
the washing of the filter cake solids is sufficient, transfer the solids
from the cake washing tank to tailings according to instructions from
your supervisor.
• Make sure a sample is taken of the underflow solids slurry transferred
from the cake washing tank to tailings.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
• Always keep your work area clean and ensure your work area is free
of obstructions.
(
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: CaF2 Processing
2012
Hazard Assessment Worksheet Node#8
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m_j
STEL mg/m3
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
}Iealth Rating
Hazard Rating
Impurity Removal Node
Process Material in Component
Uranium H2S04 Ammonia
1200-2400 50-500 100-250
2-4 93 100
------
--25
--35
0 0
40 20 20
Assessment Description: In this step, impurities will be separated from the uranium by
pH adjustment and precipitation, using ammonia, followed by settling and decantation.
REMEMBER Ammonia vapor, fumes and mists are Toxic Atmospheres and cannot
be detected by smell above approximately 100 ppm. IF you smell strong ammonia
fumes you must wear a full face respirator with universal cartridges and ventilate
the area. At high concentrations your skin and eyes can be burned. The beginning
solution and the precipitate are also radioactive and you must follow established
health physics controls. If any of the solution or precipitate gets on you, wash it off
with generous amounts of water.
To Tails -
Cell I
Impurity
Removal
Tank 1
Impurity
Removal
Tank 2
Product
Holding Tank
To Normal
Yellowcake
Precipitation
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: CaF2 Processing
2012
Operating Instructions
This node deals with the separation of uranium from impurities, by adjusting
pH with ammonia (NH3), to form a precipitate, allowing the precipitate to
settle to the bottom of the tank, and then decanting and pumping away the
clear liquid.
• Make a safety inspection of all lines and equipment.
• Inspect lines and tanks for leaks or seeps.
• Inspect safety showers and eyewash fountains
• Measure contained volume and then turn on the agitator and take a
sample of the tank contents for the impurity removal tank containing
the acid digestion liquor that has most recently been clarified by
filtration in the filter press. Place the sample in an appropriately
labeled sample bottle for analysis by the lab.
• Add steam, as necessary, to the contents of the impurity removal tank
according to instructions from your supervisor to establish and
maintain the target temperature for the tank contents. Add ammonia to
the contents of the impurity removal tank according to instructions
from your supervisor. Continue adding ammonia until the contents of
the tank reach and remain at the target pH, as instructed by your
supervisor, and then continue agitation for an additional 30 minutes.
• Tum off the agitator in the impurity removal tank and allow the
precipitate to settle according to instructions from your supervisor.
• Depending on the impurity being removed from the uranium, the
uranium may be contained in either the precipitate or in the
supernatant liquid. Once your supervisor has determined that the
precipitate in the impurity removal tank has settled sufficiently, begin
decanting the clear supernatant liquid from the tank.
• If the uranium is in the precipitate, then transfer the decanted liquid to
tailings as instructed by your supervisor. Be sure to take a sample of
the decanted liquid and record and report the volume of decanted
liquid. After the liquid is completely decanted as instructed by your
supervisor, add water to wash the precipitate as instructed by your
supervisor and agitate, settle and decant again. After washing the
No.: PBL-13 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page3of3
Date: December 18, Title: CaF2 Processing
2012
precipitate, add water and sulfuric acid to the precipitate as instructed
by your supervisor and agitate until the uranium is all re-dissolved.
Then either conduct other impurity removal steps on the liquor or
transfer it to the product holding tank.
• If the uranium is in the decanted liquid, then transfer the liquid to the
other impurity removal tank if addition impurity removal is needed, or
else transfer the liquid to the product holding tank. Once the decanting
is complete, add water, agitate, settle and decant again to wash the
precipitate, sending the liquid removed to the same tank as previously.
If the washed precipitate is sufficiently low in uranium, transfer it to
tailings as instructed by your supervisor. Otherwise, send the
precipitate to re-processing as instructed by your supervisor.
• Once impurities have been sufficiently removed and the liquor has
accumulated sufficiently in the product holding tank, transfer the
contents of the product holding tank slowly to the normal yellowcake
precipitation area of the plant. Each time a transfer from this tank
occurs, record and report the volume transferred and take a sample of
the liquor transferred in a properly marked sample container.
• Whenever working in, around or on this process circuit YOU MUST
wear PPE which includes at minimum Tyvex or Mill coveralls, rubber
boots or regular steel toed boots and gloves, safety eye glasses, a face
shield and may include full face respirators.
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES Page 1 of 1
Date: December Title: KOH Processing SOP
10, 2014
1.0 Summary
Energy Fuels Resources (USA) Incorporated's ("EFRI's") White Mesa Mill is authorized to
process alternate feed materials other than natural uranium ore under License Condition 10.7 of
Radioactive Materials License ("RML") UTl 900479. Pursuant to the conditions of the RML
and amendments, this procedure and the attached Node Worksheets describes the evaluations
and protocol for implementing operating parameters which will ensure the safety of operating
personnel and minimize radiological exposures to individuals and the environment to levels "As
Low as Reasonably Achievable" (A.L.A.R.A.).
2.0 Introduction
The RML allows the White Mesa Mill (located near Blanding, Utah) to possess, use, and transfer
source material in any form, including alternate feed materials. The source material from Allied
Signal Corporation of Metropolis, Illinois is an alternate feed material containing significant
quantities of uranium which will be recovered at the mill site. The Node Worksheets attached,
identify the standard protocol for receiving, handling, and initial processing of the KOH source
material. The Node Worksheets address the necessary administrative, safety, radiological,
industrial hygiene, and engineering controls, and measures which are required to receive, handle,
and introduce KOH/uranium material into initial process circuits.
The KOH process described in this SOP consists of 3 nodes -Drum Dumping, Acid Digest and
Filtration. The KOH material is a dry material containing 50-70% U30s. The material will be
fed to the process by way of the Submergible South Drum Dumper. The slurried material will be
leached in a mild acid leach at low temperature and then the resulting solution will be filtered
and accumulated for processing in the solvent extraction, precipitation and drying circuits. The
process steps and safety protocols are specified in the attached Node Worksheets.
/ (
No.: PBL-14
Rev. No.: R-1
Date: December 10,
2014
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
%U30s
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: KOH Drum Dumping Node
Hazard Assessment Worksheet
Drum Dumping-Node #1
Chemical Data
KOH Material
-
Ambient
Weak Oxidizer
-
Not Flammable
50-70
Page 1 of 2
Assessment Description: Drums containing the KOH material will be opened and fed to the
alternate feed by way of the Alternate Feed Circuit Submergible Drum Dumper. The KOH
material contains from 50%-70% U30 8• Breathing or ingesting this material should be avoided.
Contact with the skin should also be avoided. Operators and anyone in the area should wear
proper PPE to protect from these chemicals. In case of any contact, wash the area of
contact off with generous amounts of water.
Water
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 10, Title: KOH Drum Dumping Node
2014
Operating Instructions
This node deals with feeding the material to the alternate feed circuit
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the SDS. This means that you must read and understand the
information on the SDS and if you don't, ASK YOUR SUPERVISOR.
• Break the seal of the drums containing the KOH material
• Place drum on the scale and record the gross weight
• Engage rollers and position the drum to be lifted into the dump tank
• Remove lid and visually inspect the drum contents. Report and do not dump
any unusual looking material.
• Make sure that the dump tank has an appropriate amount of water. Add water
if needed.
• Engage the dumping mechanism and transfer the KOH material to the drum
dump tank.
• Make sure to remove all material from the drum and take care to feed drums
in such a way to avoid dusting of the KOH material.
• Once a sufficient amount of material has been transferred to the dump tank,
transfer the slurry to the digest tank. Before transferring, ensure that all
valves are in the appropriate position.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
(
No.: PBL-14
Rev. No.: R-1
Date: December 10,
2014
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
%U30s
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: KOH Acid Digest Node
Hazard Assessment Worksheet
Acid Digest -Node #2
Chemical Data
KOH Material Sulfuric Acid
4-5 <0
Ambient Ambient
Weak Oxidizer Oxidizer
-pumped line, low pressure
Not Flammable Not Flammable
50-70 0
Page 1 of2
Digest Slurry
1
<40
Oxidizer
Ambient
Not Flammable
5-15
Assessment Description: A slurry consisting of KOH material and water will be digested by
adding concentrated sulfuric acid to the slurry. Sulfuric acid is a strong acid and an oxidizer and
should be handled with caution. Any splashing or contact with this slurry before and after the
acid is added should be avoided. Operators and anyone in the area should wear proper PPE
to protect from these chemicals. In case of any contact, wash the area of contact off with
generous amounts of water.
Water
Sulfuric Acid Steam
Digest Tank
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 10, Title: KOH Acid Digest Node
2014
Operating Instructions
This node deals with digesting the KOH material in an acidic solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the SDS. This means that you must read and understand the
information on the SDS and if you don't, ASK YOUR SUPERVISOR.
• Check the level of the tank to ensure that adding water, sulfuric acid or steam
will not cause the tank to overflow.
• Add water to the tank if needed.
• Add steam to the tank if needed
• Open the valves to the acid line and add acid slowly to the tank. Add acid
until the appropriate pH has been reached.
• Allow the contents of the tank to agitate and digest for an appropriate amount
of time.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
No.: PBL-14
Rev. No.: R-1
Date: December 10,
2014
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
%U30s
ENERGY FUELS RESOURCES (USA) INC.
ST AND ARD OPERATING PROCEDURES
Title: KOH Filtration Node
Hazard Assessment Worksheet
Filtration -Node #3
Chemical Data
Filter Aid
-
Ambient
-
-
Not Flammable
0
Page 1 of2
Assessment Description: Digested KOH will be filtered and transferred to a solution holding
tank. This solution is acidic and should be handled with caution. Any splashing or contact with
this solution should be avoided. Operators and anyone in the area should wear proper PPE
to protect from these chemicals. In case of any contact, wash the area of contact off with
generous amounts of water.
Filter Aid
Digest Tank Solution Holding
Tank
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page2 of2
Date: December 10, Title: KOH Filtration Node
2014
Operating Instructions
This node deals with filtering and transferring the digest solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the SDS. This means that you must read and understand the
information on the SDS and if you don't, ASK YOUR SUPERVISOR.
• Prepare the filter press to receive solution from the digest tank. Visually
inspect the filter cloths and ensure that all valves are in the correct positions.
Also, ensure that press plates are positioned properly.
• If necessary, pre-coat the filter press with filter aid.
• If necessary, add filter aid to the digest tank.
• Pump the contents from the digest tank to the filter press.
• Ensure that the solution leaving the filter press is clear and is being transferred
to the appropriate holding tank.
• Further processing of this material beyond this point will consist of the typical
solvent extraction, precipitation and drying circuits used for ore and other
alternate feed materials.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 1 of 4 BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
1. Purpose
The following procedure applies to the release and shipping of all vanadium in the form
ofblackflake from the restricted area of the White Mesa Mill (the "Mill"). Energy Fuels
Resources (USA) Inc. ("EFR") produces or has produced vanadium in three forms:
blackflake, vanadium pregnant liquor ("VPL") and ammonium metavanadate ("AMV").
This procedure addresses release of vanadium blackflake only. Release ofVPL or AMV
may only be accomplished in accordance with separate procedures relating specifically to
those forms of vanadium. The purpose of this procedure is to ensure that no lot of
vanadium blackflake is released from the Mill's restricted area unless: a) it has an
average source material content of less than 0.05%; and b) the applicable requirements of
NRC Regulatory guide 1.86 and 10 CFR Part 20 are satisfied.
2. Form of Container
2 .1. Vanadium blackflake shall be packaged in 5 5 gallon metal drums, each drum
containing the customer specified amount of vanadium.
3. Sampling and Analysis for Source Material Content
3.1.
3.2.
3.3.
Drums shall be assembled into lots for shipment.
A composite sample of all of the drums in each lot must be taken and analyzed as
follows:
a)
b)
c)
d)
Obtain an equal volume sample from each individual drum in the lot
and composite them into a single sample;
Submit the composite sample to the EFR laboratory for sample
preparation;
Perform a radiological analysis on the composite sample for total
uranium and total thorium;
A copy of the analysis shall be attached to the Source Material Assay
and Radiological Survey of Vanadium Form.
Under no circumstances may a lot of vanadium that has a composite sample with
a combined weight percent uranium and thorium of 0.05% or greater be released
from the Mill's restricted area, unless it is released to a facility that has an
appropriate source material license and the material is being released to such
licensee in accordance with that license.
4. Preparing Black:flake Drums and Shipping
4.1. Move all drums from stacked lots and place them on the ground so that the sides
and tops can be easily inspected and prepared as necessary. The bottoms of the
drums are to be inspected by lifting the drums with a barrel grab and visually
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\Release of Vanadium Blackflake\PBL-15_Blackflake
Release SOP rev 3.doc
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of 4 BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
checking for leaks and rust. Do not get under the drums when checking or
cleaning and painting the bottoms.
4.2. After the drums are placed on the ground, check that lids and rings are properly
secured and tightened.
4.3. Ensure strong, tight packaging-i.e., no holes in any of the containers. Notify
your supervisor if there are any holes in the containers.
4.4. Paint drums if necessary.
4.5. Ensure that appropriate labeling is properly attached to each drum.
4.6. Check the drum number, date, lot number, gross weight, tare weight, and net
weight on the tops and/or sides of each drum against the numbers on the drum
list that will be attached to the Bill of Lading. If numbers do not match exactly,
notify your supervisor.
5. Product Shipment Surveys
5.1. Prior to shipment release, the Radiation Safety Department will survey
blackflake product shipments from the facility. No shipments will be released
prior to the Radiation Safety Department's authorization.
5.2. Equipment, scanning procedures and equipment calibration used for blackflake
product shipment surveys is detailed in the Radiation Protection Manual, Book 9.
5.3. Drums shall be cleaned prior to the radiation surveys.
5.4. Drums requiring repair shall be repaired prior to the radiation surveys.
5.5. The following surveys shall be performed:
5.5.1. Alpha Surveys;
a) Perform a total and removable alpha survey of each drum, using the
procedures and equipment specified in Section 6.0 of the Mill's Radiation
Protection Manual. The release limits for total and removable alpha radiation
contamination is an average of 5,000 dpm/100 cm2 and a maximum of 15,000
dpm/100 cm2. Any drum that exceeds 1,000 dpm/100cm2 total alpha radiation
contamination requires a removable alpha smear/wipe test to be performed;
b) Perform a removable alpha survey on any barrel exceeding 1,000 dpm/100
cm2 total alpha contamination. The release ltmit for removable alpha
contamination is 1,000 dpm/100 cm2• Perform a smear/wipe test and analyze
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\Release of Vanadium Blacldlake\PBL-15_Blackflake
Release SOP rev 3.doc
(
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of 4
BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
filters for removable alpha on 25% of the barrels at a minimum, and perform a
smear/wipe test and analyze the filters for removable alpha on any barrels that
exceed 1,000 dpm/100 cm2 fixed contamination;
c) Record the results of the foregoing alpha surveys on the attached Source
Material Assay and Radiological Survey of Vanadium Form; and
d) Any drums with visible contamination are to be cleaned prior to release.
5.5.2. Gamma Surveys:
a) Perform a gamma survey of each drum on contact with the surface of the
drum and record the results on the appropriate spaces on the attached Source
Material Assay and Radiological Survey of Vanadium Form. No drum that
has an average contact gamma radiation exposure rate in excess of 2 mrad/hr
shall be released from the restricted area of the Mill;
b) Calculate the average contact gamma dose rate for the lot by summing the
value calculated for each drum in the lot under paragraph 5.5.2 a) above and
by dividing the sum by the number of drums in the lot. Record this average
contact gamma dose rate for the lot on the appropriate space on the attached
Source Material Assay and Radiological Survey of Vanadium Form; and
c) No lot of 72, 55 gallon blackflake drums will be permitted to be released from
the Mill's restricted area unless the average contact gamma dose rate for the
lot, calculated over all drums in the lot pursuant to paragraph 5.5.2 b), does
not exceed 0.907 mrad/hr. If a lot size is different than 72, 55 gallon drums of
blackflake, then the RSO will determine an equivalent calculation, based on
the analysis used to determine the 0.907 mrad/hr, to be used as the permitted
average contact gamma dose rate for such lot.
5.6. If any lot is shipped in more than one shipment, the RSO shall ensure that the
average contact gamma dose rate for the drums in each shipment is comparable
to the average contact gamma dose rate for the lot.
6. Loading Drums Onto the Truck
6.1. After the drums have been surveyed, load the drums into the transport vehicle
using appropriate Mill mobile equipment.
6.2. Brace the load of drums as may be required for transport.
6.3. If the transport vehicle has entered the Mill's restricted area, then prior to the
truck leaving the restricted area, the truck will be scanned as per PBL-2,
Intermodal Container Acceptance, Handling & Release.
6.4. Ensure that the shipment has been properly placarded.
F:\Mill SOP Master Copy\Book IO_PBL Sops\EFR\Release of Vanadium Blackflake\PBL-15_Blackflake
Release SOP rev 3.doc
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 4 of 4 BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
6.5. Fill out the appropriate transportation paperwork for the shipment. Provide a
copy of the shipping packet to the driver and maintain a copy for the Mill. The
paperwork to be provided to the driver shall not include the Source Material
Assay and Radiological Survey of Vanadium Form.
7. Hazard Identification and Safety
7 .1. All safety precautions for material loading operations must be observed,
including: securing the loading ramp, and using mobile equipment, and drum
stacking precautions.
8. Paperwork Tracking
8.1. The attached Source Material Assay and Radiological Survey of Vanadium Form
shall be completed for each lot that is shipped, and shall be maintained in the
Mill's central files for inspection. Do not permit any vanadium to leave the
restricted area unless:
a) the attached Source Material Assay and Radiological Survey of Vanadium
Form has been completed, with assay results attached;
b) the Source Material weight percent, as indicated on the Form, is less than
0.05%;
c) the Average Dose Rate/Lot, as indicated on the Form, does not exceed 0.907
mrad/hr, or such other value as may be determined by the RSO under Section
5.5.2 c) above;
d) the Maximum Dose Rate/Lot, as indicated on the Form, does not exceed 2
mrad/hr; and
e) the alpha survey results indicated on the Form comply with the release
standards described in Section 5.5.1 above.
F: \Mill SOP Master Copy\Book 10 _PBL Sops\EFR \Release of Vanadium Blackflake\PBL-15 _Blackflake
Release SOP rev 3.doc
(
(
Date:
Surveyed By:
Total
Alpha
Instrument:
SN
Cal. Date:
( . I ~£ f , J' ENERGY FUELS RESOURCES
Source Material Assay
&
Radiological Survey of Vanadium
----
Source Material Assay
Total Weight% U:
Total Weight % Th:
Total Source Material:
Removable
Alpha
Model:
SN:
Cal. Date:
Function Check ( 5 x 1 min.)
Th 230 @ 33,000 dpm
Alpha Bkg Ave:
Alpha eff: ----
Bkg Average:
Dpm Average:
~,11)A:
Total
Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
Background:
----
----
Alpha Factor:
MDA:
Total
Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
Background:
See Attached
See Attached
See Attached
·Note:
Laboratory assay results for this lot of vanadium product are attached.
Comments:
F:\Mill SOP Master Copy\Book 1 O_PBL Sops\EFR\Release of Vanadium Blackflake\PBL-15_ Vanadium Shipment
Form (04192013)
LOT NO. DATE
BACKGROUND EFFICIENCY FACTOR
Drum Total Alpha Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
1ber dpm/100cm2 dpm/100cm2 Toos Sides
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
Average Gamma Dose Rate/Lot ______ _
:imum Gamma Dose Rate/Lot _____ _
E:\Mill SOP Master Copy\Book 10_PBL Sops\PBL-15\PBL-15_ Vanadium Shipment Form (10.18.10)
I
DATE
BACKGROUND
Total Alpha l o.rum
nber dpm/100cm2
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
LOT NO.
EFFICIENCY FACTOR
Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
dpm/100cm2 Tops Sides
E:\Mill SOP Master Copy\Book 10_PBL Sops\PBL-15\PBL-15_Vanadium Shipment Form (10.18.10)
DATE
BACKGROUND
/Drum Total Alpha
nber dpm/100cm2
67
68
69
70
71
72
l
LOT NO.
EFFICIENCY FACTOR
Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
dpm/100cm2 Toos Sides
E:\Mill SOP Master Copy\Book 10_PBL Sops\PBL-15\PBL-15_ Vanadium Shipment Form (10.18.10}
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES Page 1 of 1
Date: December Title: KOH Processing SOP
10, 2014
1.0 Summary
Energy Fuels Resources (USA) Incorporated's ("EFRI's") White Mesa Mill is authorized to
process alternate feed materials other than natural uranium ore under License Condition 10.7 of
Radioactive Materials License ("RML") UTl 900479. Pursuant to the conditions of the RML
and amendments, this procedure and the attached Node Worksheets describes the evaluations
and protocol for implementing operating parameters which will ensure the safety of operating
personnel and minimize radiological exposures to individuals and the environment to levels "As
Low as Reasonably Achievable" (A.L.A.R.A.).
2.0 Introduction
The RML allows the White Mesa Mill (located near Blanding, Utah) to possess, use, and transfer
source material in any form, including alternate feed materials. The source material from Allied
Signal Corporation of Metropolis, Illinois is an alternate feed material containing significant
quantities of uranium which will be recovered at the mill site. The Node Worksheets attached,
identify the standard protocol for receiving, handling, and initial processing of the KOH source
material. The Node Worksheets address the necessary administrative, safety, radiological,
industrial hygiene, and engineering controls, and measures which are required to receive, handle,
and introduce KOH/uranium material into initial process circuits.
The KOH process described in this SOP consists of 3 nodes -Drum Dumping, Acid Digest and
Filtration. The KOH material is a dry material containing 50-70% U30s. The material will be
fed to the process by way of the Submergible South Drum Dumper. The slurried material will be
leached in a mild acid leach at low temperature and then the resulting solution will be filtered
and accumulated for processing in the solvent extraction, precipitation and drying circuits. The
process steps and safety protocols are specified in the attached Node Worksheets.
/ (
No.: PBL-14
Rev. No.: R-1
Date: December 10,
2014
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
%U30s
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: KOH Drum Dumping Node
Hazard Assessment Worksheet
Drum Dumping-Node #1
Chemical Data
KOH Material
-
Ambient
Weak Oxidizer
-
Not Flammable
50-70
Page 1 of 2
Assessment Description: Drums containing the KOH material will be opened and fed to the
alternate feed by way of the Alternate Feed Circuit Submergible Drum Dumper. The KOH
material contains from 50%-70% U30 8• Breathing or ingesting this material should be avoided.
Contact with the skin should also be avoided. Operators and anyone in the area should wear
proper PPE to protect from these chemicals. In case of any contact, wash the area of
contact off with generous amounts of water.
Water
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 10, Title: KOH Drum Dumping Node
2014
Operating Instructions
This node deals with feeding the material to the alternate feed circuit
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the SDS. This means that you must read and understand the
information on the SDS and if you don't, ASK YOUR SUPERVISOR.
• Break the seal of the drums containing the KOH material
• Place drum on the scale and record the gross weight
• Engage rollers and position the drum to be lifted into the dump tank
• Remove lid and visually inspect the drum contents. Report and do not dump
any unusual looking material.
• Make sure that the dump tank has an appropriate amount of water. Add water
if needed.
• Engage the dumping mechanism and transfer the KOH material to the drum
dump tank.
• Make sure to remove all material from the drum and take care to feed drums
in such a way to avoid dusting of the KOH material.
• Once a sufficient amount of material has been transferred to the dump tank,
transfer the slurry to the digest tank. Before transferring, ensure that all
valves are in the appropriate position.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
(
No.: PBL-14
Rev. No.: R-1
Date: December 10,
2014
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
%U30s
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: KOH Acid Digest Node
Hazard Assessment Worksheet
Acid Digest -Node #2
Chemical Data
KOH Material Sulfuric Acid
4-5 <0
Ambient Ambient
Weak Oxidizer Oxidizer
-pumped line, low pressure
Not Flammable Not Flammable
50-70 0
Page 1 of2
Digest Slurry
1
<40
Oxidizer
Ambient
Not Flammable
5-15
Assessment Description: A slurry consisting of KOH material and water will be digested by
adding concentrated sulfuric acid to the slurry. Sulfuric acid is a strong acid and an oxidizer and
should be handled with caution. Any splashing or contact with this slurry before and after the
acid is added should be avoided. Operators and anyone in the area should wear proper PPE
to protect from these chemicals. In case of any contact, wash the area of contact off with
generous amounts of water.
Water
Sulfuric Acid Steam
Digest Tank
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 10, Title: KOH Acid Digest Node
2014
Operating Instructions
This node deals with digesting the KOH material in an acidic solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the SDS. This means that you must read and understand the
information on the SDS and if you don't, ASK YOUR SUPERVISOR.
• Check the level of the tank to ensure that adding water, sulfuric acid or steam
will not cause the tank to overflow.
• Add water to the tank if needed.
• Add steam to the tank if needed
• Open the valves to the acid line and add acid slowly to the tank. Add acid
until the appropriate pH has been reached.
• Allow the contents of the tank to agitate and digest for an appropriate amount
of time.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
No.: PBL-14
Rev. No.: R-1
Date: December 10,
2014
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
%U30s
ENERGY FUELS RESOURCES (USA) INC.
ST AND ARD OPERATING PROCEDURES
Title: KOH Filtration Node
Hazard Assessment Worksheet
Filtration -Node #3
Chemical Data
Filter Aid
-
Ambient
-
-
Not Flammable
0
Page 1 of2
Assessment Description: Digested KOH will be filtered and transferred to a solution holding
tank. This solution is acidic and should be handled with caution. Any splashing or contact with
this solution should be avoided. Operators and anyone in the area should wear proper PPE
to protect from these chemicals. In case of any contact, wash the area of contact off with
generous amounts of water.
Filter Aid
Digest Tank Solution Holding
Tank
No.: PBL-14 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page2 of2
Date: December 10, Title: KOH Filtration Node
2014
Operating Instructions
This node deals with filtering and transferring the digest solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the SDS. This means that you must read and understand the
information on the SDS and if you don't, ASK YOUR SUPERVISOR.
• Prepare the filter press to receive solution from the digest tank. Visually
inspect the filter cloths and ensure that all valves are in the correct positions.
Also, ensure that press plates are positioned properly.
• If necessary, pre-coat the filter press with filter aid.
• If necessary, add filter aid to the digest tank.
• Pump the contents from the digest tank to the filter press.
• Ensure that the solution leaving the filter press is clear and is being transferred
to the appropriate holding tank.
• Further processing of this material beyond this point will consist of the typical
solvent extraction, precipitation and drying circuits used for ore and other
alternate feed materials.
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 1 of 4 BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
1. Purpose
The following procedure applies to the release and shipping of all vanadium in the form
ofblackflake from the restricted area of the White Mesa Mill (the "Mill"). Energy Fuels
Resources (USA) Inc. ("EFR") produces or has produced vanadium in three forms:
blackflake, vanadium pregnant liquor ("VPL") and ammonium metavanadate ("AMV").
This procedure addresses release of vanadium blackflake only. Release ofVPL or AMV
may only be accomplished in accordance with separate procedures relating specifically to
those forms of vanadium. The purpose of this procedure is to ensure that no lot of
vanadium blackflake is released from the Mill's restricted area unless: a) it has an
average source material content of less than 0.05%; and b) the applicable requirements of
NRC Regulatory guide 1.86 and 10 CFR Part 20 are satisfied.
2. Form of Container
2 .1. Vanadium blackflake shall be packaged in 5 5 gallon metal drums, each drum
containing the customer specified amount of vanadium.
3. Sampling and Analysis for Source Material Content
3.1.
3.2.
3.3.
Drums shall be assembled into lots for shipment.
A composite sample of all of the drums in each lot must be taken and analyzed as
follows:
a)
b)
c)
d)
Obtain an equal volume sample from each individual drum in the lot
and composite them into a single sample;
Submit the composite sample to the EFR laboratory for sample
preparation;
Perform a radiological analysis on the composite sample for total
uranium and total thorium;
A copy of the analysis shall be attached to the Source Material Assay
and Radiological Survey of Vanadium Form.
Under no circumstances may a lot of vanadium that has a composite sample with
a combined weight percent uranium and thorium of 0.05% or greater be released
from the Mill's restricted area, unless it is released to a facility that has an
appropriate source material license and the material is being released to such
licensee in accordance with that license.
4. Preparing Black:flake Drums and Shipping
4.1. Move all drums from stacked lots and place them on the ground so that the sides
and tops can be easily inspected and prepared as necessary. The bottoms of the
drums are to be inspected by lifting the drums with a barrel grab and visually
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\Release of Vanadium Blackflake\PBL-15_Blackflake
Release SOP rev 3.doc
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of 4 BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
checking for leaks and rust. Do not get under the drums when checking or
cleaning and painting the bottoms.
4.2. After the drums are placed on the ground, check that lids and rings are properly
secured and tightened.
4.3. Ensure strong, tight packaging-i.e., no holes in any of the containers. Notify
your supervisor if there are any holes in the containers.
4.4. Paint drums if necessary.
4.5. Ensure that appropriate labeling is properly attached to each drum.
4.6. Check the drum number, date, lot number, gross weight, tare weight, and net
weight on the tops and/or sides of each drum against the numbers on the drum
list that will be attached to the Bill of Lading. If numbers do not match exactly,
notify your supervisor.
5. Product Shipment Surveys
5.1. Prior to shipment release, the Radiation Safety Department will survey
blackflake product shipments from the facility. No shipments will be released
prior to the Radiation Safety Department's authorization.
5.2. Equipment, scanning procedures and equipment calibration used for blackflake
product shipment surveys is detailed in the Radiation Protection Manual, Book 9.
5.3. Drums shall be cleaned prior to the radiation surveys.
5.4. Drums requiring repair shall be repaired prior to the radiation surveys.
5.5. The following surveys shall be performed:
5.5.1. Alpha Surveys;
a) Perform a total and removable alpha survey of each drum, using the
procedures and equipment specified in Section 6.0 of the Mill's Radiation
Protection Manual. The release limits for total and removable alpha radiation
contamination is an average of 5,000 dpm/100 cm2 and a maximum of 15,000
dpm/100 cm2. Any drum that exceeds 1,000 dpm/100cm2 total alpha radiation
contamination requires a removable alpha smear/wipe test to be performed;
b) Perform a removable alpha survey on any barrel exceeding 1,000 dpm/100
cm2 total alpha contamination. The release ltmit for removable alpha
contamination is 1,000 dpm/100 cm2• Perform a smear/wipe test and analyze
F:\Mill SOP Master Copy\Book lO_PBL Sops\EFR\Release of Vanadium Blacldlake\PBL-15_Blackflake
Release SOP rev 3.doc
(
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of 4
BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
filters for removable alpha on 25% of the barrels at a minimum, and perform a
smear/wipe test and analyze the filters for removable alpha on any barrels that
exceed 1,000 dpm/100 cm2 fixed contamination;
c) Record the results of the foregoing alpha surveys on the attached Source
Material Assay and Radiological Survey of Vanadium Form; and
d) Any drums with visible contamination are to be cleaned prior to release.
5.5.2. Gamma Surveys:
a) Perform a gamma survey of each drum on contact with the surface of the
drum and record the results on the appropriate spaces on the attached Source
Material Assay and Radiological Survey of Vanadium Form. No drum that
has an average contact gamma radiation exposure rate in excess of 2 mrad/hr
shall be released from the restricted area of the Mill;
b) Calculate the average contact gamma dose rate for the lot by summing the
value calculated for each drum in the lot under paragraph 5.5.2 a) above and
by dividing the sum by the number of drums in the lot. Record this average
contact gamma dose rate for the lot on the appropriate space on the attached
Source Material Assay and Radiological Survey of Vanadium Form; and
c) No lot of 72, 55 gallon blackflake drums will be permitted to be released from
the Mill's restricted area unless the average contact gamma dose rate for the
lot, calculated over all drums in the lot pursuant to paragraph 5.5.2 b), does
not exceed 0.907 mrad/hr. If a lot size is different than 72, 55 gallon drums of
blackflake, then the RSO will determine an equivalent calculation, based on
the analysis used to determine the 0.907 mrad/hr, to be used as the permitted
average contact gamma dose rate for such lot.
5.6. If any lot is shipped in more than one shipment, the RSO shall ensure that the
average contact gamma dose rate for the drums in each shipment is comparable
to the average contact gamma dose rate for the lot.
6. Loading Drums Onto the Truck
6.1. After the drums have been surveyed, load the drums into the transport vehicle
using appropriate Mill mobile equipment.
6.2. Brace the load of drums as may be required for transport.
6.3. If the transport vehicle has entered the Mill's restricted area, then prior to the
truck leaving the restricted area, the truck will be scanned as per PBL-2,
Intermodal Container Acceptance, Handling & Release.
6.4. Ensure that the shipment has been properly placarded.
F:\Mill SOP Master Copy\Book IO_PBL Sops\EFR\Release of Vanadium Blackflake\PBL-15_Blackflake
Release SOP rev 3.doc
No.: PBL-15 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 4 of 4 BookNo. 8 Title: Release and Shipping of Vanadium Blackflake Date: April 19,
2013
6.5. Fill out the appropriate transportation paperwork for the shipment. Provide a
copy of the shipping packet to the driver and maintain a copy for the Mill. The
paperwork to be provided to the driver shall not include the Source Material
Assay and Radiological Survey of Vanadium Form.
7. Hazard Identification and Safety
7 .1. All safety precautions for material loading operations must be observed,
including: securing the loading ramp, and using mobile equipment, and drum
stacking precautions.
8. Paperwork Tracking
8.1. The attached Source Material Assay and Radiological Survey of Vanadium Form
shall be completed for each lot that is shipped, and shall be maintained in the
Mill's central files for inspection. Do not permit any vanadium to leave the
restricted area unless:
a) the attached Source Material Assay and Radiological Survey of Vanadium
Form has been completed, with assay results attached;
b) the Source Material weight percent, as indicated on the Form, is less than
0.05%;
c) the Average Dose Rate/Lot, as indicated on the Form, does not exceed 0.907
mrad/hr, or such other value as may be determined by the RSO under Section
5.5.2 c) above;
d) the Maximum Dose Rate/Lot, as indicated on the Form, does not exceed 2
mrad/hr; and
e) the alpha survey results indicated on the Form comply with the release
standards described in Section 5.5.1 above.
F: \Mill SOP Master Copy\Book 10 _PBL Sops\EFR \Release of Vanadium Blackflake\PBL-15 _Blackflake
Release SOP rev 3.doc
(
(
Date:
Surveyed By:
Total
Alpha
Instrument:
SN
Cal. Date:
( . I ~£ f , J' ENERGY FUELS RESOURCES
Source Material Assay
&
Radiological Survey of Vanadium
----
Source Material Assay
Total Weight% U:
Total Weight % Th:
Total Source Material:
Removable
Alpha
Model:
SN:
Cal. Date:
Function Check ( 5 x 1 min.)
Th 230 @ 33,000 dpm
Alpha Bkg Ave:
Alpha eff: ----
Bkg Average:
Dpm Average:
~,11)A:
Total
Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
Background:
----
----
Alpha Factor:
MDA:
Total
Gamma
Model#:
SN:
Cal. Date:
Source:
Reading:
Background:
See Attached
See Attached
See Attached
·Note:
Laboratory assay results for this lot of vanadium product are attached.
Comments:
F:\Mill SOP Master Copy\Book 1 O_PBL Sops\EFR\Release of Vanadium Blackflake\PBL-15_ Vanadium Shipment
Form (04192013)
LOT NO. DATE
BACKGROUND EFFICIENCY FACTOR
Drum Total Alpha Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
1ber dpm/100cm2 dpm/100cm2 Toos Sides
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
Average Gamma Dose Rate/Lot ______ _
:imum Gamma Dose Rate/Lot _____ _
E:\Mill SOP Master Copy\Book 10_PBL Sops\PBL-15\PBL-15_ Vanadium Shipment Form (10.18.10)
I
DATE
BACKGROUND
Total Alpha l o.rum
nber dpm/100cm2
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
LOT NO.
EFFICIENCY FACTOR
Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
dpm/100cm2 Tops Sides
E:\Mill SOP Master Copy\Book 10_PBL Sops\PBL-15\PBL-15_Vanadium Shipment Form (10.18.10)
DATE
BACKGROUND
/Drum Total Alpha
nber dpm/100cm2
67
68
69
70
71
72
l
LOT NO.
EFFICIENCY FACTOR
Removable Alpha Dose Rate mr/hr Dose Rate mr/hr
dpm/100cm2 Toos Sides
E:\Mill SOP Master Copy\Book 10_PBL Sops\PBL-15\PBL-15_ Vanadium Shipment Form (10.18.10}
(
No.: PBL-16 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-1
Date: February 2, ST AND ARD OPERATING PROCEDURES Page 1 of 1
2016 Title: Dawn Mining Processing SOP
1.0Summary
Energy Fuels Resources (USA) Incorporated's ("EFRI's") White Mesa Mill is authorized to
process alternative feed materials other than natural uranium ore under License Condition 10.20
of Radioactive Materials License ("RML") UT1900479. Pursuant to the conditions of the RML
and amendments, this procedure and the attached Node Worksheets describe the evaluations and
protocol for implementing operating parameters which will ensure the safety of operating
personnel and minimize radiological exposures to individuals and the environment to levels "As
Low as Reasonably Achievable" (ALARA).
2.0 Introduction
The RML allows the White Mesa Mill (located near Blanding, Utah) to possess, use, and transfer
source material in any form, including alternate feed materials. The source material from Dawn
Mining is an alternate feed from a decommissioned uranium recovery facility near Ford,
Washington. The Node Worksheets attached identify the standard procedure for initial
processing of the Dawn Mining material. The Node Worksheets address necessary
administrative, safety, radiological, industrial hygiene, engineering controls, and measures which
are required to introduce Dawn Mining material into process circuits.
The Dawn Mining process described in this SOP consists of one node: Dumping and Acid
Digest. The Dawn Mining material is a dry material containing 1.2-1.5% U30 8. The material will
be feed 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. Process steps and safety protocols are specified in the attached Node Worksheets.
(
No.: PBL-23 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-1 ST AND ARD OPERATING PROCEDURES Page 1 of 2 Date: February 1,
2016 Title: Dawn Mining Dumping and Acid Digest Node
Material
pH
Temperature
Oxidizer/Reducer
Pressure
Flashpoint
U30s Grade
Hazard Assessment Worksheet
Dumping and Acid Digest-Node #1
Chemical Data
Dawn Mining Sulfuric Acid
Material
8 <0
Ambient Ambient
Weak oxidizer Oxidizer
-Low pressure line
Not flammable Not flammable
1.2-1.4% 0
Digest Slurry
0.5-1.0
Ambient
Oxidizer
Ambient
Not flammable
1.0-1.5 g/L
Assessment Description: Dawn Mining material will be fed to the process by dumping super
sacks into a tank. The material contains low grades of uranium and breathing or ingesting the
material should be avoided. A slurry consisting of Dawn Mining material, water, and pond return
will be digested with concentrated sulfuric acid. Sulfuric acid is a strong oxidizer and strong acid
and should be handled with caution. Any contact with the slurry before and after acid addition
should be avoided. Operators and anyone in the area should wear proper PPE to protect
from these substances. In case of contact with any of these substances, wash the exposed
area with generous amounts of water.
Sulfuric Acid
Water and/or Pond Return
Dawn Mining
Material Digest Tank
No.: PBL-23 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-1
Date: February 1, ST AND ARD OPERATING PROCEDURES Page 2 of 2
2016 Title: Dawn Mining Dumping and Acid Digest Node
Operating Instructions
This node deals with feeding the material into the circuit and digesting the material in an acidic
solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash stations.
o Always keep your work area clean and ensure your area is free of hazardous
obstructions. Always read and follow all parameters listed on the SDS. This
means that you must read and understand the information on the SDS. If you
don't understand, ask your supervisor.
• Check the level of the tank to ensure that adding Dawn Mining material, water, pond
return, or sulfuric acid will not cause the tank to overflow.
• Suspend the Dawn Mining super sack over the top of the tank.
• Open the bottom of the super sack and allow the material to empty into the tank.
• Add water and/or pond return to the tank if needed.
• Open the acid line valves and add acid to the tank slowly until the target pH has been
reached.
• Agitate the contents of the tank and add acid as necessary to maintain pH.
• Be sure to wear appropriate PPE at all times when working on or around this process.
• Always keep your work area clean and free of obstructions.
After acid digest, the leach solution will be decanted and fed to the Uranium Solvent Extraction
circuit. The SOP for Uranium Solvent Extraction is detailed in SOP Book 4, in the document
titled Uranium SX. The uranium solution is then fed from Uranium Solvent Extraction to
Precipitation and Drying. The SOP for Uranium Precipitation and Drying is detailed in SOP
Book 5.
f
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 1
Date: December 18, Title: Calcine Material Overview
2012
Standard Operating Procedures for Calcine Material Uranium Extraction Process
The following standard operating procedures (SOP) for the uranium extraction from
Calcined Byproduct material is attached. The chemical makeup and the uranium
precipitation circuits follow the conventional standard operating procedures already in
place at the White Mesa Mill. These operating procedures are summarized by nodes with
the hazards, PPE, cautionary statements and operating instructions for each node. A node
is a phase of recovery in the overall process and is indicated by graphic presentation of
the process flow. A block flow diagram of the overall process is also attached.
There are general considerations that are applicable to all process nodes. They are:
• Lines and Pumps
All lines, pumps and valves must be used according to specific operating
instructions that will be issued as required during process evaluations and
recovery.
• Specific Operating Instructions
Specific operating instructions apply to each process node based upon the
metallurgical requirements necessary for recover of an on-specification product.
These instructions will change periodically after operating process and parameters
have been determined.
• Ventilation
It is necessary that at each stage of processing and location the ventilation system
is checked and is running. This is extremely important because there is always a
potential for toxic gas and vapors to be generated.
• Hazard Assessment Worksheet
Each hazard assessment work sheet identifies hazardous parameters for each
node, such as operating temperature, pressure and radioactive content of each
stream. The overall hazard rating is based on quantity of chemical, phase of the
chemical (gas, solid, and liquid) and the MSDS health rating for each chemical.
The overall health rating is the sum of the three ratings.
• Personnel Protective Equipment (PPE)
PPE is identified on each node and is accompanied by cautionary statements of
each important hazardous chemical.
This information will be presented to all operations personnel and any questions
regarding this information will be answered.
This SOP may be modified as necessary by a radiation work permit (RWP) which would
establish new procedures and requirements during the processing of the Calcine material.
(
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2
Date: December 18,
2012
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m3
STEL mg/m3
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
STANDARD OPERATING PROCEDURES Page 1 of 3
Title: Calcine Drum Dumping Node
Hazard Assessment Worksheet
Calcine Drum Dumping Node
Node 1
Process Material in Component
Calcine Calcine Calcine
400/drum 4000/dump 160,000/pulp
tank storage tank
100 40 20
------
2.5 2.5 2.5
NL NL NL
5,000 5000 5000
Amb Amb AMB
0-100 0-100 0-100
2 2 2
3 4 5
Assessment Description: This material is high in uranium and produces a very fine
powder. Dusting and contamination should be avoided. NOTE: Whenever working in,
around or on this process circuit YOU MUST wear PPB which includes at minimum
Tyvex coveralls, rubber boots and gloves, safety glasses, face shield and may include full
face respirators as instructed by the RSO or your supervisor.
REMEMBER Calcine material is radioactive and you must follow established
health physics controls as directed by the RSO. Keep the material wet at all times
and if any solution gets on you wash it off with plenty of water. If you have any
questions about what you must wear or do when dumping drums ask your
supervisor or the RSO.
No.: PBL-17
Rev. No.: 2
Date: December 18,
2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Calcine Drum Dumping Node
Drum dumping
station
Operating Instructions
To Pulp
Tank
Page 2 of 3
The various types of material in the drums must be closely monitored to make certain that
only Calcine material is dumped into the circuit. This is important because this material
may react with designed recovery process chemicals if it is different than Calcine
material and may react violently.
• Supervisor will inform you if there is any reason to suspend operations at the start
of shift or during shift.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
o Report any damage or maintenance problem to supervisor and/or other
appropriate departments.
• Turn on the drum dumper and weigh scale.
• Confirmation of material will be performed during drum transport to dumping
area.
• Unfasten the lid carefully and report any unusual pressure release.
• Visually confirm material is Calcine by-product.
• Weigh and record the drum weight.
(
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Calcine Drum Dumping Node
2012
• Take a sample from the drum and place it in the sample container for the daily
drum composite.
• Any drummed material that may present a problem in dumping (for example,
solidified material) set aside. Supervisor will inform operator what will be done
with these drums.
• Add the appropriate amount of water as instructed by the supervisor.
• Place the drum securely in the drum dumper. Make sure the dumper water sprays
are operating before and during the dumping of any drum of Calcine material.
Take any other necessary measures for dust control during drum dumping as
instructed by your supervisor. Actuate the dumper as instructed by your
supervisor, thus emptying the drum into the dumper tank.
• Upon accumulating enough of the dumped Calcine material in the dumper tank,
transfer the material to the pulp storage tanks as instructed by the supervisor.
• Insure that the tank level in the pulp storage tank is above the agitator before
starting the agitator.
• Agitate the slurry of Calcine material and water as instructed by the supervisor.
• Continue dumping drums and transferring the slurry of Calcine material to the
pulp storage tanks until the target level in the tanks or the daily target of drums to
be dumped is reached as instructed by the supervisor.
• Shut down the dumper station and clean out the equipment pertaining to the
dumper station as instructed by the supervisor.
(
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2
Date: December 18,
2012
Equipment Component
Individual Equipment No.
Parameter per Tank
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m:;
STEL mg/m.:,
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Health Hazard
STANDARD OPERATING PROCEDURES
Title: Calcine Acid Leach Node
Hazard Assessment Worksheet
Calcine Acid Leach Node
Node2
Page 1 of 3
Process Material in Component
H2S04 U30s
61,300 5,200
8 0.6
--
1.0
3.0
0
80 80
0-100
3
7
Assessment Description: Addition of acid to a target of 60-80 gpl free acid and addition of live
steam to a target of 80°C to the first leach tank. Operators should protect themselves from
possible splashing of the leach tank contents, due to temperature, acidity, and radioactivity.
Whenever working in, around or on this process circuit the operator must wear PPB, which may
include Tyvex or Mill coveralls, rubber boots or regular steel toed boots, protective gloves, and
safety glasses. A face shield or a full face respirator maybe be required as instructed by the RSO
or your supervisor.
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Calcine Acid Leach Node
2012
Water
Sulfuric Acid
Slurry From Dumping Station
Steam
Boiler
Calcine Leach Pulp StorageTank
Solid / Liquid Separation
Operating Instructions
This node deals with the leaching of the Calcine material.
• At the beginning of your shift, make a safety inspection of all tanks, lines and
equipment in the leach area.
o Inspect lines and tanks for leaks or seeps.
o Inspect safety showers and eyewash fountains.
o Report any damage or maintenance problem to your supervisor and/or
other appropriate departments.
• The leaching of the Calcine material will be conducted in either the
continuous or batchwise mode of operation.
• If your supervisor instructs you to operate the leach circuit in the continuous
mode, then add Calcine slurry from the pulp storage tank continuously to the
designated leach tank at a rate of 40 gallons per minute ( equivalent to about
55 tons per day) or as instructed by your supervisor. Add steam to the
designated leach tanks sufficient to maintain a temperature of 80°C or as
instructed by your supervisor. Add sulfuric acid to the designated leach tanks
sufficient to maintain a free acid concentration of 60 grams per liter or as
instructed by your supervisor. Continue to maintain agitation in the
(
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Calcine Acid Leach Node
2012
designated leach tanks and flow between leach tanks as instructed by your
supervisor. Transfer the leach discharge slurry to the Counter-Current
Decantation (CCD) circuit for the solid/liquid separation step of the
processing.
• If your supervisor instructs you to operate the leach circuit in the batchwise
mode, then add Calcine slurry from the pulp storage tank to the designated
leach tank at a rate as instructed by your supervisor up to a tank volume as
instructed by your supervisor. Tum on and continue agitation in the
designated leach tank as instructed by your supervisor. Add sulfuric acid to
the designated leach tank to bring the tank contents to a free acid
concentration of 60 grams per liter or as instructed by your supervisor. Add
steam to the designated leach tank sufficient to bring the contents to a
temperature of 80°C or as instructed by your supervisor. Continue to add
steam as needed to maintain the temperature as instructed by your supervisor.
Maintain leach conditions in the designated tank as instructed by your
supervisor until the leaching step of processing is completed. Then turn off
agitation and stop reagent and steam addition in preparation for solid/liquid
separation.
• Take samples from leach tanks according to normal operation of the leach
circuit adjusted for the designated leach tanks in use and as instructed by your
supervisor.
Always read and follow all instructions listed on the MSDS.
(
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2
Date: December 18,
2012
Equipment Component
Individual Equipment No.
Parameter per Tank
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C (F)
Pressure, psig
Health Rating
Health Hazard
STANDARD OPERA TING PROCEDURES
Title: Calcine Solid/Liquid Separation Node
Hazard Assessment Worksheet
Calcine Solid/Liquid Separation Node
Node3
Page 1 of 3
Process Material in Component
H2S04 U30s Flocculant
697,971 50,000 250
20 0.1
------
2.5 2.5 NL
NL NL NL
0
20 (70) 20 (70) 20 (70)
1-100 0-100 0-100
3 3 r
7 7 1
Assessment Description: Operators should protect themselves from possible splashing of the tank
contents, due to temperature, acidity, and radioactivity. Operators should also be cautious of any
splashed or spilled flocculant solution or dry flocculant because the surfaces upon which the
flocculant lands will become dangerously slippery. Any splashed or spilled flocculant should be
cleaned up promptly by flushing the surface with generous amounts of water until the slippery
conditions are gone, or as instructed by your supervisor. Whenever working in, around or on this
process circuit the operator must wear PPB, which may include Tyvex or Mill coveralls, rubber
boots or regular steel toed boots, protective gloves, and safety glasses. A face shield or a full face
respirator maybe be required as instructed by the RSO or your supervisor.
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Calcine Solid/Liquid Separation No.de
2012
No.: PBL-17 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Calcine Solid/Liquid Separation Node
2012
Operating Instructions
Once the Calcine material has been processed in the leach circuit the uranium has
mostly dissolved into the liquid part of the slurry. In order to purify and recover this
dissolved -µranium it is necessary to separate the remaining solids from the liquid as
the next processing step.
• At the beginning of your shift, make a safety inspection of all tanks, lines and
equipment.
o Inspect tanks and lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
o Report any damage or maintenance problem to your supervisor and/or
other appropriate departments.
• If the leach circuit is being operated in the continuous mode, then the
solid/liquid separation step is accomplished by normal operation of the
Counter-current Decantation (CCD) circuit. This separation step is begun by
flowing the leach circuit discharge through the existing pipe line into the CCD
circuit. The CCD circuit is then operated according to normal SOPs with the
possible exception that fewer CCD thickeners may be used than in normal
operation of the plant in the ore processing mode.
• If the leach circuit is being operated in the batchwise mode, then the
solid/liquid separation step is accomplished in the same tank in which the
leaching was performed, as follows.
o At the conclusion of leaching and before agitation is turned off, add
flocculant solution to the contents of the tank as instructed by your
supervisor and allow the agitation of the tank to continue for a brief
time as instructed by your supervisor. Then tum off agitation to the
tank and allow the contents of the tank to settle.
o As the tank contents sit without agitation, the flocculated solids will
settle to the bottom of the tank, leaving a layer of clear supernatant
liquid above the layer of settled solids. When the settling of solids is
completed, as determined by your supervisor, begin to decant, or
transfer, the clear supernatant liquid to another leach tank as instructed
by your supervisor, taking special care to not stir up the settled solids.
o Once the supernatant liquid has been transferred, as much as possible,
to another leach tank, add wash water to the settled solids in the
bottom of the leach tank to a volume level in the tank as instructed by
No.: PBL-17
Rev. No.: 2
Date: December 18,
2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 4 of 3
Title: Calcine Solid/Liquid Separation Node
your supervisor. Tum on agitation in the tank and mix the wash water
and solids thoroughly for a time as instructed by your supervisor.
o At the conclusion of mixing the wash water and solids and before
agitation is turned off, add flocculant solution once more to the
contents of the tank as instructed by your supervisor and allow the
agitation of the tank to continue for a brief time as instructed by your
supervisor. Then tum off agitation to the tank and allow the contents
of the tank to settle again.
o When the settling of solids is completed, as determined by your
supervisor, decant the clear supernatant liquid to another leach tank as
instructed by your supervisor, talcing special care again to not stir up
the settled solids.
o Once the supernatant liquid has been transferred, as much as possible,
to another leach tank, add water to the settled solids in the bottom of
the leach tank to a volume level in the tank as instructed by your
supervisor. Tum on agitation in the tank and mix the water and solids
thoroughly for a time as instructed by your supervisor. Then transfer
the contents of the tank to tailings disposal, discharging through the
valve at the bottom of the leach tank as instructed by your supervisor.
o Mix and dilute the combined decanted supernatant liquid to prepare it
for feeding to the Solvent Extraction (SX) circuit, as instructed by your
supervisor. Then transfer the solution to another tank for feeding to
the SX circuit, as instructed by your supervisor.
Calcine Block Flow
I D~~~~ng -1-. __ ._ Pulp
Stora e
YC
Precip. ..
Calcine material can vary in impurity concentrations. Basic Block Flow is above.
Because of impurity concnetrations it may be necessary to repeat some steps or
to change the order of the processing steps.
(
{
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of I
Date: December 18, Title: Re-Gen Overview
2012
Standard Operating Procedures for Re-Generation Uranium Extraction Process
The following standard operating procedures (SOP) for uranium extraction from Re-
Generation alternate feed material is attached. The chemical makeup and the uranium
precipitation circuits follow the conventional standard operating procedures already in
place at the White Mesa Mill. These operating procedures are summarized by nodes with
the hazards, PPE, cautionary statements and operating instructions for each node. A node
is a phase of recovery in the overall process and is indicated by graphic presentation of
the process flow. There are general considerations that are applicable to all process
nodes. They are:
• Lines and Pumps
All lines, pumps and valves must be used according to specific operating
instructions that will be issued as required during process evaluations and
recovery.
• Specific Operation Instructions
Specific operating instructions apply to each process node based upon the
metallurgical requirements necessary for recover of an on-specification
uranium product. These instructions will change periodically after operating
process and parameters have been determined.
• Ventilation
It is necessary in any place of the processing that the ventilation system is
checked and is running. This is extremely necessary for all personnel to
recognize this because there is a potential for toxic gas and vapors to be
generated.
• Hazard Assessment Worksheet
Each hazard assessment work sheet identifies hazardous parameters for each
node such as operating temperature, pressure and radioactive content of each
stream. The overall hazard rating is based on quantity of chemical, phase of
the chemical (gas, solid, liquid) and the MSDS health rating for each
chemical. The overall hazard rating is the sum of the three ratings.
• Personnel Protective Equipment (PPE)
PPE is identified on each node and are accompanied by cautionary statements
of each important hazardous chemical.
This information will be presented to all operations personnel and any questions
regarding this information will be answered.
This SOP may be modified as necessary by a radiation work permit (RWP) which will
establish new procedures and requirements during the processing of the Re-Generation
material.
(
Processing of Re-Gen Material
PFD for SOP Nodes
Drums of
Re-Gen
Drum Dumping In
Modified
Extractor
Acidification
Tank
Mixer/Setller for Separation
of Phases
Waste
Aqueous Re-
Handling Tank
Organic
Na2COa
Solution Make-
Up
Steam
Re-Gen
Digestion/
Precipitation Tank
Surge Tank
for Waste
Organic
Packaging of
Waste Organic in
Drums with
Absorbent
Send Solution of
Uranium Dissolved in
Acid to Normal
Yellowcake
Precipitation
Decant to
Tailings
Send Solution of
Uranium Dissolved in
Acid to Normal
Yellowcake
Precipitation
Transporting of Drums
of Waste Organic to
Tailings Pond &
Placement
"Dirty" Filter
Press
Re-Pulp
Tank
Cake Washing
Thickener
Filter Aid
Addition
Tank
Used FIiter
Aid To
Tailings
5/9/2007
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node #1
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/m3
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Re-Gen Drum Dwnping Node
Process Material in Component
Di-Butyl Uranium Sodium Butyric
Phosphate Carbonate Acid
3600 500 2750 2800
20-70 5-30 12 20-50
315 ----162
1 ------
2 ------
--NA ----
Amb Amb Amb Amb
---·-----
2 2 2 2
1 3 2 1
Nitric
Acid
360
35
--
2
4
--
Amb
--
2
3
Assessment Description: The Re-Gen material is mostly organic and can give off vapors
with a sickening odor before it is mixed with sodium carbonate solution. Also, any
aqueous phase present in any of the Re-Gen drums will contain strong concentrations of
nitric acid. The liquid in the vessel below, into which the drums are being dumped, is
strongly basic. Any splashing or contact with the skin should be avoided. These
materials can cause skin and eye burns. The Re-Gen material is also radioactive and
you must follow established health physics controls. If any Re-Gen gets on you,
wash it off with copious amounts of soap and water.
Drums
ofRe-
r.~n
Drum
Dumping in
Modified
F.xtrnr.tnr
Na2COi
Solution
Make-Up
Tank
Na2COi
Digestion
Tank
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
The Re-Gen drums must be kept sealed or covered as much as possible until all process
components are ready for dumping the drums into the vessel of sodium carbonate
solution.
• Make sure you are familiar with the MSDS for the Re-Gen material.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Add to the empty vessel about 2500 gallons of sodium carbonate solution. The
concentration of sodium carbonate will be at least 12% and may be higher
according to instructions from your supervisor.
• Set the valves for recirculation of vessel contents and tum on the pump to start
recirculation.
• Raise a pallet of Re.:Gen drums to the working platform.
• Carefully loosen the lids of the drums on the pallet.
• Place the drums one at a time in the drum dumping station and remove the lid just
before dumping.
• Dump each drum into the vessel using the dumping station according to
instructions from your supervisor and clean out any material that does not easily
pour from each drum into the vessel using the pressure washer
• Repeat the process with additional pallets until the 20 drums for the batch have
been dumped into the vesseL
• Wash down the dumping station area and make sure all Re-Gen material from the
20 drums has been flushed into the vessel.
• Tum off the pump and re-set the valves to transfer contents of the vessel to the
carbonate digestion tank. Tum on the pump and transfer contents of the vessel.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Re-Gen Processing
2012
• Safely dispose of the damaged empty drums and move the empty drums in good
condition to the area from which they can be re-used according to instructions
from your supervisor.
• Prepare the vessel, pump, valves, and dumping station for the next batch.
• Always keep your area clean and ensure your work area is free of hazardous
obstructions.
NOTE: Whenever working in, around or on this process circuit YOU MUST
wear PPE which includes at minimum hard hat, rubber wet suit, rubber boots
and gloves, safety glasses, face shield and whatever level of respiratory
protection is deemed appropriate by the Radiation Safety Officer.
MOBILE EQUIPMENT
The forklift handling the pallets of drums of Re-Gen material will be operated according
to normal operating procedures, taking special precautions to avoid spilling or rupturing
any of the drums of the Re-Gen material.
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 2
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node #2
Equipment Component Re-Gen Carbonate Digestion Node
Individual Equipment No.
Parameter Process Material in Component
PFD Di-Butyl Uranium Sodium Butyric Acid
Phosphate Carbonate
Quantity in Equipment (lb) 3600 500 2750 2800
Concentration (%) 5-20 1-8 12 4-12
Flashpoint, °F 315 ----162
TLV-TWA mg/m3 1 ------
STEL mg/m3 2 ------
Radioactivity, pCi/g --NA ----
Temperature, °C 40 40 40 40
Pressure, psig --------
Health Rating 2 2 2 2
Hazard Rating 1 3 2 1
Assessment Description: The Re-Gen material is entirely dissolved in the heated sodium
carbonate solution in this processing step. The liquid in the digestion vessel is strongly
basic. Any splashing or contact with the skin should be avoided. These materials can
cause skin and eye burns. The dissolved Re-Gen material is also radioactive and you
must follow established health physics controls. If any carbonate digestion solution
gets on you, wash it off with copious amounts of soap and water.
Steam
Na2C03
Digestion
Tank
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with digesting the Re-Gen material in sodium carbonate
solution at 40°C for about 4 hours.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
precautions listed on the MSDS. 1
• Make sure the level of materials in the digestion tank is appropriate for
the starting agitation without causing spillage -then start agitation.
• After the batch has been moved to the digestion tank and agitated, a
sample will be taken as per the Supervisor instructions. Make sure
that you note the volume of the tank at the time of sampling.
• Adc,l steam to the contents of the tank until the contents reach 40°C.
• Continue agitation of the tank contents at 40°C for 4 hours.
• At the end of the digestion time, measure the volume of final digestion
solution in the tank and contact the lab to have a sample of the tank
contents analyzed for uranium concentration.
• "Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node#3
Equipment Component NaOH Preci:gitation Node
Individual Equipment No.
Parameter per Tank Process Material in Component
PFD Di-Butyl Uranium NaOH Diatomaceous
Phosphate Earth Filter
Aid
Quantity in Equipment (lb) 3600 500 400 1800
Concentration (%) 5-20 1-8 50 100
Flashpoint, °F 315 ------
TLV-TWA mg/mj 1 ----3
STEL mg/mj 2 ------
Radioactivity, pCi/g --NA ----
Temperature, °C 70 70 Amb Amb
Pressure, psig --------
Health Rating 2 2 2 4
Health Hazard 1 3 2 0
Assessment Description: A uranium-rich precipitate is formed by NaOH addition to the solution
from the carbonate digestion of the Re-Gen material in this processing step. The liquid in the tank is
strongly basic. Any splashing or contact with the skin should be avoided. These materials can
cause skin and eye burns. The solution and the precipitate that is formed are also radioactive
and you must follow established health physics controls. If any of the solution or precipitate
gets on you, wash it off with copious amounts of soap and water. The filter aid material is dusty
in the dry condition and you must avoid breathing the dust.
Re-Gen
Digestion/
Precipitation
Tank
50%
NaOH
~nlntlnn
Filter Aid
Addition
Tank
Operating Instructions
This node deals with formation of a uranium-rich precipitate by addition of NaOH to the
final solution from the carbonate digestion of the Re-Gen material.
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Re-Gen Processing
2012
• This NaOH precipitation will be done in the same tank in which the carbonate
digestion was performed.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all applicable instructions
listed on the MSDS.
• Continue agitation of the final solution from carbonate digestion of the Re-Gen
material. Add steam until the contents of the Re-Gen digestion/precipitation tank
reach about 50°C and continue adding steam as needed to maintain this
temperature.
• Open or close the necessary valves and tum on the necessary pumps to circulate
the solution from the Re-Gen digestion/precipitation tank through the filter aid
addition tank and back to the Re-Gen digestion/precipitation tank. Mix into the
circulating solution the amount and type of filter aid as instructed by your
supervisor. Make sure you are wearing the appropriate respirator as determined
by the Radiation Safety Officer whenever handling or working in the vicinity of
filter aid in its dry condition.
• When all filter aid has been added, tum off any pumps and close the valve to shut
off flow from the Re-Gen digestion/precipitation tank to the filter aid addition
tank. Complete transfer of all solution and filter aid from the filter aid addition
tank to the Re-Gen digestion/precipitation tank, using a small volume of water as
necessary to rinse out the tank. Then tum off the pump and close the valves to the
Re-Gen digestion/precipitation tank from the filter aid addition tank.
• To the agitated contents of the Re-Gen digestion/precipitation tank slowly add the
volume of 50% NaOH solution as instructed by your supervisor. Continue
agitation of the tank for 30 minutes after the NaOH addition is completed.
• Measure the pH of the Re-Gen digestion/precipitation tank contents with pH
paper obtained from the lab. Do not measure the pH using an ordinary pH meter
and probe -these will not give correct pH readings in this solution. Slowly add
small volumes of the 50% NaOH solution to the tank until the pH reaches 13.
Continue agitation of the Re-Gen digestion/precipitation tank for another 2 hours
to complete the precipitation reaction.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Re-Gen Processing
2012
• Whenever working in, around or on this process you must avoid splashing and
any contact with the skin and YOU MUST wear PPE which includes at a
minimum, hard hat, coveralls, rubber boots and gloves, safety glasses with side
shields, and whatever level of respiratory protection is deemed appropriate by the
Radiation Safety Officer, and may include a face shield or safety goggles.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 4
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node#4
Equipment Component
Individual Equipment No.
Parameter per Tank
NaOH Precipitate Filtration Node
Process Material in Component
PFD Di-Butyl Uranium Diatomaceous Butyric Acid
Phosphate Earth Filter
Aid
Quantity in Equipment (lb) 3600 500 1000
Concentration (%) 5-20 1-8 100
Flashpoint, °F 315 ----
TLV-TWA mg/mj 1 --3
STEL mg/mj 2 ----
Radioactivity, pCi/g --NA --
Temperature, °C (F) 70 70 Amb
Pressure, psig ------
Health Rating 2 2 4
Health Hazard 1 3 0
Assessment Description: The uranium-rich precipitate formed by NaOH addition to the
solution from the carbonate digestion of the Re-Gen material is separated from the
solution by pressure filtration. Make sure all pressurized lines, connections and fittings
are in good condition and not leaking. The liquid in the tank is strongly basic. Any
splashing or contact with the skin should be avoided. The chemicals in the liquid can
cause skin and eye burns. The solution and the precipitate are also radioactive and
you must follow established health physics controls. If any of the solution or
precipitate gets on you, wash it off with copious amounts of soap and water. The
filter aid material is dusty in the dry condition and you must avoid breathing the dust.
2800
4-12
162
--
--
--
70
--
2
1
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 4
Date: December 18, Title: Re-Gen Processing
2012
Re-Gen
Digestion/
Precipitation
Tank
Como. Air
H,O
Acidification
Tank
Filter
CakeRe-
Pnln T~nk
"Dirty"
Filter H,O
Two Acid Digestion/Ammonia
Precipitation Tanks
Operating Instructions
Filter Aid
Addition
Tank
This node deals with the pressure filtration to recover the uranium-rich
precipitate formed by NaOH addition to the solution from the carbonate
digestion of the Re-Gen material.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Add water to the filter aid addition tank for the pressure filter
according to instructions from your supervisor. Start agitation of the
tank and then add filter aid material to the tank according to
instructions from your supervisor. Mix the contents of the tank
thoroughly. Make sure you are wearing the appropriate respirator as
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERA TING PROCEDURES Page 3 of 4
Date: December 18, Title: Re-Gen Processing
2012
•
•
determined by the Radiation Safety Officer whenever handling or
working in the vicinity of filter aid in its dry condition.
Open or close all necessary valves and tum on the pump from the filter
aid addition tank to the filter press. Pump the entire contents of the
filter aid addition tank through the filter press. Then tum off the pump
and open or close all necessary valves to leave the pre-coated filter
press filled with water under some pressure.
Open or close all necessary valves and tum on the pump from the Re-
Gen digestion/precipitation tank to the filter press. Recycle filtrate
until the solution clears and then change the appropriate valves to send
all barren filtrate to the acidification tank. Pump the contents of the
Re-Gen digestion/precipitation tank through the filter press until the
pressure indicates the filter press chambers are full of filter cake.
• Tum off the pump from the Re-Gen digestion/precipitation tank, open
or close the necessary valves, and run wash water through the filter
press according to instructions from your supervisor.
• Shut off the wash water, open or close appropriate valves, and run
compressed air through the filter press according to instructions from
your supervisor.
• When the filter cake has been adequately dried by the compressed air,
shut off the air flow and depressurize the filter press.
• Turn on the conveyor system under the filter press, open the filter, and
dump and transfer all filter cake to the filter cake re-pulp tank.
• Add water to the filter cake re-pulp tank and agitate contents of the
tank until the filter cake is fully re-pulped. Transfer the re-pulped
filter cak~ slurry to one of the two acid digestion/ammonia
precipitation tanks according to instructions from your supervisor.
• Clean the filter press, close it up, and prepare it for its next fi1'tration
cycle.
• Repeat pre-coating the filter, filtering the contents of the Re-Gen
digestion/precipitation tank, and dumping and re-pulping the filter
cake until the Re-Gen digestion/precipitation tank is empty.
• When all barren filtrate from a processing batch has been sent to the
acidification tank, make sure the volume of solution in the tank is
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 4 of 4
Date: December 18, Title: Re-Gen Processing
2012
measured and recorded and make sure a sample of the contents of the
acidification tank is taken and analyzed by the lab for uranium.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
• Always keep your work area clean and ensure your work area is free
of obstructions.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 2
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node #5
Equipment Component
Individual Equipment No.
Parameter per Taruc
Re-Pulped Filter Cake Acid Digestion Node
Process Material in Component
PFD Uranium Sulfuric Acid Di-Butyl Butyric Acid
Phosphate
Quantity in Equipment (lb) 500 670 9 7
Concentration (%) 1-8 93 0.1 0.1
Flashpoint, °F ----315 162
TLV-TWA ppm ----1 --
STEL ppm ----2 --
Radioactivity, pCi/g NA 0 ----
Temperature, °C (F) Amb. Amb. Amb. Amb.
Pressure, psig --0-100 --
Health Rating 2 3 2
Health Hazard 3 2 1
Assessment Descnption: The re-pulped filter cake of basic uramum-nch precipitate and
the acidic solution in which it will be digested should be handled with caution. The small
quantity of organic phase that will be formed from the entrained barren filtrate in the
filter cake should also be handled with caution. Any splashing or contact with the skin
should be avoided. The acidic chemicals in the liquid can cause skin and eye burns.
The solution and the filter cake are also radioactive and you must follow established
health physics controls. If any of the solution or filter cake gets on you, wash it off
with copious amounts of soap and water.
H,so.
H,O
Either of Two Acid Digestion/
Ammonia Precipitation Tanks
H,SO,
H20
--
2
1
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with the acid digestion of re-pulped uranium-rich filter cake.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
applicable instructions listed on the MSDS.
• Agitate the slurry of re-pulped filter cake in the acid
digestion/ammonia precipitation tank. Add water according to
instructions from your supervisor and add sulfuric acid to bring the pH
of the slurry to 1. 0. Add steam to bring the contents of the tank to
40°C. Agitate the slurry in the tank at 40°C and pH 1.0 for one hour,
adding steam and sulfuric acid as needed to maintain these conditions.
• Tum off agitation of the contents of the acid digestion/ammonia
precipitation tank. Allow any organic phase in the tank to collect at
the top of the tank. Skim off the organic phase collected at the top of
the tank into a suitable vessel as instructed by your supervisor.
• Using the vessel, recover any aqueous phase that was removed from
the acid digestion/ammonia precipitation tank when the organic phase
was skimmed off. Return the recovered aqueous phase to the acid
digestion/ammonia precipitation tank.
• Transfer the skimmed-off organic phase to the surge tank for waste
organic.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node#6
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLVmg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Filtration After Acid Digestion of Filter Cake Node
Process Material in Component
Uranium Dilute H2S04 Diatomaceous
Earth Filter
Aid
1500 500 5000
2-6 1-2 50
------
----3
------
NA 0 --
40 40 40
--70 --
2 3 4
3 2 0
Assessment Description: This processing step involves pressure filtration of a mildly
acidic slurry. Any splashing or contact with the skin should be avoided. The acidic
chemicals in the liquid can cause skin and eye burns. The solution and the fllter
cake are also radioactive and you must follow established health physics controls. If
any of the solution or mter cake gets on you, wash it off with copious amounts of
soap and water. If any of the filter cake becomes dry, respiration of the dust must be
avoided. The filter press and piping leading to it will be under pressure and should be
handled carefully.
Acid Digestion /
Ammonia
Precioitation Tank
Filter
Cake Re-
Pulo Tank
"Clean"
Filter
Cake Washing
Thickener
Used FIiter
Aid to
Tailings
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
In this processing step the used filter aid is separated from the dissolved
uranium by pressure filtration.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect the filter feed pump and the filter press for leaks and
proper assembly.
o Inspect safety showers and eyewash fountains.
o Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
applicable instructions listed on the MSDS.
• Open or close all necessary valves and tum on the pump from the acid
digestion/ammonia precipitation tank to the filter press. Recycle all
filtrate to the acid digestion/ammonia precipitation tank. Pump the
contents of the acid digestion/ammonia precipitation tank through the
filter press until the pressure indicates the filter press chambers ate full
of filter cake.
• When the pressure indicates the filter press chambers are full of filter
cake, tum off the pump from the acid digestion/ammonia precipitation
tank, open or close the necessary valves, and run wash water through
the filter press according to instructions from your supervisor. Return
the filtrate from washing to the acid digestion/ammonia precipitation
tank.
• When the water wash is completed, shut off the wash water, open or
close appropriate valves, and run compressed air through the filter
press according to instructions from your supervisor. Return any
liquid discharged from the filter press to the acid digestion/ammonia
precipitation tank.
• When the filter cake has been adequately dried by the compressed air,
shut off the air flow and depressurize the filter press.
• Tum on the conveyor system under the filter press, open the filter, and
dump and transfer all filter cake to the filter cake re-pulp tank.
(
l
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Re-Gen Processing
2012
• Add water to the filter cake re-pulp tank according to instructions from
your supervisor and agitate contents of the tank until the filter cake is
fully re-pulped. Transfer the re-pulped filter cake slurry to the cake
washing thickener according to instructions from your supervisor.
• Clean the filter press, close it up, and prepare it for its next filtration
cycle.
• Repeat filtering the contents of the acid digestion/ammonia
precipitation tank and dumping and re-pulping the filter cake until the
acid digestion/ammonia precipitation tank contents are free of
suspended solids.
• Transfer the clear overflow from the cake washing thickener back into
the process to recover the contained uranium according to instructions
from your supervisor. Transfer the underflow from the cake washing
thickener to tailings according to instructions from your supervisor.
• Make sure samples are taken of the overflow and underflow
transferred from the cake washing thickener.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
• Always keep your work area clean and ensure your work area is free
of obstructions.
(
No.: PBL-18
Rev. No.: R-1
Date: December 18,
2012
Equipment Component
Individual Equipment No.
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 1 of 2
Title: Re-Gen Processing
Hazard Assessment Worksheet
Node#7
Ammonia Precipitation Node
Parameter Process Material in Component
PFD Uranium Dilute H2S04 Ammonia
Quantity in Equipment (lb) 1500 500 620
Concentration (%) 2-6 1-2 100
Flashpoint, °F ------
TLV-TWA mg/mj ----25
STEL mg/mj ----35
Radioactivity, pCi/g NA 0 0
Temperature, °C 40 40 20
Pressure, psig --70 0-100
Health Rating 2 3 3
Hazard Rating 3 2 1
Assessment Description: The beginning solution contains dilute sulfuric acid and the
ending solution contains dissolved ammonia and emits ammonia vapors. The solution
should be handled with caution at all times. REMEMBER Ammonia vapor, fumes and
mists are Toxic Atmospheres and cannot be detected by smell above approximately
100 ppm. IF you smell strong ammonia fumes you must wear a full face respirator
with universal cartridges and ventilate the area. At high concentrations your skin
and eyes can be burned. The beginning solution and the precipitate are also
radioactive and you must follow established health physics controls. If any of the
solution or precipitate gets on you, wash it off with copious amounts of soap and
water.
NHa
Either of Two Acid Digestion/ Ammonia
Precipitation Tanks
NHa
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with the ammonia precipitation of uranium from the acid
digestion liquor that has been clarified by filtration in the filter press.
• Make a safety inspection of all lines and equipment.
• Inspect lines for leaks or seeps.
• Inspect safety showers and eyewash fountains
• Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and.follow all
applicable instructions listed on the MSDS.
• Tum on the agitator in the acid digestion/ammonia precipitation tank
containing the acid digestion liquor that has been clarified by filtration
in the filter press.
• Add ammonia to the contents of the acid digestion/ammonia
precipitation tank according to instructions from your supervisor.
Continue adding ammonia until the contents of the tank reach and
remain at pH 7.5 or a different pH target according to instructions
from your supervisor, and then continue agitation for an additional 30
minutes.
• Tum off the agitator in the acid digestion/ammonia precipitation tank
and allow the precipitate to settle according to instructions from your
supervisor.
• Make certain a sample is taken of the clear supernatant liquid above
the settled solids. Once your supervisor has determined that the
precipitate in the acid digestion/ammonia precipitation tank has settled
sufficiently, decant the clear supernatant liquid from the tank and
transfer the decanted liquid to tailings according to instructions from
your supervisor. Make sure the volume of decanted liquid is recorded
and reported.
• Whenever working in, around or on this process circuit YOU MUST
wear PPE which includes at minimum Tyvex or Mill coveralls, rubber
boots or regular steel toed boots and gloves, safety eye glasses, a face
shield and may include full face respirators.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 2
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node#8
Equipment Component
Individual Equipment No.
Ammonia Precipitate Acid Re-Dissolution Node
Parameter per Tank Process Material in Component
PFD Uranium Sulfuric Acid Ammonia
Quantity in Equipment (lb) 500 670 150
Concentration (%) 1-8 93 100
Flashpoint, °F ------
TLV-TWA ppm ----25
STEL ppm ----35
Radioactivity, pCi/g NA 0 0
Temperature, °C (F) 40 Amb. Amb.
Pressure, psig --0-100 0-100
Health Rating 2 3 3
Health Hazard 3 2 1
Assessment Description: The settled basic uranium-rich ammonia precipitate and the
acidic solution in which it will be re-dissolved should be handled with caution. Any
splashing or contact with the skin should be avoided. The acidic chemicals in the liquid
can cause skin and eye burns. The solution and the precipitate are also radioactive
and you must follow established health physics controls. If any of the solution or
precipitate gets on you, wash it off with copious amounts of soap and water.
Steam
Either of Two Acid Digestion I
Ammonia Precipitation Tanks
Send Solu lion of
Uranium
Dissolved in
Acid to Normal
Yellowcake
Precipitation
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with the acid re-dissolution of uranium-rich ammonia
precipitate.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
applicable instructions listed on the MSDS.
• Add water to the settled ammonia precipitate in the acid
digestion/ammonia precipitation tank according to instructions from
your supervisor.
• Agitate the slw ry of an-imonJ_a precipitate in the acid
digestion/ammonia precipitatm~ank. Add sulfuric acid to bring the
pH of the slurry to 1.0. Add st to bring the contents of the tank to
40°C. Agitate the slurry in the t at 40°C and pH 1.0 for one hour,
adding steam and sµlfuric acid as needed to maintain these conditions.
• Turn off agitation and make sure a sample is taken and volume is
measured and recorded of the contents of the acid digestion/ammonia
precipitation tank.
• Open or close appropriate valves and turn the pump to transfer the
contents of the acid digestion/ammonia precipitation tank to normal
yellowcake precipitation area of the plant according to instructions
from your supervisor.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 2
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet Node#9
Equipment Component
Individual Equipment No.
Parameter per Tank
Barren Digestion Filtrate Acidification Node
Process Material in Component
PFD Di-Butyl Butyric Acid Sulfuric Acid Sodium
Phosphate Carbonate
Quantity in Equipment (lb) 3600 2800 2600 2750
Concentration (%) 0.1 0.1 93 12
Flashpoint, °F 315 162 ----
TLV-TWA nom 1 ------
STEL ppm 2 ------
Radioactivity, pCi/g ----0 --
Temperature, °C (F) Amb. Amb. Amb. Amb.
Pressure, psig ----0-100 --
Health Rating 2 2 3
Health Hazard 1 1 2
Assessment Description: The beginning basic solution of barren Re-Gen digestion filtrate
and the ending acidic solution and the organic phase separated from it should all be
handled with caution. Any splashing or contact with the skin should be avoided. The
basic or acidic chemicals in the liquids can cause skin and eye burns. If any of the
aqueous phase or organic phase gets on you, wash it off with copious amounts of
soap and water.
Acidification
Tank
Mixer/Settler for
Separation of Phases
Aqueous
Organic
Surge Tank
for Waste
Organic
Awaiting
Drumming
2
2
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with the acidification of barren Re-Gen digestion filtrate.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
applicable instructions listed on the MSDS.
• Agitate the barren Re-Gen digestion filtrate in the acidification tank.
Add water to the contents of the tank according to instructions from
your supervisor. Gradually add sulfuric acid to bring the pH of the
solution to 3.0. The acid addition will cause CO2 bubbles in the
solution, which will create a foam layer. Do not allow the foam layer
to overflow the tank. Interrupt acid addition as necessary to allow the
foam layer to diminish. After reaching pH 3.0, agitate the contents of
the tank at pH 3.0 for one hour, adding sulfuric acid as needed to
maintain this pH.
• Tum off agitation of the contents of the acidification tank. Open or
close the appropriate valves and tum on the pump to transfer the
contents of the tank to the mixer/settler for separation of phases
according to instructions from your supervisor.
• Open or close the appropriate valves and tum on the pump to transfer
the aqueous phase from the mixer/settler for separation of phases to
tailings according to instructions from your supervisor. Make sure a
sample of this aqueous phase is taken and analyzed for uranium.
• Open or close the appropriate valves and tum on the pump to transfer
the organic phase from the mixer/settler for separation of phases to the
surge tank for waste organic according to instructions from your
supervisor. Make sure a sample of this organic phase is taken and
analyzed for uranium.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: Re-Gen Processing
2012
Hazard Assessment Worksheet
Equipment Component
Individual Equipment No.
Waste Organic Disposal Node
Node #10
Parameter per Tank Process Material in Component
PFD Di-Butyl Other Diatomaceous
Phosphate Organic Earth
Absorbent
Quantity in Equipment (lb) 3600 3400 7600
Concentration (%) 60 40 100
Flashpoint, °F 315 NA --
TLVmg/mj 1 --3
STEL ppm 2 ----
Radioactivity, pCi/g ------
Temperature, °C (F) Amb. Amb. Amb
Pressure, psig ------
Health Rating 2 3 4
Health Hazard 1 3 0
Assessment Description: The waste organic phase contains a variety of organic
compounds and should all be handled with caution. Any splashing or contact with the
skin should be avoided. If any of the aqueous phase or organic phase gets on you,
wash it off with copious amounts of soap and water. The absorbent material is dusty
in the dry condition and you must avoid breathing the dust.
Surge Tank
for Waste
Organic
Absorbent
Packaging of
Waste Organic
In Drums with
Absorbent
Transporting of
Drums of Waste
Organic to
Tailings Pond &
Placement
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with the disposal of waste organic sealed in drums with
absorbent material.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
applicable instructions listed on the MSDS.
• Inspect the next drum to be used for any cracks, leaks or flaws and
discard the drum if any cracks, leaks or flaws are found. Once a good
drum is identified, place it under the waste organic discharge pipe.
• Pour absorbent into the drum to form a layer 3-6 inches deep in the
bottom of the drum.
• Open the waste organic discharge valve and put about 12 inches of
waste organic into the drum. Then close the valve and pour absorbent
into the waste organic in the drum sufficient to absorb all visible
organic and leave about a 1 inch layer of absorbent on top that is not
wetted with organic. Allow at least 5 minutes for the absorbent to
soak up the waste organic.
• Continue to make alternating additions of waste organic and absorbent
to the drum until the drum is full with about a 1 inch layer of absorbent
on top that is not wetted with organic.
• During the loading of the first lot of waste organic drums, after the
drums have been filled, let the drums settle to verify all of the liquid
has been absorbed. After the first lot, this verification process should
continue on a random bases.
• Seal the lid tightly on the filled drum and carefully move the sealed
filled drum into position for transporting to the tailings area.
• Repeat the process until a sufficient number of drums have been filled
according to instructions from your supervisor.
• If any waste organic is spilled, pour absorbent on the spilled waste
organic until all the organic is absorbed. Then scoop up the organic-
wetted absorbent into the next drum to be filled.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Re-Gen Processing
2012
• When a sufficient number of drums have been filled and sealed,
carefully transport the drums to the tailings area and place the drums
carefully in the trench prepared in the tailings area to receive the
drums according to instructions from your supervisor.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and whatever level of
respiratory protection is deemed appropriate by the Radiation Safety
Officer, and may include a face shield or safety goggles.
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1
Date: December 18,
2012
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
STANDARD OPERATING PROCEDURES Page 1 of 3
Title: Re-Gen Processing
Hazard Assessment Worksheet
Node #11
Spent Aqueous Re-Handling Node
Process Material in Component
Uranium Ammonia Sulfuric Acid
200 90 100
0.6 100 93
------
--25
--35
0 0
Amb. 20 Amb.
--0-100 0-100
2 3 3
3 1 2
Assessment Description: The beginning solution contains uranium and dilute sulfuric
acid. First the uranium is precipitated with ammonia and, after settling, the spent
aqueous is decanted and sent to tailings. Once sufficient precipitate is collected, then the
precipitate is re-dissolved with sulfuric acid. Each of the solutions should be handled
with caution at all times. IF you smell strong ammonia fumes you must wear a full
face respirator with universal cartridges and ventilate the area. At high
concentrations of ammonia your skin aild eyes can be burned. Also, the sulfuric
acid used to re-dissolve the precipitate can cause skin and eye burns. The beginning
and ending solutions and the precipitate are also radioactive and you must follow
established health physics controls. If any of the solutions or precipitate gets on
you, wash it off with generous amounts of water and with sufficient soap as needed.
Mixer/Settler for
Separation of Phases
To
Tailings
Spent
Aqueous
Re-
Handling
Tank
Decant
to
Tailings
Send Solution
of Uranium
Dissolved in
Acid to Normal
Yellowcake
Precipitation
No.: PBL-18 E~RGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: Re-Gen Processing
2012
Operating Instructions
This node deals with the recovery of uranium from the spent aqueous by
ammonia precipitation, settling, decanting, and acid re-dissolution. This will
only be performed on an as-needed basis. When the content of uranium in the
spent aqueous is sufficiently low, this processing step will be omitted and the
spent aqueous will be sent directly from the mixer/settler for separation of
phases to tailings.
• Make a safety inspection of all lines and equipment.
• Inspect lines for leaks or seeps.
• Inspect safety showers and eyewash fountains
• Always keep your work area clean and ensure your area is free
of hazardous obstructions. Always read and follow all
applicable instructions listed on the MSDS.
• Confirm with your supervisor that the uranium content of the spent
aqueous in the mixer/settler for separation of phases is high enough to
be processed in the spent aqueous re-handling tank.
• Open or close all necessary valves and turn on the pump to transfer the
spent aqueous to the spent aqueous re-handling tank. Transfer the
volume of spent aqueous to the spent aqueous re-handling tank as
instructed by your supervisor.
• Add ammonia to the contents of the spent aqueous re-handling tank
according to the same procedure described in Node #7 as modified by
instructions from your supervisor.
• Tum off the agitator in the spent aqueous re-handling tank and allow
the precipitate to settle according to the same procedure described in
Node #7 as modified by instructions from your supervisor.
• Make certain a sample is taken of the clear supernatant liquid above
the settled solids. Once your supervisor has determined that the
precipitate in the spent aqueous re-handling tank has settled
sufficiently, decant the clear supernatant liquid from the tank and
transfer the decanted liquid to tailings according to instructions from
(
No.: PBL-18 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: Re-Gen Processing
2012
•
•
•
•
•
your supervisor. Make sure the volume of decanted liquid is recorded
and reported.
If your supervisor instructs you that the amount of ammonia
precipitate in the spent aqueous re-handling tank is sufficient to
perform the acid re-dissolution, then proceed with the other processing
steps written below. Otherwise, keep the tank and settled precipitate
until the next batch of spent aqueous is treated.
When your supervisor instructs you to perform the acid re-dissolution
on the contents of the spent aqueous re-handling tank, add water to the
settled ammonia precipitate in the spent aqueous re-handling tank
according to instructions from your supervisor.
Agitate the slurry of ammonia precipitate in the spent aqueous re-
handling tank. Add sulfuric acid to re-dissolve the precipitate
according to the same procedure described in Node #8 as modified by
instructions from your supervisor.
Tum off agitation and make sure a sample is taken and volume is
measured and recorded of the contents of the spent aqueous re-
handling tank.
Open or close appropriate valves and tum on the pump to transfer the
contents of the spent aqueous re-handling-tank to normal yellowcake
precipitation area of the plant according to instructions from your
supervisor.
• Whenever working in, around or on this process circuit YOU MUST
wear PPE which includes at minimum Tyvex or Mill coveralls, rubber
boots or regular steel toed boots and gloves, safety eye glasses, a face
shield and may include full face respirators.
No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 3 ST AND ARD OPERATING PROCEDURES Page 1 of 3
Date: February 10, Title: Containerized Alternate Feedstock Material Storage
2017 Procedure
1.0 Purpose
The purpose of this procedure is to assure that storage of feedstock material is conducted in a
manner so as to preclude the release of Mill feed material to the environment.
2.0 Scope
Feed materials delivered to the White Mesa Mill must be stored in a manner, which precludes the
release of the materials to the environment. In the case of bulk materials, such as unrefined
natural ores and alternate feeds delivered in inter-modal containers, these materials are offloaded
from the truck or shipping container directly onto the approved ore pad where migration of
material is precluded by the pad's design and operating procedures (i.e. low permeability pad
material, dust control procedures and limited stockpile height). However, certain feeds are
received in drums or other containers, which serve to effectively contain the material during
storage, and, as such, are amenable for storage either on the ore pad or at locations other than the
ore pad. It is the intent of this procedure to describe the environmental safety precautions
utilized for contained feed storage.
3.0 Procedure
3 .1 Feed Mate1ial Inspections
3.2
All feed materials received at the White Mesa Mill are inspected upon arrival,
prior to entering the Restricted Area, to determine that the containers and/or
conveyances are not leaking and to assure container integrity prior to placing the
material into storage. Each container and/or conveyance will be observed on all
sides for damage or leakage of contents. If any container and/or conveyance has
signs of leakage, the inspector must notify the RSO immediately. The RSO will
make the determination through visual observation and radiological assessment if
a leak has occurred. If a leak has occurred, the RSO will make the proper
notifications to Corporate Management and regulatory agencies. All containers
exhibiting signs of leakage will be re-packed or placed in over-pack containers
prior to placing the materials into storage. Dented drums are acceptable if the
dent is not located near a seam or when the dent is not accompanied by a damage
crease on the drum surface. Drums damaged by dents near the seam, crease
damaged drums or containers that have been otherwise compromised during
shipment are re-packed or placed in over-pack containers prior to storage.
Containers, which are not damaged at the time of receipt, are transferred directly
for placement at the storage location.
Storage Locations
3.2.1 Defined Feedstock Storage
Feedstock materials stored at the defined storage location indicated on the
map attached hereto as Attachment A) the "Defined Feedstock Area" can
No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 3 STANDARD OPERATING PROCEDURES Page2 of 3
Date: February 10, Title: Containerized Alternate Feedstock Material Storage
2017 Procedure
be stored in containers or in bulk form and are subject to the routine
inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT) Monitoring Plan in
Section 3.3 of the Mill's Environmental Protection Manual.
3.2.2 Storage of Contained Feeds in Location Other Than the Defined Feedstock
Area
a) Over-pack Containers
Materials received or transferred into over-pack containers can be stored at
locations other than the Defined Feedstock Area absent a hardened ground surface
or containment berms due to the fact that the over-pack container provides a ,
secondary containment for the packaged material. Over-pack materials are
subject to the routine inspections described by the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT) Monitoring
Plan at Section 3.3.
b) Hardened Surface Storage Locations
Contained feed materials, including materials in containers which have not been
provided with over-pack protection, can be stored at locations other than the
Defined Feedstock Area when a hardened ground surface storage location is used
and has been provided with containment berms. These materials are subject to the
routine inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT) Monitoring Plan at Section
3.3.
c) Sjngle Lined Containers Stored Outside the Defined Feedstock Area
Where Hardened Surfaces and Containment Berms Are Not Utilized
Contained feeds can also be stored in locations, other than the Defined Feedstock
Area, that have been selected to avoid impact by site drainage and/or pooling.
Prior to storage at these locations, planks or pallets are placed beneath the drum
storage locations in order to raise the container from the ground surface and avoid
corrosion from water which may accumulate during precipitation events ( despite
site selection) and from rusting due to soil moisture when drums are stored
directly on the ground. These contained materials are subject to the more
particular storage protocols and inspections outlined below.
3.3 Storage Protocol Single Lined Containers
In accordance with MSHA requirements, container storage must be implemented
in such a manner as t limit the potential for a container to tip or fall onto a worker.
For drummed materials, the agency limits such stacks to three drums in height due
to stability considerations. In keeping with these concerns, EFR will configure
(
No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 3 STANDARD OPERA TING PROCEDURES Page 3 of3
Date: February 10, Title: Containerized Alternate Feedstock Material Storage
2017 Procedure
single lined storage drums (stored off the Designated Feedstock Area) in rows no
more than two containers wide at the base and may place a one-container row
either on top of a single row or in the middle of a lower two-container row, in
each case so as to straddle the tops of drums in the lower container row(s). This
stacking configuration distributes the single upper row across bottom row(s) of
containers in such a manner as to hold the bottom row(s) from leaning and
allowing for limited stacking on top of these lower row(s). accordingly, when
stacking is necessary, this configuration minimizes the risk of falling drums,
limits stacking height for safety reasons and allows for a thorough inspection of
each of the individual containers from the outside of the container row(s).
3.4 Single Lined Container Storage Area Inspections
3.5
The single lined container storage area(s) that are off of the Designated Feedstock
Area will be inspected on a weekly basis (and after significant precipitation
events) on both sides of any row in order to assure that the stored materials
remain intact, that standing water has not accumulated and that materials are not
leaking or migrating from the storage area.
Single Lined Container Storage Inspection Records
EFR will record all instances where single lined containers are received damaged
( or leaking) and require re-packing or the provision of an over-pack container.
This information will be recorded on a container receipt form (see Attachment B)
which documents the receipt of drummed materials to be stored in locations other
than the Defined Feedstock Area. Similarly, each weekly inspection shall be
recorded on the inspection form referred to in the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT) Monitoring
Plan at Attachment A-3 and attached as Attachment C to this procedure. Such
inspections require the documentation of container condition, the drainage
conditions in the storage location, the presence of leakage, if any, and any
corrective actions taken due to leakage of containers or standing water at the
storage location.
(
(
Feed Material Receipt
Inspection
Date: -------·----
Inspector: _________ _
Is the shipment leaking? Yes or No
If Yes, complete the other side of this document.
Number of containers/drums in shipment: ________ _
Radiation Activity Levels: -----------
Location of Storage: ____________ _
Corrective Action Taken for Damaged Drums:
Observations (note dented or damaged drums)
Inspector: _________ _
(Print Name) (Signature)
Feed Material Receipt
Inspection
Name of generator of shipment: __________ _
Bill of Lading#:----------------
Activity in Curies:----------------
Radionuclides: -----------------
The amount of material that leak out of the package (if known):
The amount of material that leak out of the conveyance (if known):
Can it be determined when the leak occurred?
Corrective Actions:
RSO: --------
{Print Name) {Signature)
' r
No.: PBL-20 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 1 of 1
Date: December 18, Title: SX Organic Reconditioning Overview
2012
Standard Operating Procedures for SX Organic Reconditioning Process
The following st_andard operating procedures (SOP) for the reconditioning of the SX
organic process is attached. These operating procedures are summarized by nodes with
the hazards, PPE, cautionary statements and operating instructions for each node. A node
is a phase of recovery in the overall process and is indicated by graphic presentation of
the process flow. A block flow diagram of the overall process is also attached.
There are general considerations that are applicable to all process nodes. They are:
• Lines and Pumps
All lines, pumps and valves must be used according to specific operating
instructions that will be issued as required during process evaluations and
recovery.
• Specific Operating Instructions
Specific operating instructions apply to each process node based upon the
metallurgical requirements necessary for recover of an on-specification product.
These instructions will change periodically after operating process and parameters
have been determined.
• Ventilation
It is necessary that at each stage of processing and location the ventilation system
is checked and is running. This is extremely important because there is always a
potential for toxic gas and vapors to be generated.
• Hazard Assessment Worksheet
Each hazard assessment work sheet identifies hazardous parameters for each
node, such as operating temperature, pressure and radioactive content of each
stream. The overall hazard rating is based on quantity of chemical, phase of the
chemical (gas, solid, and liquid) and the MSDS health rating for each chemical.
The overall health rating is the sum of the three ratings.
• Personnel Protective Equipment (PPE)
PPE is identified on each node and is accompanied by cautionary statements of
each important hazardous chemical.
This information will be presented to all operations personnel and any questions
regarding this information will be answered.
This SOP may be modified as necessary by a Safe Work Permit which would establish
new procedures and requirements during the reconditioning process of the SX organic
material.
No.: PBL-20 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERATING PROCEDURES Page 1 of 3
Date: December 18, Title: SX Organic Reconditioning
2012
Hazard Assessment Worksheet Node #1
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Nai C03 Contacting Node
Process Material in Component
Sodium Kerosene Tertiary Binary
Carbonate Amine Amine
7,700 123,000 2,700 4,000
12 90-95 0.5-5.0 1-5
----
--
--
--
Amb Amb Amb Amb
---
Tri-
Decyl
Alcohol
4,000
1-5
Amb
Assessment Description: The aqueous phase, sodium carbonate solution, is a strong base
and can cause eye injury if splashed in the eyes or chemical bums if it comes into contact
with the skin. The organic phase, containing kerosene, amines, and tri-decyl alcohol, can
irritate the eyes or skin if it comes in contact. Appropriate personal protective equipment
must be worn to protect eyes and skin from accidental contact with either phase. If any
organic or aqueous phase gets on your clothing or skin, wash it off immediately with
generous amounts of soap aild water. The organic phase is also flammable. No
equipment or activity that could generate any sparks or open flames is allowed in
the vicinity of the organic phase.
Organic Phase for
Reconditioning
Barren
Organic
Tanlc
To Tails
Re-Generation
Mixer/Settler Aqueous
No.: PBL-20 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 2 of 3
Date: December 18, Title: SX Organic Reconditioning
2012
Operating Instructions
The SX organic to be reconditioned shall be treated in batches of approximately 20,000
gallons, or other volumes as instructed by your supervisor.
• Make sure you are familiar with the MSDS for each of the components of the
aqueous and organic phases.
• Make sure all materials that may interfere with the organic reconditioning
treatment have been removed from the re-generation mixer/settler.
• Make a safety inspection of all lines and equipment.
o Inspect lines and vessels for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Transfer organic phase to be reconditioned into the barren organic tank -about
20,000 gallons, or some other volume as instructed by your supervisor.
• Transfer 12% sodium carbonate solution into the re-generation mixer/settler-
about 7,000 gallons, or some other volume as instructed by your supervisor.
• Tum on agitation in the re-generation mixer and adjust valves to begin re-
circulating aqueous phase from the settler to the mixer at a rate of about 100-150
gallons per minute or as instructed by your supervisor.
• Begin feeding organic from the barren organic tank to the re-generation mixer at a
rate of about 50 gallons per minute or as instructed by your supervisor and re-
circulate treated organic from the settler back to the barren organic tank.
• Continue circulating aqueous and organic phases through the re-generation
mixer/settler at the target rates for at least 24 hours or for some other time as
instructed by your supervisor.
• At the conclusion of the sodium carbonate contacting treatment, stop recirculation
of both the organic and aqueous phases through the re-generation mixer/settler.
Transfer the spent aqueous phase to tailings as instructed by your supervisor.
(
No.: PBL-20 ENERGY FUELS RESOURCES (USA) INC .
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: SX Organic Reconditioning
2012
Transfer all organic phase in the re-generation mixer/settler back to the barren
organic tank in preparation for the next stage of the re-conditioning treatment.
NOTE: Whenever working in, around or on this process circuit you must wear
appropriate PPE which may include Tyvex coveralls, rubber boots, gloves,
safety glasses, face shield and whatever level of respiratory protection is deemed
appropriate by the Radiation Safety Officer.
SCBA devices must be available whenever handling methanol inside the SX
building.
Drums of Methanol should not be stored in direct sunlight during the warmer
weather seasons of the year.
No.: PBL-20 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES
Date: December 18, Title: SX Organic Reconditioning
2012
Hazard Assessment Worksheet Node #2
Equipment Component
Individual Equipment No.
Parameter
PFD
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
NaOH/Methanol Contacting Node
Process Material in Component
Sodium Kerosene Tertiary Binary
Hydroxide Amine Amine
15,000 123,000 2,700 4,000
25 90-95 0.5-5.0 1-5
----
--
--
--
40 40 40 40
----
Page 1 of 3
Methanol
5,000
10
40
Assessment Description: The aqueous phase, sodium hydroxide/methanol solution, is a
strong base and can cause eye injury if splashed in the eyes or chemical bums if it comes
into contact with the skin. The organic phase, containing kerosene, amines, and tri-decyl
alcohol, can irritate the eyes or skin if it comes in contact. Appropriate personal
protective equipment must be worn to protect eyes and skin from accidental contact with
either phase. If any organic or aqueous phase gets on your clothing or skin, wash it
off immediately with generous amounts of soap and water. The organic phase is
also flammable. No equipment or activity that could generate any sparks or open
flames is allowed in the vicinity of the organic phase. The methanol is poisonous
and should not be ingested.
Barren Organic
Tank
To Another
Vessel in SX To Tails
Re-Generation
Mixer/Settler
Aqueous
No.: PBL-20 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of3
Date: December 18, Title: SX Organic Reconditioning
2012
Operating Insti·uctions
The SX organic to be reconditioned shall be treated in batches of approximately 20,000
gallons, or other volumes as instructed by your supervisor.
• Make sure you are familiar with the MSDS for each of the components of the
aqueous and organic phases.
• Make sure all materials that may interfere with the organic reconditioning
treatment have been removed from the re-generation mixer/settler.
• Make a safety inspection of all lines and equipment.
o Inspect lines and vessels for leaks or seeps.
o Inspect safety showers and eyewash fountains.
• Transfer 50% sodium hydroxide solution into the re-generation mixer/settler -
about 3,200 gallons and dilute with water to about 6,400 gallons, or some other
volume as instructed by your supervisor.
• Before adding methanol to the re-generation mixer/settler make sure that a
representative of the Safety Department has been contacted and is present with an
appropriate air sampling device for monitoring methanol levels in the air.
• Transfer about 700 gallons of methanol to the solution ofNaOH in the re-
generation mixer/settler. Complete the next two steps as quickly as possible after
the addition of methanol to quickly cover the aqueous solution in the settler with
about 12 inches of organic phase and thus minimize the time of exposure of the
methanol-containing solution to the air.
• Tum on agitation in the re-generation mixer and adjust valves to begin re-
circulating aqueous phase from the settler to the mixer at a rate of about I 00-150
gallons per minute or as instructed by your supervisor.
• Begin feeding organic from the barren organic tank to the re-generation mixer at a
rate of about 50 gallons per minute or as instructed by your supervisor, and re-
circulate treated organic from the settler back to the barren organic tank.
(
No.: PBL-20 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-3 ST AND ARD OPERATING PROCEDURES Page 3 of 3
Date: December 18, Title: SX Organic Reconditioning
2012
• Inject steam into the aqueous solution in the bottom of the re-generation settler
until it reaches a temperature of about 40°C.
• Continue circulating aqueous and organic phases through the re-generation
mixer/settler at the target rates and continue injection of steam to maintain a
temperature of about 40°C for at least 48 hours or for some other time as
instructed by your supervisor.
• At the conclusion of the sodium hydroxide/methanol contacting treatment, stop
recirculation of both the organic and aqueous phases through the re-generation
mixer/settler. Transfer the spent aqueous phase to tailings as instructed by your
supervisor. Transfer the organic phase to another vessel in SX as instructed by
your supervisor.
NOTE: Whenever working in, around or on this process circuit you must wear
appropriate PPE which may include Tyvex coveralls, rubber boots, gloves,
safety goggles or face shield, and whatever level of respiratory protection is
deemed appropriate by the Radiation Safety Officer.
SCBA devices must be available whenever handling methanol inside the SX
building.
Drums of methanol should not be stored in direct sunlight during the warmer
weather seasons of the year.
(
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 1 of
Date: December 18, Title: UF4 Processing 25
2012
STANDARD OPERATING PROCEDURES FOR UF4 PROCESSING
Overview
The following standard operating procedures ("SOP") are for the processing of the UF4
alternate feed material. These operating procedures are summarized by nodes with the
hazards, PPE, cautionary statements and operating instructions for each node. A node is
a phase of recovery in the overall process and is indicated by graphic presentation of the
process flow. A block flow diagram of the overall process is set out on the following
page.
There are general considerations that are applicable to all process nodes. They are:
• Lines and Pumps
All lines, pumps and valves must be used according to specific operating
instructions that will be issued as required during process evaluations and
recovery.
• Specific Operating Instructions
Specific operating instructions apply to each process node based upon the
metallurgical requirements necessary for recovery of an on-specification product.
These instructions will change periodically after operating process and parameters
have been determined.
• Hazard Assessment Worksheet
Each hazard assessment worksheet identifies hazardous parameters for each node,
such as operating temperature, pressure and radioactive content of each stream.
The overall hazard rating is based on quantity of chemical, phase of the chemical
(gas, solid, and liquid) and the MSDS health rating for each chemical. The
overall health rating is the sum. of the three ratings.
• Personnel Protective Equipment ("PPE")
PPE is identified on each node and is accompanied by cautionary statements of
each important hazardous chemical.
This information will be presented to all operations personnel, and any questions
regarding this information will be answered.
This SOP may be modified as necessary by a Radiation Work Permit ("RWP") which
would establish new procedures and requirements during the processing of the UF4
alternate feed material.
No.: PBL-21
Rev. No.: R-2
Date: December 18,
2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: UF4 Processing
Block Flow Diagram of Overall Process
ToTails-
Cell 1
lmpuriy
~emoval
Tank1
Impurity
R~oval
Tank2
Product
Ho/din Tank
Se oond Stage
Fl!er Press
Page 2 of
25
Barren Solids
To Tailings
(
l
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES
Date: December 18, Title: UF4 Processing
2012
NODE #1-UF4 DRUM DUMPING
Equipment Component
Individual Equipment No.
Parameter
Process Flow Diagram
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Hazard Assessment Worksheet
UF4 Drum Dumping Node
Process Material in Component
Uranium Sodium Hydrogen
Tetra-Carbonate Peroxide
fluoride
1600 8,300 250
70-90 10 50
----
--
--
484,263 --
25-80 25 -80
----
1 1 2
Rad 0 Oxy
Page 3 of
25
Assessment Description: The UF4 material is a dry solid and can become airborne easily.
Also, the UF4 material contains fluorides which can become highly corrosive if allowed
to come in contact with acids. The material should be left undisturbed as much as
possible once the drums are opened until the drums are loaded in the drum dumper. The
UF 4 material is also radioactive and you must follow established health physics
controls. If any UF 4 gets on your clothing or skin, wash it off with generous
amounts of soap and water.
No.: PBL-21
Rev. No.: R-2
Date: December 18,
2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: UF4 Processing
Drums
ofUF4 Steam
H,O r.1..-----,i
,--_....____._ _ _.__._,
Steam
Na2C03 Make-
Up Tank
Operating Instructions
Submerged Drum
Dumping Station
Page 4 of
25
Digestion/
Precipitation
Tank
The UF4 drums must be kept sealed or covered as much as possible until all process
components are ready for dumping the drums.
• Make sure you are familiar with the MSDS sheets for the UF4 material and the
sodium carbonate, copies of which are attached to this procedure.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains.
This processing of UF4 consumes significant volumes of sodium carbonate (soda ash)
solution. A batch of the sodium carbonate (soda ash) solution is made up as follows:
• Add a volume of water to the sodium carbonate make-up tank as instructed by
your supervisor.
• Tum on agitation in the tank and add steam as needed to raise the water
temperature as instructed by your supervisor (normally about 80°C).
• Raise a supersack of soda ash into position and gradually add soda ash to the
stirred water in the tank. Repeat with additional supersacks of soda ash until you
have added the amount of soda ash as instructed by your supervisor.
(
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERA TING PROCEDURES Page 5 of
Date: December 18, Title: UF4 Processing 25
2012
• Continue stirring and heating the contents of the tank as instructed by your
supervisor until all of the soda ash has dissolved.
• Transfer a volume of sodium carbonate (soda ash) solution from the make up tank
to the drum dumping station as instructed by your supervisor.
• Add a volume of hydrogen peroxide solution to the drum dumping station as
instructed by your supervisor.
The procedure for dumping the UF 4 drums is as follows:
• Put on the PPB specified in the applicable RWP or as otherwise specified by the
Radiation Safety Officer.
• Tum on the drum dumping station and the weigh scale.
• Place a UF 4 drum in position for handling.
• Weigh the drum and record the drum weight.
• Undo the drum lid carefully and report any unusual conditions to your supervisor.
• Examine the contents of the drum. If the contents of the drum have solidified to
the extent that the material cannot be easily removed from the drum, then refasten
the lid and set the drum aside for special handling at a later date. For all other
drums, proceed with the following steps.
• Place the drum in the drum dumper. Make sure the drum is properly secured and
make sure all personnel are clear of the drum dumper mechanisms. Then actuate
the drum dumper and dump its contents into the bath portion of the dumping
station while the drum is submerged in the bath.
• Set the valves in the appropriate positions to re-circulate the contents of the bath
and start the discharge pump.
• Operate water jets and other features of the dumping station until the drum has
been completely emptied. Then actuate the dumping mechanism to remove the
empty drum from the bath.
• Inspect the drum to assure it is empty and then remove the empty drum from the
process area as instructed by your supervisor. If the drum is not empty, repeat
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 6 of
Date: December 18, Title: UF4 Processing 25
2012
drum dumping steps as necessary the remove all remaining material from the
drum.
• Repeat the process steps described above for additional drums of UF4 material
until the target number of drums for the current batch, as instructed by your
supervisor, is reached.
• Once the target number of drums ofUP4 for the dumping station batch have been
dumped, change the settings of valves on the dumping station discharge to
transfer the slurry of dumped UP4 material to the digestion/precipitation tank and
transfer the slurry as instructed by your supervisor.
• Dispose of the empty drums as instructed by your supervisor.
• Tum off the drum dumper, the weigh scale, and the conveyor belt.
• Clean up any spilled UP 4 material, drum parts, tools, etc. and ensure your work
area is free of hazardous obstructions. Prepare the area to handle the next batch of
drums.
NOTE: Whenever working in, around or on this process circuit you must wear
appropriate PPE which may include Tyvex coveralls, rubber boots, gloves,
safety glasses, face shield and full face respirators, all as specified in the
applicable RWP or as otherwise specified by the Radiation Safety Officer.
Mobile Equipment
The forklift handling the drums of UP 4 material will be operated according to normal
operating procedures, taking special precautions to avoid spilling or rupturing any of the
drums of the UF 4 material.
(
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 7 of
Date: December 18, Title: UF4 Processing 25
2012
NODE #2 -UF4 CARBONATE DIGESTION NODE
Hazard Assessment Worksheet
Equipment Component 1l& Carbonate Digestion Node
Individual Equipment No.
Parameter Process Material in Component
Process Flow Diagram Uranium Sodium Hydrogen
Carbonate Peroxide
Quantity in Equipment (lb) 1200 8,300 440
Concentration (%) 1.4 10 50
Flashpoint, °F ------
TLV-TWA mg/mj ------
STEL mg/mj ------
Radioactivity, pCi/g 484,242 ------
Temperature, °C 80 80 Amb.
Pressure, psig --------
Health Rating 1 1 2
Hazard Rating Rad 0 Oxy
Assessment Description: The UF 4 material is completely dissolved in the heated sodium
carbonate (soda ash) solution in this processing step. The liquid in the digestion vessel is
strongly basic. Any splashing or contact with the skin should be avoided. These
materials can cause skin and eye burns. The dissolved UF4 material is also
radioactive and you must follow established health physics controls. If any
carbonate digestion solution gets on you, wash it off with generous amounts of soap
and water.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 8 of
Date: December 18, Title: UF4 Processing 25
2012
Steam
Operating Instructions
Digestion/
Precipitation
Tank
This node deals with digesting the UF4 material in sodium carbonate (soda
ash) solution at 80°C for about 4 hours.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• As the digestion tank is being filled from the drum dumping station,
once the level of slurry in the digestion tank is appropriate for starting
agitation without causing splashing or spillage -then start agitation.
Continue receiving slurry from the drum dumping station until a full
batch has been received.
• Add the required volume of hydrogen peroxide solution to the
digestion tank as instructed by your supervisor. Wear appropriate PPE
for handling hydrogen peroxide, as specified below.
• Add steam to the contents of the tank until the contents reach 80°C.
Continue adding steam as needed to maintain this temperature.
• Continue agitation of the tank contents at 80°C for 4 hours to complete
the necessary digestion.
• At the end of the digestion time, measure the volume of final digestion
solution in the tank and take a sample of the contents of the tank and
(
\
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 9 of
Date: December 18, Title: UF4 Processing 25
2012
place the sample in an appropriately marked container. Make sure this
sample container is marked clearly with the batch number, the sample
identification and the date. Make sure this sample is collected by
laboratory technicians and transported to the laboratory.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and you must wear PPE which
includes at a minimum, hard hat, coveralls, rubber boots and gloves,
safety glasses with side shields, and may include respiratory
protection, a face shield or safety goggles, all as specified in the
applicable RWP or as otherwise specified by the Radiation Safety
Officer.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 10 of
Date: December 18, Title: UF4 Processing 25
2012
NODE #3 -NaOH PRECIPITATION NODE
Hazard Assessment Worksheet
Equipment Component NaOH Precigitation Node
Individual Equipment No.
Parameter per Tank Process Material in Component
Process Flow Diagram Uranium Sodium NaOH Diatomaceous
Carbonate Earth Filter
Aid
Quantity in Equipment (lb) 1200 8,300 6,800 3,000
Concentration (%) 1.4 10 50 3
Flashpoint, °F ------
TLV-TWA mg/m1 ------
STEL mg/m3 ------
Radioactivity, pCi/g 484,242 ------
Temperature, °C 70 70 Amb Amb
Pressure, psig --------
Health Rating 1 1 3 0
Health Hazard Rad 0 Cor 0
Assessment Description: A uranium-rich precipitate is formed by NaOH addition to the
solution from the carbonate digestion of the UF 4 material in this processing step. The
liquid in the tank is strongly basic. Any splashing or contact with the skin should be
avoided. These materials can cause skin and eye burns. The solution and the
precipitate that is formed are also radioactive and you must follow established
health physics controls. If any of the solution or precipitate gets on you, wash it off
with generous amounts of soap and water.
(
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 11 of
Date: December 18, Title: UF4 Processing 25
2012
Digestion/
Precipitation
Tank
50%
NaOH
Filter Feed
Tank
Operating Instructions
This riode deals with formation of a uranium-rich precipitate by addition of
NaOH to the final solution from the carbonate digestion of the UF4 material.
• This precipitation processing step will be done in the same tank in
which the carbonate digestion was performed.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Continue agitation of the final solution from carbonate digestion of the
UF4 material. Add steam, if necessary, to maintain the contents of the
digestion/precipitation tank at least at 70°C (158°F).
• Make sure you are wearing all appropriate PPE for handling 50%
NaOH (caustic) solution, as specified below.
• To the agitated contents of the digestion/precipitation tank carefully
add 50% N aOH (caustic) solution until the pH of the contents of the
tank reaches at least 13.0 as instructed by your supervisor. Measure
the pH of the tank contents with pH paper obtained from the lab. Do
not measure the pH using an ordinary pH meter and probe -these may
not give correct pH readings in this solution.
• After the contents of the tank reach the target pH, continue for 4 hours
to agitate the tank contents at the target temperature and continue to
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 12 of
Date: December 18, Title: UF4 Processing 25
2012
carefully add small volumes of the 50% NaOH solution to the tank as
necessary to maintain the target pH.
• After four hours the precipitation reaction should be complete. At this
point add to the slun·y in the digestion/precipitation tank the amount of
filter aid (diatomaceous earth) as instructed by your supervisor. Make
sure you are wearing the appropriate respirator protection as
detemuned by the RSO whenever handling or working in the vicinity
of filter aid in its dry condition. Then adjust the necessary valves, turn
on the pump, and transfer the contents of the digestion/precipitation
tank to the filter feed tank.
• After the batch of material has been transferred as completely as
practical from the digestion/precipitation tank to the filter feed tank
then make sure the digestion/precipitation tank agitator is turned off
and that all valves, pumps, etc. have been returned to the proper
settings for starting handling of the next batch of UF 4 slurry from the
drum dumping station.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and may include respiratory
protection, a face shield or safety goggles, al] as specified in the
applicable RWP or as otherwise specified by the Radiation Safety
Officer.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. Nci.: R-2 STANDARD OPERATING PROCEDURES
Date: December 18, Title: UF4 Processing
2012
NODE #4-NaOH PRECIPITATE FILTRATION NODE
Equipment Component
Individual Equipment No.
Parameter per Tank
Process Flow Diagram
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Health Hazard
Hazard Assessment Worksheet
NaOH Precipitate Filtration Node
Process Material in Component
Uranium Sodium NaOH
Carbonate
1200 8,300 6,800
1.4 10 8
------
----
----
484,242 ----
70 70 70
------
1 1 3
Rad 0 Cor
Page 13 of
25
Diatomaceous
Earth Filter Aid
3,000
3
--
--
--
Amb.
--
0
0
Assessment Description: The uranium-rich precipitate formed by NaOH addition to the
solution from the carbonate digestion of the UF 4 material is separated from the solution
by pressure filtration. Make sure all pressurized lines, connections and fittings are in
good condition and not leaking. The liquid in the tank is strongly basic. Any splashing
or contact with the skin should be avoided. The chemicals in the liquid can cause skin
and eye bums. The solution and the precipitate are also radioactive and you must
follow established health physics controls. If any of the solution or precipitate gets
on you, wash it off with generous amounts of soap and water. The filter aid material
is dusty in the dry condition and you must avoid breathing the dust.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 14 of
Date: December 18, Title: UF4 Processing 25
2012
Filtrate and
Wash Surge
Tank
To Tails
-Cell !
Filter Cake
Re-Pulp
Tank 1
Operating Instructions
Filter Calce
Acid Re-
Dissolution
Tank
This node deals with the pressure filtration processing step to recover the
uranium-rich precipitate formed by NaOH addition to the solution from the
carbonate digestion of the UF4 material.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Inspect the filter to make sure it has been fully dumped,
cleaned, and prepared to receive fresh feed material.
• If body feed filter aid has already been added in the
digestion/precipitation tank, omit the first two steps of this SOP Node.
Otherwise, open or close the necessary valves and tum on the
necessary pumps to circulate the slurry from the filter feed tank
through the filter aid addition tank and back to the filter feed tank.
Tum on agitation in the filter aid addition tank. Add and mix into the
contents of the filter aid addition tank the amount and type of body
feed filter aid as instructed by your supervisor. Make sure you are
wearing the appropriate respirator as determined by the Radiation
Safety Officer whenever handling or working in the vicinity of filter
aid in its dry condition.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 15 of
Date: December 18, Title: UF4 Processing 25
2012
• When all body feed filter aid has been added, tum off appropriate
pumps and adjust the appropriate valves to shut off flow from the filter
feed tank to the filter aid addition tank. Complete transfer of all slurry
from the filter aid addition tank to the filter feed tank, using a small
volume of water as necessary to rinse out the tank. Then tum off the
pump and adjust the valves to shut off flow from the filter aid addition
tank to the filter feed tank.
• Add water to the filter aid addition tank for pre-coating the pressure
filter according to instructions from your supervisor. Start agitation of
the tank and then add pre-coat filter aid to the tank according to
instructions from your supervisor. Mix the contents of the tank
thoroughly. Make sure you are wearing the appropriate respirator as
determined by the Radiation Safety Officer whenever handling or
working in the vicinity of filter aid in its dry condition.
• Adjust all necessary valves and tum on the pump to transfer pre-coat
filter aid slurry from the filter aid addition tank to the filter press.
Pump the entire contents of the filter aid addition tank through the
filter press. Then tum off the pump and adjust all necessary valves to
leave the pre-coated filter press filled with water under some pressure.
• Adjust all necessary valves and tum on the pump from the filter feed
tank to the filter press. Recycle filtrate back to the filter feed tank until
the solution clears and then adjust the appropriate valves to send all
barren filtrate to the filtrate and wash surge tank. Pump the contents of
the filter feed tank through the filter press until the tank is empty or the
pressure or flow rate indicates the filter press chambers are full of filter
cake.
• Tum off the pump from the filter feed t~ adjust the necessary
valves, and run wash water through the filter press according to
instructions from your supervisor. Send the filter discharge to the
filtrate and wash surge tank.
• Shut off the wash water, adjust the appropriate valves, and run
compressed air through the filter press according to instructions from
your supervisor. Send the filter discharge liquid to the filtrate and
wash surge tank.
• When the filter cake has been adequately dried by the compressed air,
shut off the air flow and depressurize the filter press.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 16 of
Date: December 18, Title: UF4 Processing 25
2012
• Tum on the screw conveyor system under the filter press, open the
filter, and dump and transfer all filter cake to the filter cake re-pulp
tank 1.
• Add water to the filter cake re-pulp tank 1 as instructed by your
supervisor and agitate the contents of the tank until the filter cake is
fully re-pulped. Adjust appropriate valves and tum on the pump to
transfer the re-pulped filter cake slurry to the filter cake acid re-
dissolution tank according to instructions from your supervisor.
• Clean the filter press, close it up, and prepare it for its next filtration
cycle.
• Repeat pre".'coating the filter, filtering the contents of the filter feed
tank, and dumping and re-pulping the filter cake and transferring it to
the filter cake acid re-dissolution tank until the filter feed tank is
empty.
• Make sure the volume in the filtrate and wash surge tank is measured
and recorded and make sure a sample of the contents of the tank is
placed in an appropriately marked sample container for analysis by the
lab. Then send the contents of the filtrate and wash surge tank to
tailings.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and may include respiratory
protection, a face shield or safety goggles, all as specified in the
applicable RWP or as otherwise specified by the Radiation Safety
Officer.
• Always keep your work area clean and ensure your work area is free
of obstructions.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERATING PROCEDURES Page 17 of
Date: December 18, Title: UF4 Processing 25
2012
NODE #5 -FILTER CAKE ACID RE-DISSOLUTION NODE
Equipment Component
Individual Equipment No.
Parameter per Tank
Process Flow Diagram
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA ppm
STEL ppm
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Health Hazard
Hazard Assessment Worksheet
Filter Cake Acid Re-Dissolution Node
Process Material in Component
Uranium Sulfuric Acid Sodium
Chlorate
1200 1250 . 150
1-8 93 50
----
--
--
484,242 ----
25-40 25-40
--0-100 --
I 3 I
Rad Cor Oxy
--
--
--
--
Assessment Description: The re-pulped filter cake of basic uranium-rich precipitate and
the acidic solution in which it will be digested should be handled with caution. Any
splashing or contact with the skin should be avoided. The acidic chemicals in the liquid
can cause skin and eye burns. The solution and the f'Ilter cake are also radioactive
and you must follow established health physics controls. If any of the solution or
f'llter cake gets on you, wash it off with generous amounts of soap and water.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 18 of
Date: December 18, Title: UF4 Processing 25
2012
Filter Cake Acid
Re-Dissolution
Tank
Operating Instructions
This node deals with the acid digestion of re-pulped uranium-rich filter cake.
• Make a safety inspection of all equipment.
o Inspect safety showers and eyewash fountains
o Inspect valves and fittings in the acid line.
• As the slurry of re-pulped filter cake is being transferred to the filter
cake acid re-dissolution tank, tum on agitation in the tank as soon as
the level is sufficient according to your supervisor's instructions.
• Add water to the contents of the filter cake acid re-dissolution tank
according to instructions from your supervisor and carefully add
sulfuric acid to bring the pH of the slurry to 2.0 or a lower pH as
instructed by your supervisor. Add a volume of sodium chlorate
solution to the contents of the filter cake acid re-dissolution tank as
instructed by your supervisor.
• Add steam to bring the contents of the filter cake acid re-dissolution
tank to 40°C or another temperature as instructed by your supervisor.
Agitate the slurry in the tank at the target temperature and pH for a
time of at least one hour as instructed by your supervisor, adding
steam and sulfuric acid as needed to maintain these conditions.
No.: PBL~2I ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 19 of
Date: December 18, Title: UF4 Processing 25
2012
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and respiratory protection, a
face shield or safety goggles, all as specified in the applicable RWP or
as otherwise specified by the Radiation Safety Officer.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 20 of
Date: December 18, Title: UF4 Processing 25
2012
NODE #6-FILTRATION AFTER ACID DIGESTION OF FILTER CAKE NODE
Equipment Component
Individual Equipment No.
Parameter
Process Flow Diagram
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/m3
STEL mgiim3
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Hazard Assessment Worksheet
Filtration After Acid Digestion of Filter Cake Node
Process Material in Component
Uranium Dilute H2S04 Diatomaceous
Earth Filter
Aid
1,200 50 3,000
2-4 0.1-0.2 8-10
------
----
----
----
40 40 40
----
1 3 0
Rad Cor 0
Assessment Description: This processing step involves pressure filtration of an acidic
slurry. Any splashing or contact with the skin should be avoided. The acidic chemicals
in the liquid can cause skin and' eye burns. The solution and the filter cake are also
radioactive and you must follow established health physics controls. If any of the
solution or filter cake gets on you, wash it off with generous amounts of soap and
water. If any of the filter cake becomes dry, respiration of the dust must be avoided.
The filter press and piping leading to it will be under pressure and should be handled
carefully.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 21 of
Date: December 18, Title: UF4 Processing 25
2012
Filtrate
and
Wash
Impurity
Removal Tank
1
Comp.
Air
Impurity
Removal Tank
2
Filter Cake
Re-Pulp
Tank2
Second Stage
Filter Press
Filter Cake Acid
Re-Dissolution
Tank
Operating Instructions
In this processing step the used filter aid is separated from the dissolved
uranium by pressure filtration.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
o Inspect the filter feed pump and the filter press for leaks and
proper assembly.
o Inspect safety showers and eyewash fountains.
• Adjust all necessary valves and tum on the pump from the filter cake
acid re-dissolution tank to the filter press. Recycle filtrate back to the
filter cake acid re-dissolution tank until the solution clears and then
adjust the appropriate valves to send the filtrate to impurity removal
tank 1 or tank 2. Pump the contents of the filter cake acid re-
dissolution tank through the filter press until the tank is empty or the
pressure or flow rate indicates the filter press chambers are full of filter
cake.
• When the pressure or flow rate indicates the filter press chambers are
full of filter cake, tum off the pump from the filter cake acid re-
dissolution tank, adjust the necessary valves, and run wash water
through the filter press according to instructions from your supervisor.
Setid the filtrate from washing to the same impurity removal tank.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 22 of
Date: December 18, Title: UF4 Processing 25
2012
• When the water wash is completed, shut off the wash water, adjust
appropriate valves, and run compressed air through the filter press
according to instructions from your supervisor. Send any liquid
discharged from the filter press to the same impurity removal tank.
• When the filter cake has been adequately dried by the compressed air,
shut off the air flow and depressurize the filter press.
• Tum on the screw conveyor system under the filter press, open the
filter, and dump and transfer all filter cake to the filter cake re-pulp
tank 2.
• Add water to the filter cake re-pulp tank according to instructions from
your supervisor and agitate contents of the tank until the filter cake is
fully re-pulped. Transfer the re-pulped filter cake slurry to the cake
washing tank according to instructions from your supervisor.
• Clean the filter press, close it up, and prepare it for its next filtration
cycle.
• Repeat, as needed, steps for filtering the contents of the filter cake acid
re-dissolution tank and dumping and re-pulping and transferring the
filter cake until the filter cake acid re-dissolution tank is empty.
• Transfer the clear supernatant liquid from the cake washing tank back
into the process to recover the contained uranium according to
instructions from your supervisor. Wash the filter cake solids in the
cake washing tank with water as instructed by your supervisor. Once
the washing of the filter cake solids is sufficient, transfer the solids
from the cake washing tank to tailings according to instructions from
your supervisor.
• Make sure a sample is taken of the underflow solids slurry transferred
from the cake washing tank to tailings.
• Whenever working in, around or on this process you must avoid
splashing and any contact with the skin and YOU MUST wear PPE
which includes at a minimum, hard hat, coveralls, rubber boots and
gloves, safety glasses with side shields, and may include respiratory
protection, a face shield or safety goggles, all as specified in the
applicable RWP or as otherwise specified by the Radiation Safety
Officer.
• Always keep your work area clean and ensure your work area is free
of obstructions.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 ST AND ARD OPERATING PROCEDURES
Date: December 18, Title: UF4 Processing
2012
NODE #7 -IMPURITY REMOVAL NODE
Equipment Component
Individual Equipment No.
Parameter
Process Flow Dia1rram
Quantity in Equipment (lb)
Concentration (%)
Flashpoint, °F
TLV-TWA mg/mj
STEL mg/mj
Radioactivity, pCi/g
Temperature, °C
Pressure, psig
Health Rating
Hazard Rating
Hazard Assessment Worksheet
Impurity Removal Node
Process Material in Component
Uranium H2S04 Ammonia
1200-2400 50-500 100-250
2-4 93 100
------
--25
--35
----
40 20 20
1 3 3
Rad Cor
Page 23 of
25
Assessment Description: In this step, impurities will be separated from the uranium by
pH adjustment and precipitation, using ammonia, followed by settling and decantation.
REMEMBER Ammonia vapor, fumes and mists are Toxic Atmospheres and cannot
be detected by smell above approximately 100 ppm. IF you smell strong ammonia
fumes you must wear a full face respirator with universal cartridges. At high
concentrations your skin and eyes can be burned. The beginning solution and the
precipitate are also radioactive and you must follow established health physics
controls. If any of the solution or precipitate gets on you, wash it off with generous
amounts of soap and water.
No.: PBL-21 ENERGY FUELS RESOURCES (USA) 1NC.
Rev. No.: R-2 STANDARD OPERAT1NG PROCEDURES Page 24 of
Date: December 18, Title: UF4 Processing 25
2012
To Tails -
Cell I
Impurity
Removal
Tank I
Impurity
Removal
Tank2
Product
Holding Tank
To Normal
Yellowcake
Precipitation
Opernting Instructions
This node deals with the separation of uranium from impurities, by adjusting
pH with ammonia (NH3), to form a precipitate, allowing the precipitate to
settle to the bottom of the tank, and then decanting and pumping away the
clear liquid.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tanks for leaks or seeps.
o Inspect safety showers and eyewash fountains
• Measure contained volume and then tum on the agitator and take a
sample of the tank contents for the impurity removal tank containing
the acid digestion liquor that has most recently been clarified by
filtration in the filter press. Place the sample in an appropriately
labeled sample bottle for analysis by the lab.
• Add steam, as necessary, to the contents of the impurity removal tank
according to instructions from your supervisor to establish and
maintain the target temperature for the tank contents. Add ammonia to
the contents of the impurity removal tank according to instructions
from your supervisor. Continue adding ammonia until the contents of
the tank reach and remain at the target pH, as instructed by your
supervisor, and then continue agitation for an additional 30 minutes.
• Tum off the agitator in the impurity removal tank and allow the
precipitate to settle according to instructions from your supervisor.
(
(
l
No.: PBL-21 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-2 STANDARD OPERATING PROCEDURES Page 25 of
Date: December 18, Title: UF4 Processing 25
2012
• Depending on the impurity being removed from the uranium, the
uranium may be contained in either the precipitate or in the
supernatant liquid. Once your supervisor has determined that the
precipitate in the impurity removal tank has settled sufficiently, begin
decanting the clear supernatant liquid from the tank.
• If the uranium is in the precipitate, then transfer the decanted liquid to
tailings as instructed by your supervisor. Be sure to take a sample of
the decanted liquid and record and report the volume of decanted
liquid. After the liquid is completely decanted as instructed by your
supervisor, add water to wash the precipitate as instructed by your
supervisor and agitate, settle and decant again. After washing the
precipitate, add water and sulfuric acid to the precipitate as instructed
by your supervisor and agitate until the uranium is all re-dissolved.
Then either conduct other impurity removal steps on the liquor or
transfer it to the product holding tank.
• If the uranium is in the decanted liquid, then transfer the liquid to the
other impurity removal tank if addition impurity removal is needed, or
else transfer the liquid to the product holding tank. Once the decanting
is complete, add water, agitate, settle and decant again to wash the
precipitate, sending the liquid removed to the same tank as previously.
If the washed precipitate is sufficiently low in uranium, transfer it to
tailings as instructed by your supervisor. Otherwise, send the
precipitate to re-processing as instructed by your supervisor.
• Once impurities have been sufficiently removed and the liquor has
accumulated sufficiently in the product holding tank, transfer the
contents of the product holding tank slowly to the normal yellowcake
precipitation area of the plant. Each time a transfer from this tank
occurs, record and report the volume transferred and take a sample of
the liquor transferred in a properly marked sample container.
• Whenever working in, around or on this process YOU MUST wear
PPE which includes at a minimum, hard hat, coveralls, rubber boots
and gloves, safety glasses with side shields, and may include
respiratory protection, a face shield or safety goggles, all as specified
in the applicable RWP or as otherwise specified by the Radiation
Safety Officer.
(
(
White Mesa Mill -Standard Operating Procedures Date: 12/12 Revision: EFR-2
Page 1 of 4 Book: #11 Environmental Protection Manual, SOP PBL-EP-12
SPECIFIC CONDUCTIVITY, pH METER, AND
TEMPERATURE FIELD INSTRUMENT CALIBRATION
STANDARD OPERA TING PROCEDURES
1.0 SPECIFIC CONDUCTIVITY, pH, AND TEMPERATURE FIELD INSTRUMENT
CALIBRATION STANDARD OPERATING PROCEDURE
2.0
1.1 Introduction
1.2
A critical element in the White Mesa Mill's Groundwater and Surface Water
Monitoring Program is the measurement of each Monitoring Location's field
parameters (i.e., pH, temperature, and conductivity). The instrument utilized at
the Mill to perform these measurements is the Hydrolab Surveyor 4 with multiple
parameter probe called the Minisonde. It is important that all instruments used in
these measurements be calibrated and inspected prior to each use, to ensure that
they are functioning properly and have no obvious, visible damage or
contamination present.
Equipment
1. Hydrolab Surveyor 4 with Minisonde or equivalent
2. NBS traceable thermometer.
3. pH 7.0 and 4.0 buffer solutions.
4. Ecologic Instrument Division of Industrial Municipal Equipment Inc.
stock conductivity solution of 3000 mhos or equivalent
5. Deionized water.
CALIBRATION OF PROBES FOR CONDUCTANCE, pH, AND
TEMPERATURE
2.1 pH Probe Calibration
The following describes the procedures for calibration of the Hydrolab Surveyor 4 /
Minisonde pH probe.
1. Prior to calibration ensure that the Surveyor 4's battery is fully charged.
F:\Mill SOP Master Copy\Book 1 l_Environmental Procedures\07 License Renewal\EFR\PBL-EP-12 Field Instrument
Calibration 2.doc
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White Mesa Mill -Standard Operating Procedures
Book: #11 Environmental Protection Manual, SOP PBL-EP-12
Date: 12/12 Revision: EFR-2
Page 2 of4
2. Inspect probes for visible damage and contamination.
3. Rinse the probes with distilled water prior to placing them in the sample
container.
4. Fill the Minisonde's sample container with pH 7.0 buffer solution. If the
Minisonde's sample container is not used and the probe is placed directly
into a sample container place the probe protector over the probes prior to
measurement.
5. From the Surveyor 4 main menu choose calibrate and press "Enter".
6. At the next prompt choose "Ions-1", and press "Enter".
7. Type "7" after "standard:<<".
8. Thoroughly rinse the probes and sample container with deionized water.
Rinse sensors with a small amount of the pH 4.0 buffer. Fill the sample
cup with the pH 4.0 buffer solution. Allow 1-3 minutes for the readings to
stabilize.
9. In the Main Menu move the cursor to "Calibrate" and press "Enter."
10. Next move the cursor to "Ions" and press "Enter."
11. Place the cursor on "pH: units" and press "Enter."
12. Now type the 4.0 after "standard:<<, followed by "Enter."
13. The pH sensor is now calibrated. If further problems are encountered refer
to the DataSonde4\MiniSonde manual or return instrument to the
manufacturer for repair or calibration if required.
2.2 Temperature Probe Calibration
The following describes the procedures for calibration of the Hydrolab Surveyor
4 I Minisonde temperature probe:
1. The Hydrolab Surveyor 4 / Minisonde temperature probe is calibrated at
the factory and typically does not require any calibration for temperature.
However, a check to ensure that it the probe functioning properly should
be performed prior to each use.
2. Place the probe in distilled water and allow the temperature reading to
stabilize (1-3 minutes), record the reading.
F:\Mill SOP Master Copy\Book I !_Environmental Procedures\07 License Renewal\EFR\PBL-EP-12 Field Instrument
Calibration 2.doc
(
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White Mesa Mill -Standard Operating Procedures Date: 12/12 Revision: EFR-2
Page 3 of4 Book: #11 Environmental Protection Manual, SOP PBL-EP-12
3. Monitor the temperature of the solution with a NBS traceable
thermometer, recording this reading.
4. Comparison of these two temperature readings should not vary more than
0.5 degrees Celsius between the two readings. No reference checks of
temperature readings are retained.
5. At this point sample collection and monitoring of groundwater and surface
water field temperature may proceed.
2.3 Specific Conductance Probe Calibration
The following describes the procedures for proper calibration of Surveyor 4 /
Minisonde for specific conductance measurements:
1. Rinse probes with de-ionized water.
2. Fill sample container with conductivity standard solution.
3. Allow conductivity readings to stabilize (1-3 minutes).
4. Record reading on the Groundwater/Surface Water Field Sampling Sheet.
Repeat previous steps monitoring deionized water (less than 10 mhos). If
conductivity standard reading is within two-percent of the standard and the
deionized water reading is less than 10 mhos, proceed to field
measurements.
5. If the readings do not meet the conditions stated in the previous step,
calibrate the instrument using the conductivity standard.
6. To calibrate choose "Calibrate".
7. From the menu choose "Specific Conductance" and press "Enter."
8. Enter the value of the standard solution in mhos/sq. cm and press "Enter."
9. The Surveyor 4 display will indicate whether or not the calibration was
successful. If display indicates the calibration was successful proceed
forward with field measurements. If display indicates that calibration was
not successful repeat calibration procedures until indication that
calibration was successful is given.
F:\Mill SOP Master Copy\Book 11 _ Environmental Procedures\07 License Renewal\EFR\PBL-EP-12 Field Instrument
Calibration 2.doc
White Mesa Mill -Standard Operating Procedures
Book: #11 Environmental Protection Manual, SOP PBL-EP-12
3.0 QUALITY ASSURANCE
Date: 12/12 Revision: EFR-2
Page 4 of 4
Following the steps outlined in procedures above and using the prescribed equipment will
produce accurate and repeatable results of groundwater and surface water field
parameters. HS/EA Department Manager will review technician performance
periodically.
F:\Mill SOP Master Copy\Book l l_Environmental Procedures\07 License Renewal\EFR\PBL-EP-12 Field Instrument
Calibration 2.doc
White Mesa Mill -Standard Operating Procedures Date: 11/14 Revision: EFR-5
Page 1 of 7 Book # 11, Environmental Protection Manual, Section 1.1
AIR MONITORING-PARTICULATE RADIONUCLIDES
PART I AIR MONITORING PLAN
1.0 PARTICULATE RADIONUCLIDE AIR MONITORING
Air samples for monitoring particulate radionuclides are taken at the following locations:
(See Attachment A)
BHV-1
BHV-2
BHV-4
BHV-5
BHV-6
BHV-7
BHV-8
Northeast of the Mill at the meteorological station.
Approximately 2.5 miles north of the Mill.
Approximately 400 yards south of Cell No. 4.
Approximately 100 yards south of the intersection of Highway 191 and the
Mill access road.
Approximately 0.5 miles south ofBHV-5 along Highway 191.
Approximately 0.8 miles south ofBHV-1 along Highway 191.
Approximately 0.6 miles west ofBHV-1.
Air samples are collected on a weekly basis. A composite of 13 weekly samples from
each of the above locations is prepared to form a quarterly sample for each location.
2.0 QUALITY ASSURANCE
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in this SOP (Section 6.0).
Quality assurance of the analytical results is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percent recovery. The laboratory will
also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides 4.14 and 4.15
when analyzing the air filter samples. The laboratory is committed to meet the LLD
values for radionuclides listed in these guidance documents, and will perform re-runs on
all samples not meeting these limits.
3.0 ANALYTICAL REQUIREMENTS
Each quarterly sample will be analyzed for U-Nat, Ra-226, Th-230, Pb-210 and Th-232.
Results will be expressed in picocuries per milliliter (pCi/mL).
White Mesa Mill -Standard Operating Procedures
Book # i I, Environmental Protection Manual, Section 1.1
PART II STANDARD OPERA TING PROCEDURES
1.0 EQUIPMENT
Date: 11/14 Revision: EFR-5
Page 2 of 7
The equipment used in monitoring levels of particulate radionuclides consists of high
volume air samplers equipped with mass flow controllers and vacuum switch controlled
timers. The samplers are capable of collecting air through the sample filter at a
volumetric flow rate of approximately 40 standard cubic feet per minute (scfin). The
mass flow controller varies the actual air flow rate as dictated by changing temperature,
filter loading, and barometric pressure to maintain a constant standard air flow rate. The
actual rate is read directly from the analog gauge located on the front panel. The timer is
turned off when no vacuum exists in the system, i.e., when the motor/blower assembly is
disconnected or otherwise malfunctions.
Particulates are trapped on an 8 x 10-inch glass microfiber filter such as one of the
following, or equivalent:
1. Whatman EPM 2000
2. Schliecher & Schuell #1 HV.
2.0 MONITORING METHODOLOGY
The air samplers are mounted on towers approximately 2 meters above ground plane.
The samplers run continuously except for calibration, mechanical or electrical failure, and
maintenance down time. Target flow rate will be 36 scfin.
Air filters are replaced weekly due to particulate loadings. Maximum filter use duration
will be weekly unless weather conditions prohibit safe access to one or more of the air
monitoring station locations.
Each filter is stamped by the manufacturer with a unique number. The blank filters are
weighed to the nearest 0.0001 gram using a Sartorius Model 2432 analytical balance or
equivalent. The filters are kept in manila folders inside resealable plastic bags for support
during transportation to the site. The tare weight is then recorded on each filter folder
along with the location, filter number, start date, and start time. This information is then
input into an analytical data file on the computer. When the sampled filters are collected
in the field, the stop dates and times are entered on the folder. On return from the field,
the filters are again weighed and the gross weights are recorded on the folders. The
weights, stop dates, and stop times are then recorded into the analytical data file that is
printed off and sent to the contract laboratory.
Samples are collected continuously for approximately one week. The "loaded" filters are
removed from the shut down samplers, folded, and placed in the folders in the plastic
bags. If any part of the filter remains on the seal gasket, it is removed and added to the
folder. The new filters are removed from their folders and placed on the vacuum head
White Mesa Mill -Standard Operating Procedures
Book # 11, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 3 of 7
with the filter holder frame tightened enough to seal, but not tight enough to rupture the
filters. The samplers are then turned on.
Each station's filters are composited on a quarterly basis (13 weeks) by the environmental
staff. The samples are forwarded, along with an analytical sheet and Chain of Custody
(COC) form (provided by the contract laboratory), to the contract laboratory in sealed
plastic bags.
3.0 CALIBRATION
3.1 Orifice Plate
The orifice plates shall be calibrated every year as recommended by the EPA. A certified
calibration laboratory that will use the EPA or an EPA-approved method will do the
calibration. Calibrations will be completed in accordance with EPA-600/4-77-027a, The
Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II -
Ambient Air Specific Methods. Calibration records are kept in the environmental files.
3.2 Sampler
Calibration of the equipment occurs during the first Monday of each month. If a non-
scheduled motor replacement is necessary, the sampler is re-calibrated.
An orifice plate assembly and U-tube manometer are used for monthly calibrations.
The sampler flow rate is regulated to a standard air volume that is recorded on the field
calibration sheet using 20°C. (298 K) and 29.2 inches (760 mm) of mercury as standard
conditions. The top portion of the Monthly Calibration and Weekly Flow Check
Worksheet (Attachment C) is completed for each air sampling station and retained in the
files.
The monthly calibration task involves the following:
1. Before visiting each monitoring location, the air temperature and barometric
pressure are recorded.
2. The motors are replaced as required. The replacement motors are prepared at the
Mill office.
3. A filter is placed within the orifice plate, and the orifice plate is secured on top of
the vacuum head.
4. The orifice plate is connected to the U-tube manometer and the initial inches H20
is recorded and a flow rate calculated using the current field temperature and
pressure.
5. The control screw is adjusted as necessary to advance or slow the vacuum motor
to reach the desired flow rate. The final flow rate must be at least 32 scfm on the
analog meter and reach 75% onstream time for the quarter to meet the required
LLD for the radionuclide parameters.
White Mesa Mill -Standard Operating Procedures
Book # 11, Envirorunental Protection Manual, Section 1.1
4.0 CALCULATIONS
Date: 11/14 Revision: EFR-5
Page4 of7
Using inches of water from the U-tube, refer to the following subsections to perform the
calculation of flow rate. Section 4.1 provides the equation used to compute the flow rate
at field conditions, and (the "actual" flow rate [Qa]), in cubic meters per minute. Actual
flow rate must be corrected to standard flow rate (Qs) using the flow rate equation in
Section 4.2. The standard flow rate is then converted to standard cubic feet with the
conversion equation in Section 4.3.
4.1 Orifice Equation
Using the inches of water
measurement, determined from the U-tube, the following equation is used to calculate the
flow rate at field conditions:
Where:
Qa = Actual flow rate at field conditions (m3 /min)
m = Slope value from Qa portion of orifice calibration
~H = Manometer reading (in. H20)
Ta= Actual temperature (273 + °C = K) [from the meteorological station data
(temperature readings) that are downloaded weekly]
Pa= Actual atmospheric pressure (mmHg) [from the meteorological station data
(barometric pressure readings) that are downloaded weekly]
b = Intercept value from Qa portion of orifice calibration
The constants m and b in the above equation are provided by the calibration laboratory
for each specific calibrated orifice (Attachment D). Each orifice will have unique
performance properties that relate to design; those measured performance properties are
incorporated into the flow equation as specific constants. The flow equation
demonstrates the relationship between measured vacuum pressure in inches of water to
actual flow rate utilizing this device.
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
4.2 Standard Conditions Flow Rate Equation
Date: 11/14 Revision: EFR-5
Page 5 of 7
The flow rate at standard conditions is calculated by adjusting the field condition flow
rate, calculated above, by the following equation:
0 -Q (p{JJ(~)
-s ti ~ T;,
Where:
Os = Standard flow rate at standard conditions (m3 /min)
Q. = Actual flow rate at field conditions (m3 /min)
T. = Actual temperature (273 + °C = K)
Pa= Actual atmospheric pressure (mmHg)
Ts= Standard temperature= 298 K
Ps = Standard atmospheric pressure= 760 mmHg
4.3 Correction Equation
To convert the standard flowrate, from cubic meters per minute to standard cubic feet per
minute, use the following equation:
5.0 RECORD KEEPING
The records are kept on the filter folders and the field worksheets, which are retained in
the environmental files in the environmental office and are also entered into the analytical
data file on the computer after the data have been reviewed. The following information
will be entered into the computer data file (see Attachment E):
• Filter number
• Start date
•
•
•
•
•
•
•
•
•
Stop date
Start time
Stop time
Starting manometer reading (~H) (in. H20)
Stopping manometer reading (~H) (in. H20)
Weekly average temperature (Ta) (°C)
Weekly average pressure (Pa) (mmHg)
Tare filter weight (g)
Gross filter weight (g)
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 6 of?
The following information will be calculated by the computer file (see Attachment E):
• Total time (min)
• Average manometer reading (~H) (in. H20)
• Weekly average temperature (K)
• Actual flow rate (Qa) (m3/min)
• Standard flow rate (Qs) (m3 /min)
• Standard flow rate (Qs) (ft3/min)
• Total standard volume (m3)
• Net weight (mg)
• Loading (mg/m3)
• Percent onstream
6.0 QUALITY ASSURANCE
6.1 Installation and Removal of Filters
Field methods to assure quality of air sample collection include the following:
1. Inspection of all new filters for aberrations and discarding damaged ones.
2. Maintaining seals on equipment connections.
3. Careful installation and removal of filters, retaining all abraded filter media.
4. Proper sequential handling of all filters.
5. Filters are inspected for fingerprint contamination by visual observation.
6.2 Sample Duration
Maintenance of sample duration is assured by:
1. Installation of a vacuum-actuated timer which operates the timer only when
the motor is running and pulling the minimum allowable vacuum.
2. Weekly monitoring of stations and inspecting wear on the motors and proper
change-out at appropriate intervals (monthly).
6.3 Sample Flow Rate
Quality assurance of each sampler's flow rate is accomplished by weekly readings of the
sampler's flow characteristics using a manometer. Sampler pressure drop readings are
measured on a weekly basis using a manometer and going through the monthly
calibration steps. This value, along with average weekly temperature and pressure values
from the site meteorological station, are used to determine weekly flow rate values.
Monthly checks of flow controller operation and documentation thereof also provide
quality assurance. Samplers are calibrated and checked at motor rotation intervals
(monthly).
l
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
6.4 Calculations
Date: 11/14 Revision: EFR-5
Page 7 of 7
Calculations are checked on a random basis for inconsistencies, and such checks are
documented.
Upon retrieval of the data analytical sheet from the contract laboratory, the date of receipt
is noted, along with the date of transcription is noted on the sample station log sheet with
the transcriber's initials. The transcription of data is reviewed by another person in the
Environmental Department to minimize transposition of numerical values. Calculation
and data storage is by computer program.
6.5 Sampler Performance
A record of sampler operation time versus total possible duration time is maintained as a
flag against excessive equipment downtime. Sampler performance is reviewed monthly.
6.6 Quality Control Methodology
Blanks are weighed each week and submitted alongside the actual filters. The filters and
blanks are recorded on an analytical sheet which is sent to the vendor, and this sheet is
returned with the results.
,·"'
I ' "-•'" .-· '1 I /• l
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\~ ...... \ } ',, I -. (
'\ ' ' " f~
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**Tentative location based on DRC
correspondence dated June 12, 2014.
Final locatons will be surveyed after
installation. Installation will be performed
after DRC approval of The Environmental
Protection Manual.
/
Legend * Existing Air Monitoring Station + Tentative Air Monitoring Station**
.... •· · Canyon Rim
---Drainage
-Road
( c::::I ~roperty Boundary
c:]Tailings Cell
C]Towns hip and Range
C]section
Pond
Coordinate System: NAO
1983 StatePlane Utah
South FIPS 4303 Feet
.. \
•"' I I'...,....:,,.; ' .-,. ,, J.'. l /
I ' \ I ··~
REVISIONS Project:
Date: By: County: San Juan
Location: -
·--...· \ ' ,·r·:
' I \,j ' '
if~
WHITE MESA MILL
Stale; Utah
ATTACHMENT A
PARTICULATE MONITORING STATIONS
Author. mhenington Date: 8/22/2014 Drafted By: mhenington
ATTACHMENT C
MONTHLY CALIBRATION AND WEEKLY FLOW CHECK WORKSHEET
Site: Orifice Plate No.: ----------------------Date of Calibration: Calibrator's Name: ---------------Temperature (Ta): ____ 0_C~/ ___ K Pressure (Pa): ____ mmHg (25.4 x inches)
M tbl C lib t" i th M th f on IY a ra 10n or e on 0 :
Initial Qa lLJ Qs lJJ Qs \'tJ Adjusted Adjusted
Manometer (I) Actual Flow Standard Flow Standard Flow Manometer <5) Qs (2,3,4,5)
(~H) (in. H20) (m3/min)
W kl Fl Ch k ee ly ow ec
Week Filter Number
1
2
3
4
5
Orifice Information
Orifice SIN
Qa Slope (m)
Qa Intercept (b)
Calibration Date
Monthly Calculations:
(m3/min)
Start Start
Date Time
(ft3/min) (in. H20) (ft3/min)
Starting Stopping
Manometer Stop Stop Manometer
(in. H20) Date Time (in. H20)
Orifice Notes: Information to left found on the
latest certification worksheet delivered with a
newly certified orifice. Orifice should be
calibrated annually. Slope and intercept values
should come from Qa portion of the calibration.
1) Connect the U-tube manometer to the orifice plate then read and record the initial pressure drop.
2) Use the manometer reading to calculate the actual flow rate using the Qa equation below, which
uses actual temperature and pressure as well as specific orifice values filled out above.
3) Convert actual flow rate to standard flow rate using the Qs equation below.
4) Convert the standard flow rate from (m3/min) to (ft3/min).
5) If necessary, adjust the control screw so that the final flow rate is between 32-40 ft3 /min.
(3) Q, =Q"[;,X;,J
(4) Q)fl~n) = 35.315 X Q,("'fmin)
Where:
Qa = Actual flow rate at field conditions (m3/min)
Qs = Standard flow rate at standard conditions (m3/min)
m = Slope value from Qa portion of orifice calibration
b = Intercept value from Qa portion of orifice calibration
~H = Manometer reading (in. H20)
Ta= Actual temperature (273 + °C = K)
Pa= Actual atmospheric pressure (mmHg)
Ts= Standard temperature= 298 K
Ps = Standard atmospheric pressure= 760 mmHg
TISCH
E n v ronmental
RECALIBRATION
DUE DATE:
October 4, 2019
--------~
Cal. Date: October 4, 2018
Operator: Jim Tisch
Calibration Model #: TE-5025A
Vol. lnlt
Run (m3J
1 1
2 3
3 5
4 7
5 9
Vstd Qstd
(m3) (x-axis)
0.9917 0.7129
0.9875 1.0076
0.9855 1.1224
0.9843 1.1760
0.9790 1.4168
m=
QSTD b=
r=
Calibration Certification Information
Rootsmeter 5/N: 438320
Calibrator S/N: 5-76-02
Vol. Final AVol. ~Hime
(m3J (m3) (min)
2 1 1.3910
4 1 0.9800
6 1 0.8780
8 1 0.8370
10 1 0.6910
Data Tabulation
J 11H ( tsfa )( Tr~d )
(y-axis) Va
1.4113 0.9957
1.9959 0.9915
2.2315 0.9895
2.3405 0.9883
2.8227 0.9830
2.00723
-0.02176 QA
0.99999
Calculations
Ta: 296
Pa: 751.8
4P 4H
(mm Hg) (in H20)
3.2 2.00
6.4 4.00
7.9 5.00
8.8 5.50
12.8 8.00
Qa j 6H( Ta/Pa)
(x-axis) (y-axis)
0.7158 0.8874
1.0117 1.2549
1.1270 1.4030
1.1808 1.4715
1.4225 1.7747
m= 1.25689
b= -0.01368
r= 0.99999
OK
mm Hg
Vstd=IAVol((Pa-AP)/Pstd)(Tstd/Ta) Va=l6Vol{(Pa-AP)/Pa)
Qstd= I Vstd/ lffime Qa=IVa/.lnime
For subsequent flow rate calculations:
Qstd= 1/m(( J6H(-~;d )(-T~!d ) )-b)
Standard Conditions
Tstd:I 298.15 °K
Pstd:I 760 mm Hg
Key
AH: calibrator manometer reading (In H20J
f.P: rootsmeter manometer reading (mm Hg)
Ta: actual absolute temperature (°KJ
Pa: actual barometric pressure (mm Hg)
b: intercept
m: slope
Tisch Environmental, Inc.
145 South Miami Avenue
Village of Cleves, OH 45002
Qa= 1/m (( / aH{ Ta/Pa) )-b)
RECALIBRATION
US EPA recommends annual recalibration per 1998
40 Code of Federal Regulations Part 50 to 51,
Appendix B to Part 50, Reference Method for the
Determination of Suspended Particulate Matter in
the Atmosphere, 9.2.17, page 30
www.tisch-env.com
TOLL FREE: [phone]
FAX: [phone]
Tl CH RECALIBRATION
DUE DATE:
September 12, 2019
Calibration Certification Information
Cal. Date: September 12, 2018
Operator: Jim Tisch
Rootsmeter S/N: 438320 Ta: 297
Pa: 755.7
"K
mm Hg
Calibration Model#: TE-5025A Calibrator S/N: 8091779
Vol. lnit Vol. Final 4Vol. 4Time 4P 4H
Run (m3) (m3J (m3) (min) (mm Hg) (In H20)
1 1 2 1 1.3870 3.2 2.00
2 3 4 1 0.9800 6.4 4.00
3 5 6 1 0.8740 7.9 5.00
4 7 8 1 0.8340 8.7 5.50
5 9 10 1 0.6860 12.8 8.00
Data Tabulation
Vstd Qstd JaH( Pa X Tstd) Tsfcr ~ Qa J 6H( Ta/Pa)
{m3) {x-axis) (y-axis) Va (x-axis) (y-axis)
0.9934 0.7162 1.4125 0.9958 0.7179 0.8866
0.9892 1.0094 1.9976 0.9915 1.0118 1.2539
0.9872 1.1295 2.2334 0.9895 1.1322 1.4019
0.9861 1.1824 2.3424 0.9885 1.1852 1.4703
0.9807 1.4296 2.8251 0.9831 1.4330 1.7732
m= 1.98111 m= 1.24054
QSTD b= -0.00399 QA b= -0.00251
r= 0.99998 r= 0.99998
Calculatlons
Vstd=l/lVol((Pa-/lP)/Pstd)(Tstd/Ta} Va=l6Vol((Pa-tiP)/Pa)
Qstd=IVstd/6Time Qa=IVa/lffime
For subsequent flow rate calculations:
Qstd= 1/m(( )AH( ;:d )( T~:d 1 )-b)
Standard Conditions
Tstd:I 298.15 "K
Pstd:I 760 mm Hg
Key
llH: calibrator manometer reading (in H20)
/lP: rootsmeter manometer reading (mm Hg)
Ta: actual absolute temperature ("K)
Pa: actual barometric pressure (mm Hg)
b: intercept
m: slope
Tisch Environmental, Inc.
145 South Miami Avenue
Village of Cleves, OH 45002
Qa= 1/m ((J 6H{ Ta/Pa) )-b)
RECALIBRATION
US EPA recommends annual recalibration per 1998
40 Code of Federal Regulations Part 50 to 51,
Appendix B to Part 50, Reference Method for the
Determination of Suspended Particulate Matter in
the Atmosphere, 9.2.17, page 30
www.tisch-env.com
TOLL FREE: [phone]
FAX: {513)467-9009
Energey Fuels Resources -White Mesa Mill Calibration Date: ########
Period: July I, 2014-September 30, 2014 Calibration Slope & Intercept: m= 1.25049 b= -0.0081
Orifice SIN: 8091779
t.H au
Week Filter Slart Stop Slart Stop Slarling Stopping
# Nwnba Date Date Time Time Ma,10men:r Maooroetcr
(in. H20) (in. H10)
I 713050S 7n/2014 7/14/2014 7278.3 17366.2 10087.9 4.0 4.0
2 7123199 17366.2 27408.8 10042.6 3.S 3.6 3.6 20.0 293.2 621.03 1.04 0.87 30.56 8689.7 4.S221 4.5319 9.8 0.0011 99.6
3 7129193 27408.8 37640.7 10231.9 4.0 3.5 3.8 20.0 293.2 621.03 1.07 0.89 31.40 9098.0 4.5172 4.5218 4.6 0.0005 101.S
4 7129187 37640.7 47869.5 10228.8 3.0 3.9 3.5 20.0 293.2 621.03 1.03 0.85 30.13 8726.1 4.5303 4.5360 5.7 0.0007 101.S
5 47869.5 57734 9864.5 3.5 4.0 3.8 20.0 293.2 621.03 1.07 0.89 31.40 8771.3 4.5295 4.5380 8.5 0.0010 97.9 ;..
6 57734 67754.2 100202 4.0 3.8 3.9 20.0 293.2 621.03 1.09 0.91 32.02 9085.1 4.5402 4.5464 6.2 0.0007 99.4 ~
7 67754.2 77803.4 10049.2 3.6 3.9 3.8 20.0 293.2 621.03 1.07 0.89 31.40 8935.S 4.5359 4.5435 7.6 0.0009 99.1 ;.. n
8 77803.4 83387.6 5584.2 3.7 3.6 3.7 20.0 293.2 621.03 1.06 0.88 30.98 4899.1 4.5536 4.5610 7.4 0.0015 55.4 ~
9 83387.6 93412.4 10024.8 3.8 4.0 3.9 20.0 293.2 621.03 1.09 0.9 1 32.02 9089.3 4.5542 4.5605 6.3 0.0007 99.5 :: t2,
10 93412.4 103434.8 10022.4 4.0 4.0 4.0 20.0 293.2 621.03 I.II 0.92 32.42 9202.2 4.5613 4.6928 131.5 0.0143 99.4 2
II 103434.8 113555.1 10120.3 3.S 3.6 3.6 20.0 293.2 621.03 1.04 0.87 30.56 8757.0 4.5489 4.5543 5.4 0.0006 100.4 ~
t."l
12 17921.6 2794S.8 100242 3.6 3.8 3.7 20.0 293.2 621.03 1.06 0.88 31.19 8854.0 4.5355 4.5454 9.9 O.OO!l 99.4
13 27945.6 38066.3 10120.7 3.7 4.0 3.9 20.0 293.2 621.03 1.08 0.90 31.81 91 17.6 4.5355 4.5454 9.9 0.0011 100.4 .. Totals . .. . ·--·· . 13.92 11.56 408.38 112503.2 58.908 59.168 259.1 0.0291 126421.7 I
Averages 9724.7 3.7 3.8 3.8 19.9 293.l 621.03 1.07 0.89 31.41 8654.1 4.531 4.551 19.9 0.002-2 I 96.5
Comments:
Jnscn Wtt.kly flow check values in yeUow colwnns.
, ..... .'' ... ·.··-:~,::.~-r~~i--Jla ;Jl'~ ...... ,,?'l"'~.;.411.Jt .. , .,~ ...... .:.,·-t,.~t~--=-.!--·~t"".:.--•·~ .. _.,---·---~...:_,,-<--~ ·-~0#0 ?.;.... ___ ..__--,,,.:,~~~...:.~ .. .:.;:·.-=:.
White Mesa Mill -Standard Operating Procedures
Book # 11, Environmental Protection Manual, Section 1.2
Date: 12/18 Revision: EFR-5
Page 1 of 4
1.
AIR MONITORING --RADON
RADON MONITORING PLAN
Radon monitoring at the Mill is conducted as follows:
• Environmental radon samples are collected using outdoor detectors at the
locations specified in Attachment A to Section 1.1 of this Environmental
Protection Manual. The samples are collected as described below in Section 2.
• Radon Flux sampling is conducted on the Tailings Management System Cells 2
and 3 as described below in Section 3.
2.
2.1
ENVIRONMENTAL RADON SAMPLING
Locations and Frequency of Samples
Environmental Radon samples are taken at the following locations:
BHV-1
BHV-2
BHV-2A (Duplicate of BHV-2)
BHV-3 (Background location for use in assessment of background concentrations)
BHV-4
BHV-5
BHV-6
BHV-7
BHV-8
BHV-70 (Transit Control sample(s) for use in assessment of effects due to sample
shipment. Previously numbered as BHV-7)
See Attachment A to Section 1.1 of this Environmental Protection Manual for the
locations of these monitoring stations.
Samples are collected on a quarterly basis using Radonova Rapidos® High Sensitivity
Outdoor Environmental detector, or equivalent. One or more than one Outdoor Air
Radon Detector will be placed at each of the locations noted above ( except BHV -70). If
more than one Rapides® High Sensitivity Outdoor Environmental detector is placed at a
location, one of the Rapidos® High Sensitivity Outdoor Environmental detectors will be
designated as the primary detector. The number of detectors to be placed at each location
shall be as determined by the Radiation Safety Officer ("RSO"). If multiple Rapidos®
High Sensitivity Outdoor Environmental detector are placed at one location, either the
results from the primary detector or the numeric average of the results for that location
will be calculated and reported as the radon value for the quarter.
White Mesa Mill -Standard Operating Procedures Date: 12/18 Revision: EFR-5
Page 2 of 4 Book #11, Environmental Protection Manual, Section 1.2
Rapidos® High Sensitivity Outdoor Environmental detector results will be reported in
the Semi-Annual Effluent Report.
2.2 Quality Assurance
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in Section 2 of this procedure. In addition, the
following steps will be followed:
2.3
a) One duplicate sample or set of duplicate samples will be collected each
quarter by placing samples at the same location as the routine sample(s), at the
same height as the routine sample(s), and as close to the routine sample(s) as
reasonably achievable;
b) A transit control sample will be analyzed each quarter to assess any
concentrations resulting from shipment of the detectors;
c) Detector locations will be monitored periodically to ensure the detectors have
not been lost;
d) Detector shipments will be inspected to ensure that all detectors are present
when receiving or shipping detectors; and
e) Monitoring data will be reviewed for consistency and data transportation
issues/detections.
Analytical Requirements
Each quarterly sample will be analyzed for Radon-222. Results will be expressed in
pCi/L.
2.4 Standard Operating Procedures
2.4.1 Equipment
Samples will be collected using the Rapidos® High Sensitivity Outdoor Environmental
detector or equivalent. The Rapides® High Sensitivity Outdoor Environmental detector
will be returned to the supplier/manufacturer for processing and analysis. Detectors are
analyzed using a"high sensitivity" methodology, which provides a lower limit of
detection. The lower limit of of detection is based on the number of days the detector is
deployed.
2.4.2 Monitoring Methodology
The following monitoring procedures will be followed:
White Mesa Mill -Standard Operating Procedures Date: 12/18 Revision: EFR-5
Page 3 of 4 Book #11, Environmental Protection Manual, Section 1.2
3.
a) Remove detector from package -The Outdoor Air Radon Detector are
supplied in aluminum bags which prevent radon exposure. Open the aluminum
bag and remove the Rapidos® High Sensitivity Outdoor Environmental detector.
Assemble the mounting assembly for the Rapidos® High Sensitivity Outdoor
Environmental detectors as specified in the manufacturer's instructions. Note that
the Rapidos® High Sensitivity Outdoor Environmental detectors, before, during
or after exposure should not be in locations which exceed a temperature of 160°F
(70°C). There is no low temperature.
b) Fill in the enclosed Detector and Commission Information Sheet with the
serial number on the Rapidos® High Sensitivity Outdoor Environmental detector
label. Also fill in the date installed and the location information in the
location/comments area.
c) Attach the protective canister assembly to a post or other location using the
metal bracket with the open mouth of the canister facing down. The protective
canister assembly may be placed at any desired height (typically 3-6 feet) and
preferably in a location minimizing animal damage or tampering. Install the
Rapidos® High Sensitivity Outdoor Environmental detector inside the protective
canister and replace the wing nuts in order to hold the Rapidos® High Sensitivity
Outdoor Environmental detector in place in the protective canister.
d) Leave the detectors undisturbed for the duration of the three-month
monitoring period.
e) At the end of the monitoring period, remove the Rapidos® High Sensitivity
Outdoor Environmental detector from the protective canister. Peel off the gold
seal provided with the shipment and cover all the holes on the top of the detector.
This stops the monitoring period. Record the ending date on the Detector and
Commission Information Sheet.
f) After all of the detectors have been collected and sealed, but prior to final
packaging and shipment, place the transit control detector(s) in the shipping
container.
This detector will be reported as as BHV-70.
g) Return the detectors along with a copy of the Detector and Commission
Information Sheet.
RADON FLUX SAMPLING
Radon flux monitoring for Cells 2 and 3 is conducted in accordance with 40 CFR, Part
61, Appendix B, Method 115.
The frequency of monitoring for Cell 3 is determined annually. The frequency will be
specified at the time of the first monitoring event. The frequency will be in accordance
with EPA requirements.
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.2
Date: 12/18 Revision: EFR-5
Page 4 of 4
Cell 2 is monitored in accordance with the Division of Waste Management and Radiation
Control ("DWMRC") (formerly the Division of Radiation Control) letter dated July 23,
2014.
4. RECORD KEEPING
Data maintained in record form for radon monitoring are:
a) Sample period;
b) Sample location(s); and
c) Analytical/monitoring data.
White Mesa Mill -Standard Operating Procedures
Book # 11: Environmental Protection Manual, Section 1.3
Date: 08/14 Revision: EFR-4
Page 1 of2
METEOROLOGICAL DATA MONITORING PLAN
AND STANDARD OPERATING PROCEDURES
1.
1.1
MONITORING METHODOLOGY
Monitoring Equipment
The collection of meteorological data is accomplished on a daily basis through the use of a
Campbell Scientific Data Logger Model #SM 192, or equivalent. The meteorological station
retrieves the data continuously and the information is downloaded into the aforementioned data
logger.
1.2 Weekly Function Check
On a weekly basis, a function check of the system is performed. The function check includes
checking of the data logging process, amount of data points being stored, wind direction, wind
speed, barometric pressure, temperature, and battery voltage. This information is tabulated on
the form "A" attached.
1.3 Weekly Downloading of Data
See form "B" for specifications on the downloading.and data retrieval.
Data that is collected is:
1.4
1 -Battery Charge
2-Wind Vane
3 -Wind Speed
4-Data Module Bytes stored (starting and ending times)
5 -Temperature
6 -Barometric Pressure
Monthly Exchange of Data Module
On the first Monday of each month, after the downloading and data retrieval, exchange the data
module with another data module and send the older module in for downloading and data
verification by the independent meteorological contractor.
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.3
Date: 08/14 Revision: EFR-4
Page2 of2
After the contractor has downloaded all data and verification of the data has been established, the
contractor will then return the data module for exchanging the next month.
1.5 Record Keeping
All paperwork generated through the downloading and verification process will be maintained
in the Environmental Department.
FORMA
WEEKLY METEOROLOGICAL STATION CHECK-WHITE MESA MILL
HARDWARE
SOLAR PANEL:
COMMENTS
-----------------
BATTERY CHARGE: ---------------
ST AT ION CONDITION: --------------
SENSORS
WIND VANE: ------------------
WINDS PEED: ------------------
TEMPE RA TURE: -----------------
BAROMETRIC PRESSURE: --------------
TOWER CABLES: -----------------
DAT A MODULE: -----------------
DATA RETRIEVAL
DATE: ------
STORAGE LOCATION: ------
STORAGE LOCATION START: ---
STORAGE LOCATION END: ----
DATA TRANSFER OK (TECH INITIALS) -----
TIME OF DAY (MST): ____ _
ATTACHMENT B
White Mesa Mill
CR510 Data Logger User Information
Instructions on Setting the Time and Date On The CR510: *5
*5 Unit displays time (HH:MM:SS)
05:xx Unit displays year, change if needed
05:xxxx Unit displays day of year, change if needed
05:HH:MM: Unit displays hours/minutes in MST, change if needed
View Current (Instantaneous) Values from the CR510: *6
01: Wind Direction (degrees from true north)
02: Wind Speed (m/s)
03: Ambient Temperature (DC)
04: Ambient Temperature (DF)
05: Barometric Pressure (mb)
06: Barometric Pressure (in of Hg)
07: Battery Voltage (volts DC)
Final Data Storage Locations on the CR510: *7
(order seen when downloaded on computer)
Hourly Averages
01 : Site ID# 297
02: Year
03: Day of Year
04: Time [Mountain Standard Time (MST)]
05: Wind Speed (m/s)
06: Wind Direction hourly average (degrees from true north)
07: Sigma Theta [standard deviation of WO] (degrees)
08: Ambient Temperature (DC)
09: Ambient Temperature (DF)
10: Barometric Pressure ( mb)
11: Barometric Pressure (in of Hg)
12: Battery Voltage instantaneous reading (volts DC)
13: Wind Direction instantaneous reading (degrees from true north)
How to Load Programs to and From the Storage Module
*D 71A 18A Stores data logger program into storage module
program area #8
*D 71A 28A Loads program from storage module program area
#8 into data logger
ALPHA KEYS:
A: advance or enter B: back up C: change sign D: decimal
NOTE: Keys may have multiple uses (see Operator's Manual)
----------------------------------------·
Project 2397-10 August 27, 2014
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 12/16 Revision: EFR-5
Page 1 of 6
STACK EMISSION MONITORING PROCEDURES
WHITE MESA GAS STACK EMISSIONS
1.0 INTRODUCTION
White Mesa, or it's contracted service providers, uses scientifically approved
reference methods to determine gas stack emissions release concentration for
radionuclide particulates. These methods conform to principles that apply to
obtaining valid samples of airborne radioactive materials, using prescribed
acceptable methods and materials for gas and particulate sampling. See American
Standard.Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities
ANSI Nl3.1-1969. These sampling methods are also consistent with guidance
contained in the U.S. Nuclear Regulatory Commission's Regulatory Guide 4.14,
"Radiological Effluent and Environmental Monitoring at Uranium Mills."
2.0 SAMPLING METHODOLOGIES
The sampling methods for airborne radionuclide particulates, from the yellowcake
dryer and other mill effluent control stacks, are identical to methods published in
the EPA's manual, Gas Stream Sampling Reference Methods for New Source
Performance Standard ; they are found in the EPA Manual in Appendix No. 5,
"Determination of Particulate Emissions from Stationary Sources" ("EPA Method
#5") and Appendix No. 17, "Determination of Particulate Emissions from
Stationary Sources (In-Stack Filtration Method)" ("EPA Method #17). Sampling
is performed as per the methods, to ensure that the sampling and results are: (1)
isokinetic; (2) representative; and (3) adequate for determination of the release
rates and concentrations of U-Nat, Th-230, Ra-226 and Pb-210.
2.1 Sampling Equipment
Sampling equipment used to collect airborne radionuclide particulates from point
source emission stacks at the Mill consists of equipment manufactured by
Research Appliance Company (RAC), (or other equivalent apparatuses), as
follows:
1. RAC Model 201009 Model 2414 stack sampler.
2. Two each, RAC Model 201044 modular sample cases. One heater box and
one glassware box.
3. One each, RAC Model 201019 umbilical cord.
4. Three each, RAC Model 201013 -110 mm diameter filter holders.
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 12/16 Revision: EFR-5
Page 2 of6
5. One each, RAC Model 201005 standard pilot tube, three feet length,
stainless steel/S-type probe.
6. Barometer.
7. Stainless steel probe with S pi tot tube.
8. Satorius Model 2432 balance or equivalent.
9. Triple beam balance.
Equipment instruction and operating manual(s) provided by the manufacturer(s)
are retained at the Mill and used for specific guidance and reference.
2.2 Sample Collection
Gas stack samples are collected from emission control systems used in Recovery
Operations at the Mill. These samples are collected from process stacks when the
emission control systems are operating. They are sampled for radionuclide
particulate concentrations at a frequency in accordance with Table 5-1. Sample
collection methods are described in detail in EPA Method #5 and EPA Method
#17, Determination of Particulate Matter Emissions From Stationary Sources. It
is necessary to read and understand all procedures described in the methods and in
the equipment manual. The operation of the equipment requires "hands-on"
instruction from the Environment Departmental Staff from individuals who are
experienced in using sample collection equipment and applying sample collection
methods. The following steps are described for stack sample collection.
1. Check equipment listed in Section 2.1 of this SOP. Consult the
manufacturers equipment operations manual for details.
2. Assemble equipment as described in the operations manual for sample
collection EPA Method #17.
3. Follow the calibration procedure listed in the manual. If the
calibration measurements are not obtained, consult the trouble
shooting section of the manual for corrective instruction. Once the
collection apparatus is calibrated, proceed to the next step.
4. Weigh a new glass fiber filter, record the weight, and place in the
filter holder assembly.
5. Check the sample collection system for leaks.
6. Cap ends of sample probes to prevent contamination and transport
sample unit to the sample location.
7. Uncap sample end and insert 3/8-diameter sample probe into the stack
at the location determined by EPA Method #1.
8. Turn sample apparatus on and observe unit operation to ensure a
sample is being collected and the apparatus is functioning properly.
9. Collect the stack sample for at least one hour during periods of routine
process operation. Note the collection time.
l '-.
White Mesa Mill-Standard Operating Procedures
Book #11: EnvironII\ental Protection Manual, Section 1.4
Date: 12/16 Revision: EFR-5
Page 3 of6
10. Record the information described in the manufacture's operations
manual. This information is also described in the EPA Methods #5
and #17 for point source particulate emissions.
11. After sample collection is complete, turn off unit. Obtain sample
filter from filter housing and place in a new plastic petri dish. Send to
outside laboratory for radionuclide analysis in accordance with Table
5-1.
2.3 Sample Handling and Shipping
1. During preparation and assembly on the sampling train, keep all
openings where contamination can occur covered until just prior to
assembly or until sampling is about to begin. Check all connection
points to ensure 0-rings are in place where required.
2. Using a tweezer or clean disposable surgical gloves, place a labeled
(identified) and weighed filter in the filter holder. Be sure that the
filter is properly centered and the gasket properly placed so as to
prevent the sample gas stream from circumventing the filter. Check
the filter for tears after assembly is completed.
3. Before moving the sampling train to the cleanup site, remove the
probe from the sample train and cap the open outlet of the probe. Be
careful not to lose any condensate that might be present. Cap the filter
inlet where the probe was fastened. Remove the umbilical cord from
the last impinger, and cap the impinger. If a flexible line is used
between the first impinger or condenser and the filter· holder,
disconnect the line at the filter holder, and let any condensed water or
liquid drain into the impingers or condenser. Cap off the filter holder
outlet and impinger inlet. Either ground-glass stoppers, plastic caps,
serum caps, or aluminum foil may be used to close these openings.
4. Transfer the probe and filter-impinger assembly to the cleanup area.
This area should be clean and protected from the wind so that the
chances of contaminating or losing the sample will be minimized.
5. Save a portion of the acetone used for cleanup as a blank. Take 200
ml of this acetone directly from the wash bottle being used, and place
it in a glass sample container labeled "acetone blank."
6. Carefully remove the filter from the filter holder, and place it in its
identified petri dish container. Use a pair of tweezers and/or clean
disposable surgical gloves to handle the filter. If it is necessary to fold
the filter, do so such that the PM cake is inside the fold. Using a dry
Nylon bristle brush and/or a sharp-edged blade, carefully transfer to
the petri dish and PM and/or filter fibers that adhere to the filter
holder gasket. Seal the container.
7. Send to the laboratory for radionuclide analysis.
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
3.0 RECORD KEEPING
Date: 12/16 Revision: EFR-5
Page 4 of 6
Records of gas stack effluent sampling events and results of analysis are retained
at the Mill. The following information is recorded:
1. Stack and Run ID
2. Date and Sampler
3. Sampled Air Volume at standard conditions
4. Sampled Water Volume at standard conditions
5. Moisture Content (volume basis)
6. Stack Gas Molecular Weight (wet basis)
7. Stack Gas Velocity
8. Stack Gas Volumetric Flow Rate ( dry basis, at standard conditions)
9. Particulate Concentration
10. Percent Isokinetics
11. Emission Rates for Particulates U-Nat, Th-230, Ra-226, and Pb-210.
The data are used to calculate emission rates in pounds and pico curies per hour
for radionuclide particulate concentrations.
4.0 MONITORING LOCATION AND FREQUENCY
Stack sampling must be performed during any quarter or semi-annual period that
the stacks operate in accordance with the schedule in Table 5-1. During non-
operational periods, stack sampling is not performed.
4.1 Yellowcake Stacks
The exhaust stack for the drying and packaging equipment associated with the
yellowcake calciner is sampled on a quarterly basis during operations. The
sample ports are located on the roof of the main Mill building.
4.2 Feed Stacks
The grizzly feed stack is located on the north end of the grizzly structure. This
stack is accessible from a stack platform and is sampled quarterly if this system is
operating.
4.3 Vanadium Stacks
The exhaust stack for the drying and packaging equipment associated with the
vanadium circuit is sampled on a quarterly basis during operations. The sample
ports are located on the roof of the vanadium annex portion of the building.
(
White Mesa Mill -Standard Operating Procedures Date: 12/16 Revision: EFR-5
Page 5 of6 Book #11: Environmental Protection Manual, Section 1.4
5.0 ANALYSIS REQUIREMENTS
All gas stack samples are collected at the Mill according to the calendar year
schedule shown below in Table 5-1. The samples will be sent to an off-site
laboratory for the analysis detailed below.
TABLES-1
Sampling Frequency and Analysis
Grizzly North and/or Yellowcake Vanadium South Packaging Vanadium Frequency Baghouse Yellowcake Baghouse Dryer Stack Packaging
Stack Dryer Stacks Stack Stack
Quarterly If operating, If operating, If operating, U-If operating, U-If operating, U-
U-nat, Th-230, U-nat, Th-230, nat, Th-230, nat, Th-230, nat, Th-230,
Ra-226, Pb-Ra-226, Pb-Ra-226, Pb-Ra-226, Pb-Ra-226, Pb-
210, Th-232, 210, Th-232, 210, Th-232, 210, Th-232, 210, Th-232,
Ra-228, and Ra-228, and Ra-228, and Ra-228, and Ra-228, and
Th-228. Th-228. Th-228. Th-228. Th-228.
Note: Grizzly baghouse stack and Vanadium Circuit stack samples shall be representative
and adequate (based on EFRI's operational knowledge and operational conditions at the
time of the sampling event) for the determination of the release rates and concentrations
of radionuclides listed in Table 5-1 above, and do not need to be collected in an isokinetic
state.
6.0 QUALITY ASSURANCE METHODOLOGY
6.1 Equipment Operation
Prior to performing an emission point sampling run, the sampling equipment is
subjected to a dry run test to determine leakages or equipment malfunction.
Calibration of equipment is checked on a periodic basis. Probe tips are protected
by a protective cap while not in use to protect accuracy determinations. During
transport of equipment, all openings are sealed to prevent contamination.
Calculations utilized during runs to maintain isokinetic conditions are reviewed
and dry run tested prior to the actual run. All containers and probes are washed
prior to each usage.
Malfunction of sampling equipment, excessive malfunctions of normal operations
being monitored, or percent isokinetic sampling rates greater than ± 10% error,
indicate mandatory voiding of the run or data involved.
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
6.2 Operations
Date: 12/16 Revision: EFR-5
Page 6 of6
If samples are collected from the operation of any unit which appears, in the
judgment of the sampler, to be functioning in a manner not consistent with normal
operations, then the sample will be voided and the system will be resampled.
6.3 Chemical Sample Control
Analyses on each period's sample shall include blanks for the filters, impinger
solutions, and the rinse solutions. A field logbook shall be maintained listing data
generated, determinations of volumes measured, and net gain weights of filters to
provide a back up to summary data records. Filters are transmitted within plastic
enclosed petri dishes. Handling of filters is only done using tweezers.
6.4 Calculations
All calculations will be retained at the Mill in both a hard copy and computer
files.
The gas stack effluent concentrations (C) are calculated as follows:
Lab Result µCi (A)/ Volume Sampled (V) = Effluent Concentration (C)
where
Volume Sampled (V) = Flow rate (Q) * Time of sample collection in minutes (t)
and
Lab Result µCi (A) = Radioisotopic activity, in µCi on air filter
White Mesa Mill -Standard Operating Procedures Date: 04/14 Revision: EFR-3
Pagel of5 Book #11: Environmental Protection Manual, Section 2.1
SURFACE WATER MONITORING PLAN
AND STANDARD OPERATING PROCEDURES
PART I SURFACE WATER MONITORING PLAN
1.0 MONITORING METHODOLOGY
1.1 Flow Measurement
No flow measurements are taken at the two drainage creeks sample locations: Westwater
Canyon and Cottonwood Creek.
1.2 Water Quality
Westwater Canyon and Cottonwood Creek are monitored at two locations west of and
adjacent to the White Mesa Mill facility (See Figure 1 ). Samples are obtained annually
from Westwater and quarterly from Cottonwood using grab sampling and analyzed in
accordance with Table 1.
2.0 QUALITY ASSURANCE
Quality assurance for surface water monitoring includes an annual review of procedures
used to measure field parameters; review of procedures for sample preservation;
precautions applied to use of sample containers and equipment; and semi-annual
submittal of one site split sample for analysis as a blind duplicate.
PART II SURFACE WATER STANDARD OPERATING PROCEDURES
1.0 EQUIPMENT
2.0
Equipment used for monitoring surface water quality includes:
1. Hydrolab Surveyor 4 meter and probe, or equivalent;
2. 2 one gallon sample containers
SAMPLING PROCEDURE
Two one gallon samples using clean unused sample containers that are provided by the
analytical laboratory, are obtained. Specific conductivity, tern erature and H data are
White Mesa Mill-Standard Operating Procedures Date: 04/14 Revision: EFR-3
Book #11: Environmental Protection Manual, Section 2.1 Page 2 of 5
obtained in the field as an in-stream measurement, and recorded on the field water
analysis data form (Attachment A). One of the samples is sent off to the laboratory and
the other remains on site in the environmental sample refrigerator as a backup sample for
the analytical laboratory. Suspended samples are not filtered.
Samples are submitted to the analytical laboratory on a quarterly basis. See Table 1 for
analytical data to be requested on the surface samples.
2.1 Sample Labeling
Sample containers are labeled with:
1. Project/facility
2. Date and time of sample
3. Filtered or unfiltered
4. Preservation method
5. Sampler's initials
6. Sample location
3.0 CALIBRATION
Equipment used to measure field parameters will be calibrated in accordance with SOP
PBL-EP-12.
4.0 RECORD KEEPING
Radiological and chemical quality data is maintained in the Mill files m the
Environmental Office. Records will include field and laboratory data as follows:
1. Sample location
2. Sample date
3. Field pH
4. Field temperature
5. Field conductivity
6. Total Suspended Solids Concentration
7. Total Suspended Radionuclide Concentrations
8. Dissolved Radionuclide Concentrations for U-nat, Th-230, Ra-226
5.0 MONITORING LOCATIONS AND FREQUENCY
As shown on Table 1, surface water samples are collected from two locations west of the
Mill property:
1. Lower Cottonwood Creek;
2. Lower Westwater Creek.
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 2.1
Date: 04/14 Revision: EFR-3
Page3of5
Samples are obtained four times a year on Cottonwood Creek with the semi-annual list of
parameters analyzed twice, and the quarterly list analyzed twice per year. Westwater is
sampled once on an annual basis and analyzed for the list of semi-annual parameters
shown on Table 1.
6.0 ANALYSIS PROCEDURE
The contract laboratory analytical procedures are in accordance with their respective
established quality assurance and quality control programs.
Field sampling procedures are discussed in Section 2.0. Measurement of field parameters
is performed using instruments which have been calibrated in accordance with SOP PBL-
EP-12.
7.0 QUALITY ASSURANCE METHODOLOGY
7 .1 Field Quality
Review of pH, temperature, and conductivity procedures performed in accordance with
SOP PRL-EP-12 is done each year. Review of procedures involved with sample
preservation is checked each sampling period. Sample collection bottles are not re-used
and sample contents are maintained in a cooler.
7 .2 Water Quality
Blind duplicates will be assessed in accordance with the most recently approved Mill
Groundwater QAP.
Data is reviewed and graphed on a semiannual basis to observe abnormalities.
White Mesa Mill -Standard Operating Procedures
Book# 11: Environmental Protection Manual, Section 2.1
Table 1
Date: 04/14 Revision: EFR-3
Page 4 of5
Operational Phase Surface Water Monitoring Program
Monitoring Sites
Westwater and Cottonwood Creeks
Field Requirements
1. Temperature °C
2. Specific Conductivity, µmhos at 25 °C
3. pH at 25 °C
4. Sample date
5. Sample ID
Vendor Laboratory Requirements
Semiannual*
One gallon Unfiltered and raw
One gallon Unfiltered and raw
Total dissolved solids
Total suspended solids
Gross Alpha
Suspended U-nat
Dissolved U-nat
Suspended Ra-226
Dissolved Ra-226
Suspended Th-230
Dissolved Th-230
Quarterly
One gallon Unfiltered and raw
One gallon Unfiltered and raw
Total dissolved solids
Total suspended solids
*Semiannual sample must be taken a minimum of four months apart.
**Annual Westwater Creek sample is analyzed for semi-annual parameters.
Radionuclides and LLDs reported in Ci/ml
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 2.1
Date: 04/14 Revision: EFR-3
Page 5 of5
Attachment A
FIELD WATER ANALYSIS SURFACE WATER
WHITE MESA MILL
LOCATION (Circle one):Cottonwood Creek Westwater Canyon Other (describe) ____ _
DATE: _________ _ BY: ------------(Sampler's initials)
pH BUFFER 7.0 _____ _ pH BUFFER 4.0 _____ _
SPECIFIC CONDUCTIVITY --------~µ_M_H_O_s
STEAM DEPTH:
pH ofWATER ___________ _ TEMP --------
COND µmhos COND µmhos
pH Units pH units
Temp°C Temp°C
COND µmhos COND µmhos
pH units pH units
Temp °C Temp°C
Comments:
t;te' 1 1
v .
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
FILE COPY
July 21, 2020
David Frydenlund
Chief Financial Officer, General Counsel and Corporate Secretary
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Energy Fuels Resources, June 25, 2020, Receipt and Processing of Ores from Chemours at the
Energy Fuels Resources (USA) Inc. (EFRI) White Mesa Mill, Utah Division of Waste
Management and Radiation Control Request for Additional Information (RAI)
Utah Radioactive Materials License No. UT 1900479 (License)
Utah Groundwater Discharge Permit No. UGW370004 (Groundwater Permit)
Dear Mr. Frydenlund:
The Utah Division of Waste Management and Radiation Control (DWMRC) has reviewed the following
Energy Fuels Resources (USA) Inc. (EFRI) document:
EFRI, June 25, 2020, Receipt and Processing of Ores from Chemours at the Energy Fuels
Resources (USA) Inc. (EFRI) White Mesa Mill.
The EFRI letter is regarding potential receipt and processing of Chemours material, which is separated
monazite mineral sand, at the White Mesa Uranium Mill (Mill). The material would be received from
the Chemours' Offerman Mineral Separation Plant located in Pierce County, GA. It was noted that the
Chemours Material will initially comprise material from the Mission Mine but may include material
from the Amelia Mine and other mine sources in the future.
Based on the DWMRC review, additional information is needed to supplement the original EFRI
submittal to evaluate whether the processing of this material will require modifications to the Mill's
License and/or Groundwater Permit.
(Over)
DRC-2020-012682 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.iitali.gort
Printed on 100% recycled paper
(
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
Revision 2.5
March 2017
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 2 of 37
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
TABLE OF CONTENTS
1. IN"TRODUCTION ................................................................................................................... 3
1.1. Background ....................................................................................................................... 3
2. DAil, Y TAI1,INGS IN"SPECTIONS ........................................................................................ 4
2.1. Daily Comprehensive Tailings Inspection ...................................................................... ..4
2.2. Daily Operations Inspection .............................................................................................. 7
2.3. Daily Operations Patrol ..................................................................................................... 7
2.4. Training .............................................................................. : .............................................. 7
2.5. Tailings Emergencies ........................................................................................................ 7
3. WEEKLY TAI1,INGS AND DMT IN"SPECTION .................................................................. 8
3.1. Weekly Tailings Inspections ............................................................................................. 8
4. MONTHLY TAI1,INGS INSPECTION ................................................................................ 11
5. QUARTERLY TAI1,INGS INSPECTION ............................................................................ 12
6. ANNUAL EV ALUATIONS .................................................................................................. 13
6.1. Annual Technical Evaluation .......................................................................................... 13
6.2. Movement Monitors ........................................................................................................ 14
6.3. Free board Limits ............................................................................................................. 15
6. 3 .1. Cell 1 ........................................................................................................................ 15
6.3.2. Cell 2 ........................................................................................................................ 15
6.3 .3. Cell 3 ........................................................................................................................ 16
6.3.4. Cell 4A ..................................................................................................................... 16
6.3.5. Cell 4B ..................................................................................................................... 16
7. OTHER IN"SPECTIONS ........................................................................................................ 19
8. REPORTIN"G REQUIREMENTS ......................................................................................... 19
8.1. Monthly Tailings Reports ............................................................................................... 19
8.2. Weekly Cell I and Cell 4B Photographs ......................................................................... 19
Appendix A
AppendixB
Appendix C
AppendixD
APPENDICES
Forms
Tailings Inspector Training
Certification Form
Example Freeboard Calculations for Cell 4B
( White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. INTRODUCTION
03/17 Revision: EFR 2.5
Page 3 of37
This Tailings Management System procedure for the White Mesa Mill (the "Mill") provides
procedures for monitoring the tailings cell systems as required under State of Utah Radioactive
Materials License No. UT1900479 (the "RML"). The procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, LE and I.F of the
Mill's Groundwater Discharge Permit ("GWDP") Number 370004, are presented in the DMT
Monitoring Plan ("DMT Plan"), which is a separate Plan.
This Tailings Management System procedure and the DMT Plan when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, and inspection of the feedstock storage areas at the Mill.
This Tailings Management System is published and maintained in the Mill's Environmental
Protection Manual while the DMT Plan is issued as a stand-alone document.
1.1. Background
This Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that Energy Fuels Resources (USA) Inc. ("EFRI")
develop the initial DMT Plan in response to GWDP requirements. In developing the initial DMT
Plan, EFRI combined the existing Tailings Management System procedure set out as Chapter 3.1 of
the Mill's Environmental Protection Manual with a number of new DMT requirements from the
GWDP to form the initial DMT Plan. The initial DMT Plan and subsequent revisions (through
revision 11.5) maintained the requirements from the RML (i.e., Chapter 3.1 of the Mill's
Environmental Protection Manual) and the DMT requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. The DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the DMT Plan that flow from the RML and
not from the GWDP have been separated from the DMT Plan and have been returned to their
original status as this Tailings Management System procedure, which comprises Chapter 3.1 of the
Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected and
enforced under the requirements of the GWDP and this Tailings Management System procedure to
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 4 of 37
be managed, inspected and enforced under the requirements of the RML.
In addition, EFRI has incorporated in this plan the requirements for operating mill tailings specified
by the Environmental Protection Agency ("EPA") in 40 CFR Part 61, Revisions to National
Emissions Standards for Radon Emissions From Operating Mill Tailings.
This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") have been
included in this DMT Plan. The inclusion of this RML requirement is to address the DRC request
for uniformity in monitoring and reporting requirements for Cells 1, 2, and 3 and to address
anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Compreheo ive Tai.lings In pection
On a daily basis, including weekends, all areas connected with the evaporation cells (Cell 1 and Cell
4B) and the tailings cells (Cells 2, 3, 4A,) will be inspected. Observations will be made of the
current condition of each cell, noting any corrective action that needs to be taken.
The Radiation Safety Officer ("RSO") or his designee is responsible for performing the daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform the daily tailings inspection.
Observations made as required by this Tailings Management System by the inspector will be
recorded on the Daily Inspection Data form (a copy of which is included in Appendix A to this
Tailings Management System procedure). The daily leak detection check for Cells 1, 2, and 3 will be
recorded on the Daily Inspection Data form included as Attachment A-1 of the DMT Plan. The
Daily Inspection Data form included with this Tailings Management System procedure contains an
inspection checklist, which includes a tailings cells map, and spaces to record observations,
especially those of immediate concern and those requiring corrective action. The inspector will place
a check by all inspection items that appear to be operating properly. Those items where conditions
of potential concern are observed should be marked with an "X". A note should accompany the "X"
specifying what the concern is and what corrective measures will resolve the problem. This
observation of concern should be noted on the form until the problem has been remedied. The date
that corrective action was taken should be noted as well. Additional inspection items are required
under the DMT Plan, which requires that the daily inspection form requirements in Attachment A to
the DMT Plan also be completed.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 5 of 37
Areas to be inspected include the following: Cell 1, 2, 3, 4A and 4B, the liners of Cells 1, 2, and 3,
Dikes 4A-S, 4A-E, and 4B-S, wind movement of tailings, effectiveness of dust minimization
methods, spray evaporation, Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A and
4B liquid pools and associated liquid return equipment, and the Cell 1, 2, and 3 leak detection
systems.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell
4A or Cell 4B; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
b) Cell 1.
c) Cell 2.
d) Cell 3.
e) Cell 4A.
f) Cell 4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S .
h) The Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A and Cell
4B liquid pools and associated liquid return equipment.
i) Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
j) Spray evaporation pumps and lines.
k) Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
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initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
1) Observation of flow and operational status of the dust control/spray evaporation
system(s).
m) Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
4A, and4B.
n) Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
o) An estimate of flow for active tailings slurry and SX line(s).
p) An estimate of flow in the solution return line(s).
q) Daily measurements in the leak detection system sumps of the tailings Cells 1, 2,
and 3 will be made when warranted by changes in the solution level of the
respective leak detection system. Measurement of fluids in the Cells 4A and 4B
leak detection system and recording of the daily measurements of the Cells 1, 2,
and 3 leak detection systems sumps are discussed in the DMT Plan.
The trigger for further action when evaluating the measurements in the Cells 1, 2,
and 3 leak detection systems is a gain of more than 12 inches in 24 hours. If
observations of trigger levels of fluids are made, the Mill Manager should be
notified immediately and the leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter and
totalizer is recording on Cells 1, 2, and 3, a notation of the date and the time will
be recorded on the Daily Inspection Data form. This data will be used in
accordance with License Condition 11.3 .B through 11.3 .E of the Mill's
Radioactive Materials License, to determine whether or not the flow rate into the
leak detection system is in excess of the License Conditions.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed following notification to the Director.
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r) Observations regarding visible sediments (Celll and Cell 4B only).
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the RSO and/or Mill
management in the event that during their inspection they discover that an abnormal condition or
tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
Inspectors will notify the RSO and/or Mill management immediately if, during their inspection, they
discover that an abnormal condition exists or an event has occurred that could cause a tailings
emergency. Until relieved by the Environmental or Technician or RSO, inspectors will have the
authority to direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the RSO, one of whom will notify Corporate Management. If
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dam failure occurs, notify your supervisor and the Mill Manager immediately. The Mill Manager
will then notify Corporate Management, MSHA (303-231-5465), and the State of Utah, Division of
Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3 .1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly (as well as
daily) to determine whether it is wet or dry. If marked wet, the liquid levels need
to be measured and reported. In Cell 1, 2, and Cell 3 the leak detection system is
measured by use of a dual-probe system that senses the presence of solutions in
the LDS system ( comparable to the systems in Cells 4A and 4B) and indicates the
presence of solution with a warning light. The water levels are measured to the
nearest 0.10 inch. The water level data in Cells 1, 2, and 3 is recorded on the
Daily Tailings Inspection Form included as Attachment A-1 of the DMT Plan.
If sufficient fluid is present in the leak detection system of Cells 1, 2, and 3, the
fluid shall be pumped from the LDS, to the extent reasonably possible, and the
volume of fluid recovered will be recorded. Any fluid pumped from an LDS
shall be returned to a disposal cell.
For Cells 1, 2, and 3, if fluid is pumped from an LDS, the flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed time
since fluid was last pumped or increases in the LDS fluid levels were recorded,
whichever is the more recent. This calculation shall be documented as part of the
weekly inspection.
For Cells 1 and 3, upon the initial pumping of fluid from an LDS, a fluid sample
shall be collected and analyzed in accordance with paragraph 11.3 C. of the
RML. The LDS requirements for Cells 4A and 4B are discussed in the DMT
Plan.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
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system which aids in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37 .97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. The extension of the Cell 2 slimes drain access pipe did
not require any changes to the measurement procedure. The surveyed measuring
point on the extended pipe is used as required. The elevation of the measuring point
is 5618.73 fmsl. The head measurements are calculated in the same manner, using
the same procedures as those used prior to the extension of the Cell 2 slimes drain
access pipe; however, the total depth to the bottom of the pipe is now 37.97 feet as
noted on the corrected form in Attachment A. All head measurements must be made
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from the same measuring point (the notch at the north side of the access pipe 5618.73
fmsl), and made to the nearest 0.01 foot. The results will be recorded as depth-in-
pipe measurements on the Weekly Tailings Inspection Form. The quarterly recovery
test specified in the GWDP is discussed in the DMT Plan. It is important to note that
the extension of the Cell 2 slimes access pipe has not changed the method of
calculation of the pre-and post-pump head calculations, only the constant (Cell 2
slimes drain access pipe height) used in the calculation has changed. The head is
calculated by subtracting the depth to liquid from 37.97 feet rather than from the
previous measurement of 38 feet. The weekly Tailings Inspection form included in
Attachment A has been changed to reflect the extension height;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains
are kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B
slimes drains are inspected and the results reported in accordance with the
requirements of the permit.
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore pad,
near the Mill's scale house. Weekly and annual inspection requirements for the
New Decontamination Pad are discussed in the DMT Plan.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill's maintenance shop and the ore feeding grizzly.
A The Existing Decontamination Pad will be inspected on a weekly basis.
Any soil and debris will be removed from the Existing Decontamination
Pad immediately prior to inspection of the concrete wash pad for
cracking Observations will be made of the current condition of the
Existing Decontamination Pad, including the concrete integrity of the
,
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exposed surfaces of the pad. Any abnormalities relating to the pad and
any damage or cracks on the concrete wash surface of the pad will be
noted on the Weekly Tailings Inspection form. If there are any cracks
greater than 1/8 inch separation (width), the RSO must be contacted.
The RSO will have the responsibility to cease activities and have the
cracks repaired.
e) Weekly Photographs for EPA Subpart W
Weekly photographs of Cells 1 and Cell 4B documenting observations regarding
sediments present and proof of saturation as necessary. Digital photographs will
be taken and will have at a minimum date and time electronically embedded.
Notations regarding the completion of the photographic documentation will be
made on the Weekly Tailings and DMT Inspection form in Attachment A.
f) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings Inspection form is provided in Appendix A of this
Tailings Management System procedure. A similar form containing DMT inspection requirements is
provided as Attachment A of the DMT Plan.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the RSO or his designee from the Radiation Safety
Department and recorded on the Monthly Inspection Data form, an example of which is contained in
Appendix A. Monthly inspections are to be performed no sooner than 14 days since the last monthly
tailings inspection and can be conducted concurrently with the quarterly tailings inspection when
applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be visually inspected at key
locations to determine pipe wear. The critical points of the pipe include bends, slope
changes, valves, and junctions, which are critical to dike stability. These locations to
be monitored will be determined by the Radiation Safety Officer or his designee from
the Radiation Safety Department during the Mill run.
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b) Diversion Ditches
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Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
d) Overspray Dust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results attached to the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the RSO or his designee from the Radiation Safety
Department, having the training specified in Section 2.4 above, once per calendar quarter. A
quarterly inspection should be performed no sooner than 45 days since the previous quarterly
inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
(
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a) Embankment Inspection
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The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.
d) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
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All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being approached.
Records will also be reviewed to summarize observations of potential concern. The evaluation also
involves discussion with the Environmental and/or Radiation Technician and the RSO regarding
activities around the tailings area for the past year. During the annual inspection, photographs of the
tailings area will be taken. The training of individuals will be reviewed as a part of the Annual
Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Director and to the Assistant State Engineer, Utah Division of Water Rights at the address specified
below.
Assistant State Engineer
Utah Division of Water Rights
1594 West North Temple, Suite 220
P.O. Box 146300
Salt Lake City, Utah 84114-6300
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 4A-
E, 4A-S, and 4B-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
(
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6.3. Freeboard Limits
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The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of 0.77 feet.
The flood volume from the PMP event over the Cell 4B area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), times the PMP of 10
inches, with a wave run up factor of 0.77 feet.
The total pool surface area in Cell I is 52.9 acres, in Cell 4A is 40 acres, and in Cell 4B is 40
acres. The top of the flexible membrane liner ("FML") for Cell I is 5,618.2 FMSL, for Cell 4A
is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. Cell 1
The freeboard limit for Cell 1 will be set at 5,615.4 FMSL. This will allow Cell I to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 feet equals 2.85 feet. The
freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive
Materials License condition 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2
The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).
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6.3.3. Cell 3
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The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future
tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell 4A will be attributed to Cell 4B. A spillway has been added to Cell 4A to allow overflow into
Cell 4B.
6.3.5. Cell 4B
The freeboard limit for Cell 4B will be set assuming that the total PMP volume for Cells 2, 3, 4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell 4B is as follows:
( a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell 4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Cell 4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres
Wave run up factor
Total required freeboard
3 8 .1 acre-feet
159.4 acre-feet
197.5 acre-feet
4.9 feet
0.77 feet
5.7 feet
( all values in the above calculation have been rounded to the nearest one-tenth of a foot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation of the beach area in Cell 4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the free board limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
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(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevation of the beach area in Cell 4B first exceeds 5,594 FMSL, then the
freeboard limit for the remainder of the ensuing year (period t=O) (until the next November 1) will be
calculated when that elevation is first exceeded (the "Initial Calculation Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
4B prior to the Initial Calculation Date ("To") will be determined;
ii) The expected number of dry tons to be deposited into Cell 4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("Llo*"), will be determined;
iii) flo* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4B will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell 4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directly proportional to the reduction in the available space in Cell 4B
for solids. That is, the reduced pool surface area for period t=O ("RP Ao"), after the
reduction, will be calculated to be:
(1 -(Llo* x 1.5) / (2,094,000 -To)) x 40 acres = RP Ao
vii) The required freeboard for Cell 4B for the remainder of the period t=O can be
calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the
quotient of 197 .5 acre feet divided by the RP Ao. The freeboard limit for Cell 4B for
the remainder of period t=O would then be the elevation of the FML for Cell 4B of
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculation is set out in Appendix F.
( d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5,594FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARP At-I)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-1).
The RP At-I used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPA1-1 is merely the RPA that would have
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been used for period t-1 had the actual tonnages for year t-1 been known at the outset
of period t-1 and had the RP A been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARPA1-1 can be calculated using the following formula:
(1 -~t-1 / (2,094,000-Tt-I)) X ARPA1-2= ARPAt-1
Where:
• ~t-1 is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;
• T1-1 is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t-1; and
• ARPA1-2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARPA1-2 is 40 acres;
ii) Once the ARPA1-1 for the previous period (period t-1) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1 -(~t* x 1.5) I (2,094,000 -Tt)) x ARPA1.1 = RPAt
Where:
• ~t* is the expected number of dry tons of tailings to be deposited into Cell 4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Ti is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t; and
• ARPA1-1 is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-1) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for period t can be calculated in feet to be the wave run up
factor for Cell 4B of 0.77 feet plus the quotient of 197.5 acre feet divided by the RPAt.
The freeboard limit for Cell 4B for period t would then be the elevation of the FML
for Cell 4B of 5594.0 FMSL less this required freeboard amount, rounded to the
nearest one-tenth of a foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting free board limit will persist until the next Annual Calculation
Date for period t+ 1.
An example of this calculation is set out in Appendix D.
(e) When a Spillway is Added to Cell 4B that Allows Ove,flow Into a New Tailings Cell
When a spillway is added between Cell 4B and a new tailings cell then, if an approved freeboard
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 19 of 37
limit calculation method for the new cell is set to cover the entire PMP event for Cells 2, 3, 4A, 4B
and the new tailings cell, the freeboard limit for Cell 4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3, 4, 5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily inspection forms included as Appendix A to this Tailings Management
System procedure, the inspection forms included as Attachment A of the DMT Plan and the
Operating Foreman's Daily Inspection form the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the RSO, the report shall be submitted to the RSO for
review. The Mill Manager will review the report as well before the report is filed in the Mill Central
File. The report will contain a summary of observations of concern noted on the daily and weekly
tailings inspections. Corrective measures taken during the month will be documented along with the
observations where appropriate. All daily and weekly tailings inspection forms will be attached to
the report. A monthly inspection form will also be attached. Quarterly inspection forms will
accompany the report when applicable. The report will be signed and dated by the preparer in
addition to the Radiation Safety Officer and the Mill Manager.
8.2. Weekly Cell I and Cell 4B Photographs
Weekly photographs taken in response to EPA 40 CFR Part 61 will be stored on the Mill network
and reported in the EPA Central Data Exchange at least monthly ( as available). If the EPA Central
Data Exchange is unavailable, the photographs will be maintained at the Mill in an electronic format.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A
FORMS
03/17 Revision: EFR 2.5
Page 20 of37
(-
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .1
03/17 Revision: EFR 2.5
Page 21 of 37
APPENDIX A-1
DAILY 1NSPECTION DATA
Inspector: ______ _
Date; ________ _
Accompanied by: ___ _
Time: ________ _
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
I. TAILJNGS SLURRY TRANSPORT SYSTEM I
Insoection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point( s) of Discharge Improper Location or Orientation
II. OPERATIONAL SYSTEMS and JNTERIOR of CELLS
Insoection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3
N s E w
Interior Cell Walls
Liner Observable Liner Damage
Water Level Greater Than Operating Level, Large
Change Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
Cell 4A Cell 4B
Cell 4A Cell 4B
N S E w N S E w
Presence of Sediments Sediments should be saturated YorN NIA NIA NIA YorN Notes:=========='.=~~~~'.'.::::===========-=----------------------------
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
ID. DIKES AND EMBANKMENTS
Ins12ection Items Conditions of Potential
Concern
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
Crest Cracks, Subsidence, Severe
Erosion
IV. FLOWRATES
Dike 1-I
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
I
Dike 1-
lA
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
03/17 Revision: EFR 2.5
Page 22 of37
Dike2 Dike 3
No No
visible visible
exterior exterior
slope or slope or
dike to dike to
inspect inspect
No No
visible visible
exterior exterior
slope or slope or
dike to dike to
inspect inspect
Dike
4A-S
Slurrv Line( s) Pond Return S-X Tails
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VI. DUST CONTROL
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
Slimes
Cell2
______ Y"es
______ Y"es
Cell 3
Dike Dike
4A-E 4B-S
Sorav Svstem
______ No
______ No
Cell 4A Cell 4B
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
General Meteorological conditions:
VII. DAILY LEAK DETECTION CHECK
03/17 Revision: EFR 2.5
Page 23 of37
Daily Leak Detection Checks are recorded on the Daily Inspection Data form included
as Attachment A-1 of the DMT Plan
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
Taili11gs Daily Inspection Repoit
Tailings Sluny Discharge Location
I -. -·
i j
!
f
I
// ·.
,--------I MILL SITE
I I .
/ /
' . CELL NO. 1 ~· \ \.
( _, llike 1-I -:=_
\ : ·----..... CELL NO. 2
I I --... ,, ...... Filled I I -. . '1
' II CiELL N Dik·~---o. 3 .. -··· .. :·· ''. \
I I ;·
I ' // 1Ji111 ; ,
----....__J ,1 . (
CELL NO. 46 ; .: . / .
. __ . 1.!,,· CELL NO. 4A //
• ike as-"• 1 • / I!;
• I ,:;' D* B --D,xc1A _-I~, I11sp ect or: . _
I I
I I
,,# ·--.... ..
(. ----==--.... ,._
I --~-
I I
I I
N
--..... ,.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 25 of37
APPENDIX A-2
WHITE MESA MILL
WEEKLY TAILINGS INSPECTION
Date: _______ _
1. Slimes Drain Liquid Levels Cell 2
Inspectors: --------------
Pump functioning properly ___ _
------~Depth to Liquid pre-pump
_______ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 43.41 '-Depth to Liquid Pre-
pump = __ _
Post-pump head is _43.41' -Depth to Liquid Post-
pump = __ _
2. Existing Decontamination Pad (concrete): ___________________ _
3. Tailings Area Inspection (Note dispersal of blowing tailings):
4. Sediments visible in: Cell 1: Y Or N Cell 4B: Y Or N If yes, are they saturated? Y Or N
5. If no, note corrective actions: ______________________ _
6. Control Methods Implemented: _____________________ _
7. Remarks: ________________________________ _
8. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .1
03/17 Revision: EFR 2.5
Page 26 of 37
APPENDIX A-3
MONTHLY INSPECTION DATA
Inspector:-------------
Date: ---------------
1. Slurry Pipeline: -----------------------------
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Diversion Ditch 1
__ yes __ no
__ yes __ no
__ yes __ no
__ yes __ no
__ yes __ no
__ yes __ no
Diversion Ditch 2
__ yes __ no
__ yes __ no
__ yes __ no
__ yes __ no
Diversion Ditch 3 Diversion Berm 2
__ yes __ no
__ yes __ no
__ yes __ no
yes no ----
Comments: _________________________________ _
3. Summary of Activities Around Sedimentation Pond: -----------------
(
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: ___ yes __ ~no
Overspray carried more than 50 feet from the cell: __ yes no
If "yes", was system immediately shut off? __ yes __ no
Comments:
03/17 Revision: EFR 2.5
Page 27 of37
----------------------------------
5. Remarks:----------------------------------
6. Settlement Monitors:
Attach the Settlement monitor monthly survey data (spreadsheet). Note any unusual observations
below.
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections: ----------------
9. Monthly LDS Pump Checks in Cells 4A and 4B:
White Mesa Mill -Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 28 of37
APPENDIX A-4
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:-------------
Date: ---------------
1. Embankment Inspection: ---------------------
2. Operations/Maintenance Review:
3. Construction Activities: --------------------
4. Estimated Areas:
Cell 3 Cell 4A Cell 4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments:
( White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1 -.
APPENDIXB
TAILINGS INSPECTOR TRAINING
03/17 Revision: EFR 2.5
Page 29 of37
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediate! y to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A of this Tailings Management System
procedure. A similar form containing DMT inspection requirements is provided as Attachment A of
the DMT Plan. The inspection form contained in this Tailings Management System procedure is
summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 30 of37
are to be monitored for leaks, and loose connections. The pipeline supports are to be
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 4B solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
3. Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 4A-S, 4A-E, and 4B-S,, should be inspected closely
for mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
i
\
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Flow Rates:
03/17 Revision: EFR 2.5
Page 31 of 37
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "O". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2, 3, 4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by Environmental, Health and Safety personnel as close to 8:00
a.m. as possible. All snow or ice should be melted before a reading is taken.
7. Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each. area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8. Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
White Mesa Mill -Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
03/17 Revision: EFR 2.5
Page 32 of 37
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit on Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area ( other than the Cell 4A and 4B dike) is 15 mph. These limits should not
be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. W aterfow 1 seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
11. Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Rl:1diation Safety Officer authorizes certification. Refer to the Certification
(
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 33 of37
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the RSO and
filed.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Date:
APPENDIXC
CERTIFICATION FORM
------------
Name: ___________ _
03/17 Revision: EFR 2.5
Page 34 of37
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems ( dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System Supervisor
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Assumptions and Factors:
APPENDIXD
Example of Freeboard Calculations
For Cell 4B
o Total PMP volume to be stored in Cell 4B -159.4 acre feet
o Wave runup factor for Cell 4B -0.77 feet
o Total capacity of Cell 4B -2,094,000 dry tons
o Elevation of FML of Cell 4B -5,600.35 FMSL
o Maximum pool surface area of Cell 4B -40 acres
03/17 Revision: EFR 2.5
Page 35 of37
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL-1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL-March 1, 2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Tailings Actual Tailings Solids
Tailings Solids Solids Disposition into Disposition into Cell 4B
Disposition into Cell 4B at the determined at end of
Cell4B beginning of the the period (dry tons)*
Determined at period, multiplied by
the beginning of 150 % Safety Factor
the period ( dry (dry tons)
tons)*
March 1, 2012 to 150,000 225,000 225,000
November 1, 2012
November 1, 2012 to 300,000 450,000 275,000
November 1, 2013
November 1, 2013 to 200,000 300,000 250,000
November 1, 2014
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only.
Based on these assumptions and factors, the free board limits for Cell 4B would be calculated
as follows:
1. Prior to March 1. 2012
l Prior to March 1, 2012, the maximum elevation of the beach area in Cell 4B is less than or
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 36 of37
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1, 2012 to November 1. 2012
The pool surface area would be reduced to the following amount
(1-225,000/ (2,094,000-1,000,000)) x 40 acres= 31.77 acres
Based on this reduced pool area, the amount of free board would be 197 .5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave run up factor for Cell 4B of 0. 77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell 4B would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1, 2012 to November 1, 2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since the actual tonnage of225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as
the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1-450,000/ (2,094,000-1,000,000 -225,000)) x 31.77 acres= 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197 .5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave run up factor for Cell 4B of0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
4B would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66
feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2012, and this freeboard limit would persist until November 1, 2013.
4. November l, 2013 to November l, 2014
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(
(
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 37 of 37
(1-275,000/ (2,094,000-l,OOO,OOO-225,000) x 31.77 acres= 21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1, 2013.
Then, calculate the modeled pool surface area to be used for the period:
(1-300,000/ (2,094,000-1,000,000 -225,000-275,000)) x 21.72 acres= 10.75 acres
Based on this reduced pool area, the amount offreeboard would be 197.5 acre feet divided by
10.75 acres equals 18.37 feet. When the wave run up factor for Cell 4B of0.77 feet is added
to this, the total free board required is 19 .14 feet. This means that the free board limit for Cell
4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet,
rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2013, and this freeboard limit would persist until November 1, 2014.
i
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 12.4
December 2016
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
WHITE MESA MILL
12/16 Revision: EFRI 12.4
Page 2 of25
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. IN"TRODUCTION ................................................................................................................... 3
1.1. Background ....................................................................................................................... 3
2. DAILY TAILINGS INSPECTIONS ........................................................................................ 4
2.1. Daily Inspection ................................................................................................................ 4
3. WEEKLY TAILINGS AND DMT INSPECTION .................................................................. 5
3.1. Weekly Tailings Inspections ............................................................................................. 5
Northing ................................................................................................................................... 9
Easting ..................................................................................................................................... 9
3.2. Weekly Feedstock Storage Area Inspections .................................................................. 12
4. ANNUALEVALUATIONS .................................................................................................. 12
4.1. Annual Leak Detection Fluid Samples ............................................................................ 12
4.2. Annual Inspection of the Decontamination Pads ............................................................ 12
4.4 Annual Inspection of Waste Oil and Fuel Tanks ............................................................ 13
5. IN"SPECTION OF THE AMMONIUM SULFATE COVER AREA .................................... 13
6. OTHER INSPECTIONS ........................................................................................................ 14
7. REPORTING REQUIREMENTS ......................................................................................... 14
7.1. DMT Reports .................................................................................................................. 14
Attachment A
Attachment B
Attachment C
ATTACHMENTS
Forms
Feedstock Storage Area
Tables
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
1. INTRODUCTION
12/16 Revision: EFRI 12.4
Page 3 of25
This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
White Mesa Mill's (the "Mill's") Groundwater Discharge Permit ("GWDP") Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT 19004 79 ( the "RML") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3 .1 of the Mill's Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of the feedstock storage areas at the Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill's Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3 .1 of the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill's Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill's Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requir~ments from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
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Page 4 of25
This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1, 2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1, 2, 3, 4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-1 to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2. lq).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 5 of25
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell's LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1, 2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS ( comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-1 of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill's environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
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For Cells 1, 2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C of the
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table lA and lB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 closed and Phase
1 cover activities have commenced. Each cell has a slimes drain system which aids
in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in 2011 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the 2011 re-
grading of the interim cover and the placement of an additional 62,000 cubic yards of
fill material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe was 6.97 feet in length and the measuring point was 37.97 feet from
the bottom of the slimes drain. This value was used in all calculations from 4th
quarter 2011 through the 3rd quarter 2016. In April 2016, Phase 1 cover placement
and construction commenced. The Pahse 1 cover activities include the placement
and compaction of approximately 4.5 feet of soil materials. During the 3rd quarter
2016, the slimes drain access pipe was extended 5.44 feet as a result of the Phase 1
cover activities. The measuring point on the extension pipe was surveyed by a Utah-
Certified Lai:id Surveyor. The measuring point elevation is now 5624.17 fmsl. For the
quarterly recovery test described in section vi below, this extension has no effect on
the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
43.41 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. . This means that the bottom of the slimes drain pool
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 7 of25
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 44.31 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5624.17 fmsl), and made to the nearest 0.01 foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5624.17 -Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11, 2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii)If at any time the most recent average annual head in the Cell 2 slimes drain is found
to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
c) Tailings Wastewater Pool Elevation Monitoring
12/16 Revision: EFRI 12.4
Page 8 of25
Solution elevation measurements in Cells 1, 4A, and 4B are to be taken by survey on a weekly
basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a
monthly basis when beaches are first observed, as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee (the
"Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B2 l, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The Reference Points for Cells 1, Cell 4A, and 4B, are known points established by
professional survey. For Cell 1, the Reference Point is a wooden stake with a metal
disk on it located on the southeast corner of Cell 1. The elevation of the metal disk
(the "Reference Point Elevation") for Cell 1 is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 4A and 4B, the Reference Point is a piece of stamped metal
monument located next to the transformer on the south side of Cell 4A and 4B. The
elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A
and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a
location where both the applicable Reference Point and pond surface are visible.
(iv)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and
4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by
gently rocking the rod back and forth until the Surveyor has established a level
reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1, Cell 4A, or Cell 4B, or
the area of the beach in Cell 4B with the highest elevation, as the case may be. These
designated locations, and the methods to be used by the Assistant to consistently use
the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
( White Mesa Mill -Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 9 of25
B.
A. Pond Surface Measurements
I. Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
II. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
Ill. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are:
Northing Easting
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Cell 4 B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
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(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 11 of25
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet arrlsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill's maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
3.2. Weekly Feedstock Storage Area Inspections
12/16 Revision: EFRI 12.4
Page 12 of25
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Annual Leak Detection Fluid Samples
Pursuant to Part I.E.lO(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
( White Mesa Mill -Discharge Minimization Technology Monitoring Plan
b) Existing Decontamination Pad
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Page 13 of25
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
4.4 Annual Inspection of Waste Oil and Fuel Tanks
During the second quarter of each year, the used/waste oil tank and fuel tanks will be inspected to
ensure the integrity of the tanks and support structures. The tanks and any associated piping will be
visually inspected for signs of corrosion or leaking. Any concrete structures, containments and
supports will be inspected to ensure the integrity of the exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the surface, repairs will be made within 7 days. All
inspection findings and any repairs required shall be documented on the Annual Inspection form.
The documentation of the inspection findings, any repairs required and repairs completed will be
maintained at the Mill.
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1/8 inch separation (width) or any significant deterioration or damage of the concrete
pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/ Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
6. OTHER INSPECTIONS
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Page 14 of25
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIRE1\1ENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7 .1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part l .F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3.l(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3 .1 ( d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
including any repairs required, and repairs completed]);
b) On a quarterly basis, a summary of the weekly water level ( depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b ), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
e) With respect to the annual inspection (after the completion of 8 quarterly
( White Mesa Mill -Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 15 of25
inspections) of the Ammonium Sulfate Cover Area described in Section 5 .0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
f) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A
FORMS
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Page 16 of25
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ATTACHMENT A-1
DAILY INSPECTION DATA
Any Item not "OK" must be documented. A check mark= OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3
Inspector: ______ _
Date: ________ _
Accompanied by: ___ _
Time: ________ _
Cell 4A Cell 4B
Leak Checked Checked Checked Checked Checked
Detection
System Wet Dry Wet Dry Wet Dry Wet Dry Wet
Checked
Initial level Initial level Initial level Initial level Initial level
Final Final Final Final Final
level level level level level
Gal. pumped Gal. pumped Gal. pumped Gal. pumped Gal. pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-1)
Dry
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Page 18 of25
Date: _______ _
1. Pond and Beach
elevations (msl, ft)
2. Leak Detection Systems
Observation:
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Inspectors:-------------
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation 5597 __ _
(c) Depth of Water above FML ((a)-(b)) _____ _
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b)) _____ _
Cell 4B: (a)Pond Solution Elevation
(b )FML Bottom Elevation 5557 .50
(c)Depth of Water above FML ((a)-(b)) ____ _
( d)Elevation of Beach Area with Highest Elevation
(monthly)
New Decon Pad, Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or __ wet __ dry __ wet __ dry __ wet __ dry
dry?
If wet, Record liquid Ft to Liquid Ft to Liquid Ft to Liquid
level:
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):---------------------
( White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-3
12/16 Revision: EFRI 12.4
Page 19 of25
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through ____ Date of Inspection: _______ _
Inspector: ___________ _
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: ___ no: ___ _
comments: __________________________________ _
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no: __ _
comments (e.g., conditions of containers): _________________ _
Are all sumps and low lying areas free of standing solutions?
Yes: No: __ _
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No: __ _
Comments: __________________________________ _
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
Ore Pad Stonnwater Transfer Line:
Is the transfer line visible?
Yes: No: __ _
12/16 Revision: EFRI 12.4
Page 20 of25
Comments: __________________________________ _
Is there any evidence of breakage, spillage or leakage?
Yes: No: __ _
Comments: __________________________________ _
Other comments:
Ore Pad Southwest Stormwater Containment {Kiva):
Is there sediment or debris in the bottom of the Kiva?
Yes: No: __ _
Comments: __________________________________ _
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes: No: __ _
Comments: __________________________________ _
( White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-4
12/16 Revision: EFRI 12.4
Page 21 of25
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection: _______ _
Inspector:-----------
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
_Yes _No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? __ Yes __ No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September
1 of each calendar year.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-5
12/16 Revision: EFRI 12.4
Page 22 of25
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection:. ____ _
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
_Yes_No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
_Yes_No
Is there any significant deterioration or damage of the asphalt surface? __ Yes __ No
Findings:
I
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-6
12/16 Revision: EFRI 12.4
Page 23 of25
ANNUAL USED/WASTE OIL AND FUEL TANK INSPECTION
Date of Inspection: ___ _
Are there any anomalies on tanks including dents or rusty areas?
_Yes_No
Comments: __________________________________ _
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints: ______________________________ _
Pipeline Supports: ______________________________ +
Valves: _________________________________ _
Point(s) of Discharge: ___________________________ _
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
_Yes _No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
__ Yes __ No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable): ______ _
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT B
FEEDSTOCK STORAGE AREA
DATE: ___ _
12/16 Revision: EFRI 12.4
Page 24 of25
·----.-----.. ,---....
N
I
f '
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 25 of25
ATTACHMENT C
TABLES
Table IA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day )
Table lB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
Requests for Additional Information (RAI' s) are numbered and included, following:
RAI 1 — Additional information needed to support claims of 0.26% U308 in the Chemours Monazite
Mineral Sand meet the definition of uranium ore
EFRI states on page 4 of the letter that the Chemours material has a grade of 0.26% U308. The EFRI
letter includes an Attachment D Table which is referred to as "a summary of the mineral composition of
a typical ore produced in 2019" (Page 4). It is assumed that the EFR letter is claiming that the
Chemours monazite sand will contain a consistent percentage of recoverable uranium, however, there is
no source for the data provided in Attachment D and no way to confirm that consistent percentages will
be present for all material accepted at the Mill. Please provide the data and sources used to claim the
U308 concentrations of the Chemours Material as well as justification that all material received from the
Mission mine and the multiple future mines and sources of mineral sand will contain a consistent
percentage of recoverable uranium.
At a minimum, it needs to be documented with analytical data that the Chemours material will always
meet the definition of source material ore per the Utah Administrative Code R-313-12-3 (see also
10CFR40.4) contain by weight one-twentieth of one percent (0.05 percent) of uranium for acceptance at
the White Mesa Uranium Mill.
RAI 2 — Additional information needed to evaluate potential changes to Mill Tailings Constituent
Inventory and concentrations for evaluation of Groundwater Permit Monitoring Requirements
The EFRI letter does not include specific evaluation of the impacts to the mill tailings due to the
processing and disposal of the Chemours material tailings. Page 4 of the EFRI letter generally discusses
that the Chemours material should not require any additional mill processes; however, DWMRC notes
that monazite sand is not chemically consistent with uranium/vanadium ores from the Colorado Plateau
and Arizona Strip which were evaluated when determining compliance monitoring requirements of the
Mill in the Groundwater Permit Statement of Basis. Please submit a more detailed EFRI evaluation of
the uranium/rare earth mineral ore which will be processed and disposed of in the tailings cells using the
anticipated Mill processes (existing or new), including an evaluation of expected changes in constituent
concentrations in the tailings management system and potential new constituents which may need to be
included in the Groundwater Permit as a result of processing a uranium ore with rare earth minerals.
RAI 3 — Additional information is needed regarding changes or additions that may be required in the
uranium extraction circuits
It is unclear in the information submitted where in the process the rare earth minerals would be
extracted, and what physical alterations to the mill works would be necessary. Please describe changes
necessary to the plant and the processes. If no changes are needed, please explain/justify why not.
RAI 4 — Additional information for compliance with U.S. Department of Transportation requirements
On June 26, 2020 in an email request, the Division requested to see an old manifest of the monazite sand
material when it was being sent to China. After reviewing both the letter of June 25, 2020 and the
manifest please provide the following information:
• The manifest provided listed the "chemical form" as monazite sand. This is not a chemical form
description according to U.S. Department of Transportation. Please provide the correct chemical
form for the uranium/rare earth mineral ore. (i.e. U308 other appropriate chemical descriptions).
• In the EFRI's letter it states that supersaks in intermodal containers will be used to transport the
uranium ore to the Mill. Please provide information that the supersaks and intermodal containers
are IP-1 containers which are the appropriate transport containers for LSA-1 material.
• Please indicate the shipment of the uranium/rare earth mineral ore will be exclusive use
shipments.
• Please provide a detailed description of transportation route(s) that will be used to transport the
ore to the Mill.
• Please update the transportation emergency response plan to include the transportation of the
uranium/rare earth mineral ore from Georgia to the Mill.
• Please provide a description of all other transportation requirements regarding labeling,
placarding, transportation papers, etc.
RAI 5 — Assess the Radiological and Non-radiological effects of processing uranium ore with rare
earth minerals
From the 1978 Environmental Report for the White Mesa Uranium Project, Section 1.0 Proposed
Activities, it states "Energy Fuels Nuclear, Inc. proposes to construct and operate an acid leach
uranium mill-and associated facilities for producing yellowcake uranium concentrate and, when
economically feasible, limited quantities of copper and/or vanadium concentrates." In EFRI' s
June 25, 2020 letter, it proposes to process a uranium ore for yellowcake uranium concentrate and a rare
earth mineral concentrate. The process of extracting a rare earth mineral concentrate has not been
environmentally evaluated for the White Mesa Uranium Mill.
Please evaluate the radiological and non-radiological effects of processing a uranium ore with rare earth
minerals. Please include occupational and public exposure and short and long-term effects of processing
uranium ore with rare earth minerals.
Please discuss any adjustments needed to the radiation safety program, environmental monitoring
program and groundwater monitoring to process the ore. If no changes are needed, please
explain/justify why not.
The previous RAI items were discussed between DWMRC and EFRI during a conference call on
July 21, 2020.
If you have any questions, please call me at [phone].
Sincerely,
Phil Goble, Uranium Mills and Radioactive Materials Manager
Division of Waste Management and Radiation Control
PG/TR/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Mill Manager, EFR1
( White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.3
Date: 04/14 Revision: EFR-4
Page I of3
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
DUST MINIMIZATION
1. Operational Procedure for Dust Minimization:
In an effort to keep wind movement of tailings sand to a minimum, the following dust
minimization procedures will be utilized.
1.1. When blowing tailings sand or dusting is observed on Tailings beaches, the spray
system should be operated until a crystal crust develops on the sands surface. The
spray lines will be moved as necessary. As soon as the crystal surface develops, the
spray system will be shut off. The Environmental Coordinator along with the Mill
Foreman and Shift Foreman will be responsible for the operational decisions
regarding dust minimization. The spray lines require periodic cleaning because they
tend to crystallize over a period of time. The spray system should be operated if there
is evidence of excessive blowing sands indicating surface crust deformation or
otherwise on an as needed basis.
1.2. During times of strong winds, the Environmental Coordinator will ensure that no
spray is being carried out of the cells. If spray is leaving the confines of the cell, all
spraying will cease immediately.
1.3. Additional snow fencing and straw bales will be assembled to form windbreaks, as
needed on the Tailings beaches.
1.4. As 11 e.(2) by product material is placed in Cell 3, interim cover can be advanced in
an effort to minimize dusting on Cell 3.
The effectiveness of the above methods will be documented on the weekly tailings inspection
form. Documentation will include observed wind movement of tailings sand, if any, and the
steps taken the preceding week for dust control. Wind movement of tailings sand is noted on
every daily inspection form along with an estimate of the percentage of dusting from Cells 3
and 4a. The areas of blowing dust will be noted as well on Monday's daily inspection form.
2. Procedure: Tailings Dust Control System:
There are five methods of control of blowing tailings dust: Spraying raffinate solution,
creating wind breaks with straw bales and snow fencing, flooding with slurry, using
chemical stabilization agents and covering with interim cover. During operation of the
Mill, Cell 2 will not require any dust control measures since the cell consists of cover
( White Mesa Mill-Standard Operating Procedures
Book 11: Envirorunental Protection Manual, Section 3 .3
Date: 04/14 Revision: EFR-4
Page 2 of3
area. The entire control activities will be focused on Cell 3 and Cell 4a beaches unless
the above conditions are modified.
At present, there are four general areas in Cell 3:
1. Thepond.
2. The 11 e.(2) by product material disposal area.
3. The cover area.
4. The tailings beaches.
The area of concern regarding dusting is the tailings beaches. These beaches will need to
be sprayed in order to minimize dusting. The sprays should continue until a crust
develops on the tailings surface. Once a crust develops, the spray system can be shut
down.
Another method of dust control for Cell 3 and Cell 4a beaches is the use of straw bales
and snow fencing, which are used as wind breaks. These breaks should extend at least
three feet above the existing sands and should be extended in lines to form barriers.
These windbreaks will be monitored daily and repaired or replaced as needed.
The use of interim cover as a means of dust control in Cell 3 beaches will be utilized only
in the area in which the 11 e.(2) by product materials are placed, or in areas of Cell 3
where the tailings sand is up to final grade and is dewatered sufficiently enough to
support the use of equipment for placement of the interim cover. As the material is
placed, the cover can be advanced; thus, reducing the amount of tailings sand subject to
dusting.
When the mill is operating and tailings are deposited in Cell 4a, the area where tailings
sand is deposited becomes inaccessible to equipment. After a period of two to three
weeks, the sand surface will be stable enough to walk or work on. Tailings will be
deposited through two lines until the sands are at the final deposition elevation. At this
time, the lines will be moved to another area.
3. Procedure: Dust Minimization for Ore Stockpiles:
Dusting from the ore stockpiles have not been observed to be a problem as a hard crust has
developed, which has inhibited dusting. The primary dust control techniques will utilize water
application to the roadways on an as needed basis. If dusting is observed while transferring ore
to the Grizzly from either roadways or stockpiles, water applications will be applied to minimize
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .3
Date: 04/14 Revision: EFR-4
Page 3 of3
dusting. The number of applications, time of application, and location of application is
documented and kept on file in the Environmental Office. Weekly inspections of the stockpile
area are conducted to evaluate the effectiveness of dust control measures.
White Mesa Mill-Standard Operating Procedures
Book 11: Envirorunental Protection Manual, Section 3.4
Date: 04/14 Revision: EFR-4
Pagel of2
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
TAILINGS LINE DETECTION
1. Procedure: Tailings Line Rupture Detection System
The following method detects line rupture of a tails line at the White Mesa Mill.
There are four major pipelines that transport solution and slurry from the Mill to the tailings
Cells and from the tailings Cells back to the Mill. One six inch line and one eight inch line
transport slurry from the Mill to impoundment Cell 4a. One eight inch line transports tails
solution from the solvent extraction process to impoundment Cell 1-1. Solution is returned
back to the mill in a pond return line from either Cell 1-I or Cell 4a.
Each of the above mentioned lines will have separate sensing systems that will be tied into a
common alarm system. Each line will have a sensor at its discharge to determine the flow
condition in the line. There will be a total of four (4) sensors.
The type of sensors will be a conductivity detection device, which will detect the presence or
absence of material in the pipe. They will be positioned at high points in the line so that a
"no flow" condition will not produce a high conductivity reading. If they were positioned at
a low point in the line, the material would always present a false reading.
A time delay device will be incorporated in both tailings slurry lines that will activate the
alarm after approximately 30 seconds of no flow condition, or a time determined by
operational practice. This is necessary because of surges in the tailings slurry lines. It is not
anticipated that delay devices will be necessary for the pond return line or SX tails line. The
rupture detection alarm will be both optical and auditory, and will activate in the Central
Control Room. An alarm indicator will be installed in the Central Control Room along with
an "on-off' switch so that the Shift Foreman will have immediate control over the pond
return pump.
The Central Control Room will have an alarm panel that will show lights corresponding to
the different lines. The lines not in use will be shown as "no flow" conditions by the lights.
When a line goes from a "flow" to a "no flow" condition, an alarm horn unique to the tailings
system will sound and the corresponding light to the line will then blink intermittently. The
Shift Foreman can then acknowledge the alarm. This will tum off the horn, but the light will
remain on and cease to blink.
The Shift Foreman under the direction of the Mill Foreman will perform the daily test of the
F:\Mill SOP Master Copy\Book l l_Environmental Procedures\07 License Renewal\EFR\Section 3 4 Tails Line
Monitoring 4.doc
( White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .4
Date: 04/14 Revision: EFR-4
Page 2 of2
rupture detection system during the day shift. The Shift Foreman will shut down each
running pump under his control and observe the alarm board in the Central Control Room.
When the appropriate alarm sounds, he will acknowledge the alarm and restart the pump,
making sure the alarm light goes out. This will be recorded in the daily Shift Foreman's
report.
The Environmental Coordinator will review these reports to ensure that the rupture detection
system is functioning properly. In the event of a failure of the rupture detection alarm system
or rupture of a line, the Mill Foreman will be notified immediately.
2. Operational Procedure for Tailings Rupture Detection System -Central Control Room
2.1. Every day on the day shift the Shift Foreman will test the rupture detection system.
This test will show alarms at the rupture detection system panel board located in the
Central Control Room.
2.2. Any alarm will suggest a line rupture and will be investigated and treated as such.
2.3. Line ruptures will be reported immediately to the Mill Manager and the
Environmental Coordinator. The Mill Manager will also inform corporate
management immediately.
F:\Mill SOP Master Copy\Book 1 l_Environmental Procedures\07 License Renewal\EFR\Section 3 4 Tails Line
Monitoring 4.doc
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
PART I
SURFACE SOIL MONITORING
SOIL MONITORING PLAN
1.0 SOIL MONITORING
Date: 05/16 Revision: EFR-5
Page I of 5
Surface soils are sampled at the eight air monitoring sites and at spaced intervals around the
perimeter boundary of the Mill property. The sampling locations are shown in Figure 1. Soil
samples from the northern Mill boundary and the north half of the eastern boundary (adjacent
to Sections 22, 27 and 34) are collected approximately every 1000 feet. The remainder of the
perimeter boundary soil samples are collected every 2500 feet. Soil samples are taken once
per year during August or as soon as possible thereafter, but no later than September 30 of
the year. Each soil sampling location will be marked with an aluminum tag with the sample
location identification etched or painted on the tag. The tags will be attached to a metal stake
driven approximately 18 inches into the ground. The sampling locations will be placed on
the inside of the Mill's perimeter fence to prevent tampering and vandalism. The locations
will be sited approximately one foot from the inside of the perimeter fence to prevent
inadvertent disturbance by truck or vehicle traffic. The location markers will be designed
and installed with as low a profile as possible, while still maintaining visibility for ease of
location during the annual sampling program.
In addition, a soil sample could be taken from Westwater Creek, in the place of a water
sample. However, a sediment (soil) sample would only be taken at Westwater Creek if water
was not available. In the event that a soil sample is collected in place of a water sample for
Westwater Creek, the sample should be analyzed for the same parameters as those called for
in this SOP (Radium-226, Pb-210, Th-232, and U-nat). Refer to SOP No. PBL-EP-3 for
details regarding collection of a water sample from Westwater Creek.
2.0 SAMPLING AND ANALYTICAL QUALITY ASSURANCE
The sample bags are marked for location identification and are submitted to the analytical
laboratory accompanied by Chain-of-Custody forms. (Attachment A)
Analytical quality assurance for soil monitoring is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percentage recovery. The laboratory is
committed to meet the LLD values for radionuclides contained in U.S. NRC Regulatory
Guides 4.14 and 4.15 and will perform re-runs on all samples not meeting these limits.
Appropriate laboratory control and quality assurance data will be provided by the contract
laboratory, or equivalent, including LLD information.
3.0 ANALYTICAL REQUIREMENTS
All soil samples will be analyzed, on a dry basis for the following radionuclides: Ra-226 Th-
232, Pb-210, and U-Nat. Analytical results will be reported in appropriate radiological units
such as pico curies per gram or micro curies per kilogram.
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 05/16 Revision: EFR-5
Page 2 of5
PART II SOIL MONITORING STANDARD OPERATING PROCEDURES
1.0 SURFACE SOIL SAMPLING
1.1 Equipment
Equipment used for soil sampling is as follows:
1. Tape measure or measuring stick calibrated to 1 foot and to one centimeter.
2. Clean trowel or shovel.
3. Clean sample containers.
1.2 Soil Sampling Procedure
Soil samples are collected using a clean trowel or shovel to excavate a soil sample evenly
across a one square foot area at a depth of five centimeters. The five centimeter excavation
depth is maintained by using the tape measure or other suitable calibrated measuring stick.
As the soil is being collected, it is placed directly into the sample container. The sample
container is then identified with a label (see Section 2.1 below).
1.3 Decontamination Procedure
Equipment such as trowels or shovels used for sampling is decontaminated between
sampling locations. Equipment is decontaminated by spraying with deionized water and
wiping with clean paper toweling. Decontamination will continue until all visible dirt and
debris is removed from the equipment.
2.0 SAMPLING QUALITY ASSURANCE
2.1 Sample Duplicates
Soil sample duplicates will be collected at a frequency of 1 duplicate per 20 samples. The
duplicates will be submitted blind to the laboratory and will be named as follows:
NID where:
N = Northern boundary
1 = Sequential number of the northern boundary sample
D = Duplicate of sample NI
Duplicate precision will be discussed in the Semi-Annual Effluent Report. Duplicate
precision will be assessed as follows:
White Mesa Mill -Standard Operating Procedures Date: 05/16 Revision: EFR-5
Page 3 of5 Book #11, Environmental Protection Manual, Section 4.1
a) Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results. Section
3.3 will apply when the RPD > 35%, unless the measured concentrations are less than 5 times the
required detection limit (Standard Methods, 1998) (EPA Contract Laboratory Program National
Functional Guidelines for Inorganic Data Review, February 1994, 9240.1-05-01, p. 25).
2.2 Sample Labeling
2.2
Each sample must be labeled and all sample labels must be filled out in ink and numbered.
The following information must be contained on the label:
1. Project and facility.
2. Company name
3. Date and time of sample collection.
4. Sampler's initials.
5. Sample location.
6. Requested Analytical Parameters
Sample Chain-of-Custody
During sampling activities, traceability of the sample must be maintained upon sample
collection until the laboratory data is issued. Information on the custody, handling, transfer,
and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The
sampler is responsible for filling out the COC form. The COC form will be signed by the
sampler when the sampler relinquishes the samples to anyone else. A COC form is to be
completed for each set of samples placed in a sample shipping container and is to include the
following:
1. Sampler's name.
2. Date and time of collection.
3. Sample location.
4. Sample type.
5. Analysis requested.
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
6. Signatures of persons releasing custody.
Date: 05/16 Revision: EFR-5
Page 4 of 5
7. Signatures of persons accepting custody, dates, and times.
Copies of the COC forms and all custody documentation when received will be retained in
appropriate files at the Mill. The original COC form remains with the samples until disposal
of the samples.
2.3 Sample Handling and Shipping
Samples will be placed in shipping containers and transported to the contract laboratory.
COC forms will be placed inside a resealable bag and placed inside the sample shipping
container.
2.4 Record Keeping
All laboratory and field soil sample data are retained in the filesat the Mill and the Corporate
Offices ..
3.0 ANALYTICAL QUALITY ASSURANCE
3.1 Data Validation and Quality Control
Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in
results noted and investigated. Appropriate measures to confirm or disaffirm results will be
pursued, such as laboratory conversation, analytical sample rerun, or trend analysis.
3.2 Quality Assurance and Data Validation
The contract laboratory will prepare and retain a copy of all analytical and quality control
documentation. The laboratory will provide hard copy information in each data package
submitted in accordance with quality assurance objectives for the surface soil quality
assurance project plan that is: COC forms, cover sheets with comments, narratives, samples
analyzed, reporting limits and LLD values for analytes, and analytical results of quality
control samples. The data package will be signed, and dated by a laboratory representative.
3.3 Corrective Action
Corrective action will be taken for any deficiencies or deviations noted in the procedures or
anomalous results, such as but not limited to additional sample collection, sample re-run,
laboratory inquires, or other actions as appropriate.
Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue. If the deviation is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
(
White Mesa Mill -Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 05/16 Revision: EFR-5
Page 5 of5
a. Request the laboratory review all analytical results for transcription and calculation
errors, and
b. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
,::l;
•t I ~ ·o ~ E-i
.~
lYRflC,W Chain of Custody and Analytical Request Record Page_ of_
PLEASE PRINT, provide as much information as possible. Refer to corresponding notes on reverse side. l.ABORA TORIFS
Company Name: I t'IOJed Na1118, nv;:, #, Pennlt #, Etc.:
Report Mall Address: Contact Name, Phone, Fax, E-mail: Sampler Name If other than Contact:
Invoice Address: Invoice Contact & Phone #: r-u.-..nase vruer F. ELI Quote#:
Report Required For: POTWIWWTPO owa C A ~, L, SI ; I ~4 lU =~ ft D Notify ELI prior to RUSH Shipped by:
Other e 0 1 sample submittal for additional CD m GI .E>i'~ charges and scheduling Cooler ID(S)
Special Report Fonnats -EU must be notified prior to ..!!I UJ :>I GI
sample submittal for the following: 5~:26 C ~ Comments:
,0 < ~ >, w ~ Receipt Temp
NELAC0 A2LAD Level 1vO J: t:. 0 ,~ !! (.) ... t:. oc '-F-Om C 'Cl
Other jl .91flll.S! ~ I I Custody Seal Y N E ""S llll
EDD/EDT O Format ::, E GI lntad YN z r,J 3:1 < F ~ w ii Signature YN
:i: SAMPLE IDENTIFICATION Collection Collection w I II) Match
{Name, location, Interval, etc.) Date Tune MATRIX en ~ Lab ID
1 >.
2 ~
3 -111
4 U) -,.
5 >
6 ~
7 ~
a ~
9 -m
10 ~
Custody RallnqJilhed by (plnl~ Dalll/l1mO: ~ -by(pdnQ: DolalT1me: Sigrlallft;
Record Rellnqulshed by (pllnl~ OaW1ino: MUST be Slgnal,.n: Rac:elvedb¥(pml); Dlll.rTlme: 5'gnatllta:
Signed LABORATORY USE ONLY
SamnlA Ols"""""1: Relum to cUent Lab Dis""""": Sample Type: # of frac:tlona
Ir: -q,tatn circumstances, samples submitted ta EMfVY Laboratorlas, Inc:. may ~.~-·~ to other caitlfled laboratories In order to complete the analyal• ntq11-~.
. . This serves aa notlc:e of thl1 poalblllty. All sub-ci, J!, data wUI be c:learly notated on your analytical report , ;
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(_ ·t,.~NERGYFUELS
REVISIONS Project: WHITE MESA MILL
Date: By: County: San Juan State: Utah
Location:.
FIGURE 1
T37S
T38S
N
Ii~
J
c::JTownship and Range
C]Section
Coordinate System: NAD t----t---1
1983 StatePlane Utah
SOIL MONITORING LOCATIONS
South FIPS 4303 Feet Author: areither Date: 12/2/2014 Drafted By: areither
White Mesa Mill -Standard Operating Procedures
Book# 11: Environmental Protection Manual, Section 4.2
VEGETATION MONITORING
PART I VEGETATION MONITORING PLAN
1.0 VEGETATION MONITORING PLAN
Date: 11/14 Revision: EFR-3
Page 1 of 4
Vegetation is sampled in early spring, late spring, and late fall at three locations around the
Mill. These locations are: Northeast Area (near BHV-1), Northwest Area (Yi mile west of
BHV-1) and the Southwest Area (West ofBHV-4 and south off Cell 3).
2.0 QUALITY ASSURANCE
Quality assurance for vegetation monitoring is based on the contract laboratory's quality
controls such as duplicates, blanks, standard percent recovery, and spike percent recovery.
The laboratory will also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides
4.14 and 4.15 when analyzing the vegetation samples. The laboratory is committed to meet
the LLD values for radionuclides addressed in these guidelines and will perform re-runs on
all samples not meeting these limits.
3.0 ANALYTICAL REQUIREMENTS
Each vegetation sample will be analyzed for Ra-226, U-Nat, Th-232, and Pb-210
radionuclide concentrations. Results will be expressed in units of picocuries per gram (pCi/g)
or micro curies per kilogram (µci/kg), on a wet basis.
PART II VEGETATION MONITORING ST AND ARD OPERA TING PROCEDURES
1.0 VEGETATION SAMPLING
1.1 Equipment
Equipment used for vegetation sampling is as follows:
1. Scissors
2. Large plastic sample bags
1.2 Vegetation Sampling Procedure
Vegetation samples are collected and removed at the surface with scissors at each sampling
location. The vegetation sample is enclosed in a large plastic bag. Each sample will be
weighed upon return to the office and must weigh at least three kilograms in order for the
(
White Mesa Mill -Standard Operating Procedures Date: 11/14 Revision: EFR-3
Page 2 of4 Book #11: Environmental Protection Manual, Section 4.2
2.0
2.1
laboratory to meet the required LLD values outlined in U.S. NRC Regulatory Guide 4.14. In
addition, as vegetation samples are collected efforts will be made to minimize the amount of
soil in the samples. The sample bag is then labeled (see Section 2.1 ).
SAMPLING QUALITY ASSURANCE
Sample Labeling
All sample labels must be filled out in waterproof ink and numbered. The date, time,
sampler's initials, and the sample location will be completed at the time the sample is
collected. The following information will be included on the label:
1. Project and facility.
2. Sampler's company affiliation.
3. Date and time of sample collection.
4. Sampler's initials.
5. Sample location.
6. Weight of sample.
7. Requested analytical parameters.
2.2 Sample Chain-of-Custody
During sampling activities, traceability of the sample must be maintained upon sample
collection until the laboratory data is issued. Information on the custody, handling, transfer,
and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The
sampler is responsible for filling out the COC form. The COC form will be signed by the
sampler when the sampler relinquishes the samples to anyone else. A COC form is to be
completed for each set of samples placed in a shipping container and is to include the
following:
1. Sampler's name.
2. Date and time of collection.
3. Sample location.
4. Sample type.
5. Analysis requested.
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
6. Signatures of persons releasing custody.
Date: 1 l/14 Revision: EFR-3
Page3of4
7. Signatures of persons accepting custody, dates, and times.
Copies of the COC forms and all custody documentation when received will be retained in
appropriate files at the Mill. The original COC form remains with the samples until analysis of the
samples. After sample analysis, the COC form will be sent to the Environmental Department along
with the analyses.
2.3 Sample Handling and Shipping
Sample bags will be packaged in large shipping boxes and transported to the contract
laboratory. COC forms will be placed inside a sealed bag and placed inside the shipping
box.
2.4 Record Keeping
All vegetation sampling data will be retained in a file. When analytical data becomes
available, the data is entered into a computer file and retained in the files. All laboratory
analytical data is stored in the vegetation files after the data has been entered into the
computer file.
3.0 ANALYTICAL QUALITY ASSURANCE
3.1 Data Validation and QC Review
Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in
results noted and investigated. Appropriate measures to confirm or disaffirm results will be
pursued, such as laboratory conversation, analytical sample rerun, or trend analysis.
3.2 Quality Assurance and Data Validation
I
The contract laboratory will prepare a copy of and retain all analytical and QC
documentation. The laboratory will provide the Mill with paper copies of the following in
each data package, in accordance with QA objectives for the Surface Soil QA Project Plan:
1. COC forms
2. Cover sheets with comments
3. Narrative
4. Samples analyzed
5. Reporting limits and LLD values for analytes
6. Analytical results of QC samples
The data reduction and laboratory review will be documented, signed, and dated by the
(
White Mesa Mill -Standard Operating Procedures Date: 11/14 Revision: EFR-3
Page 4 of 4 Book #11: Environmental Protection Manual, Section 4.2
3.3
contract laboratory analyst.
Corrective Action
Corrective action will be taken for any deficiencies or deviations noted in the procedures or
anomalous results, such as but not limited to additional sample collection, sample re-run,
laboratory inquires, or other actions as appropriate.
White Mesa Mill -Standard Operating Procedures Date: 08/14 Revision: EFR-3
Page 1 of2 Book #11 : Environmental Protection Manual, SOP Section 4.3
1.
1.1
EXTERNAL GAMMA MONITORING PLAN
AND STANDARD OPERA TING PROCEDURES
EXTERNAL GAMMA MONITORING PLAN
Locations and Frequency of Monitoring
External gamma measurements are taken over a quarterly interval for the twelve months of the
year at all BHV locations and selected areas around the mill site (see Attachment #1 for those
locations).
1.2 Quality Assurance
Quality assurance for external gamma measurements consists of:
1.3
a) Monitoring the container locations to ensure the Optically Stimulated Luminescence
dosimeters (OSLs) shave not been lost;
b) Ensuring that all containers are present when receiving or shipping to Landauer; and
c) Reviewing Landauer data for consistency and data transportation.
Analytical Requirements
Values reported are in millirems per week average for the monitor period (supplied by Landauer)
along with a counting error term. The counting error term is calculated by:
1.4
1.5
[(sample 2 sigma)-(control mrem/week)] / (#weeks)
STANDARD OPERATING PROCEDURES
Equipment
External gamma is monitored at the ambient air sampling sites and other selected areas around
the mill site, using OSL badges from Landauer, Inc., or the equivalent.
1.6 Monitoring Methodology
(
White Mesa Mill -Standard Operating Procedures Date: 08/14 Revision: EFR-3
Page 2 of2 Book #11: Environmental Protection Manual, SOP Section 4.3
1.7
a) The containers are mounted approximately one meter above ground plane at each site
with one container per site.
b) The containers loaded with OSLs are received the first of each quarter from Landauer
and exchanged with those in the field.
c) A background OSL is stored in the Administration Vault as a transportation control.
d) The OSLs are returned to Landauer for processing.
Record Keeping
Data maintained in record form for external gamma is:
C a) Sample period;
b) Sample location; and
c) External gamma levels for total radiation.
~l'."H[l.,Uc.:."'J i ' ' ~ ,•,--
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II
O~L GAMMrADW"O= , ~ l\it>NlTOlUNG LOCA~N
W10 : MESA MILL
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. Lucptl~n oJ Mo~tor,, _ )1adg~ -1:.I:... -~ •, ' ' .. ·-·""'
Control Administration Vault
1 V20 5 Control Room
2 BHV-6
3 Ore Stor. -Barrel Area
4 Vanadium Precip.Area
5 Yellowcake Drying Area
6 Leach
7 SAG Mill Control Room
8 Yellowcake Precip.
9 Central Control Room
10 Trommel Screen ( ore pad)
11 North East Comer Ore Pad
12 Met. Lab
13 Filter Press Room
14 BHV-1
15 BHV-2
16 BHV-3
17 BHV-4
18 BHV-5
19 SAG Mill
20 Tails
21 CCD
22 North SX
23 Administration Building
24 Admin Parking Lot
25 Yellowcake Packaging
26 Yellowcake Storage
27 Bucking Room
28 Mill Lunch Room
29 South SX
30 Mtce. Super.'s Office
31 Ore Feed Grizzly
32 Scalehouse
33 Sample Plant (OBS)
34 Front Gate
45 AF -Barrel Dump Station
(
··;,. •.. . ~ 'J "''· .. ,. ll4il'.ACBMEN!'f I --.:~\:. { .. , ,.
OSL @AMMA ENVJI«)~NT.U. MONff.0RlNG LOC~TfONS
WDITE M,EJA MiLt.
-~-' -
Jl_ad~e Un\ber Loi:a~n of Montt-011
'
46 AF Circuit -South
47 AF Circuit -North
51 North Control # 1
52 North Control # 2
53 CaF2 Barrel Dump Station -Operator Station
64 KF Barrel Dump Station
70 BHV-7
71 BHV-8
(
White Mesa Mill -Standard Operating Procedures Date: 06/201 I Revision: OUSA-2
Page I of5 Book# 11: Environmental Protection Manual, SOP Section 5.0
1.
I.I
SETTLEMENT MONITORING
STANDARD OPERA TING PROCEDURES
SETTLEMRNT MONITORING
Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) lo be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010), within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor
Poinls map (originally dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within 60 calendar days of completion of the intermediate cover at the designated locations. The
Settlement Monitor Points map will he updated as part of the installation of new monitors.
Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been
closed to further disposal pursuant to RML condition 10.5.A. Settlement monitors will be
installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of
each ISL disposal area, and then annually after that point. One Settlement Monitor will be
required for approximately every 22,500 square feel or 5,000 cubic yards of ISL material. These
monuments will be uniquely labeled to identify the specific ISL material.
For ISL source disposal areas or trenches completed before April I, 201 t, the required settlement
stands will be placed and the initial elevation survey completed prior to June l, 2011.
White Mesa Mill -Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Page 2 of5 Book fl 11: Environmental Protection Manual, SOP Section 5 .0
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate withal" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the P' inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. 'lbese devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
turned in to the RSO, or designee. The RSO, or dcsignee, will make same day notification to the
Corporate Compliance Director. Replacement and/or repairs to the damaged Settlement Monitor
and the surveying and documentation of changes due to the Settlement Monitor damage will be
completed within within 30 calendar days of the discovery of the damage to the Settlement
Monitor.
1.4
(i)
(ii)
(iii)
(iv)
(v)
(vi)
Monthly Surveying
The monthly survey wilJ be perfonned by the Mill's Radiation Safety
Officer or designce (the "Surveyor") with the assistance of another Mill
worker (the "Assistant");
The survey will be perfonned using a survey instrument accurate to 0.1
feet, such as a Sokkai No. 82 l, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
The reference points are known points established by a professiom1l
survey.
The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
Once in location, the surveyor will ensure that the survey instrument is
level by centering the bubble in the level gauge on the survey instrument;
The assistant will place the survey rod vertically on the reference point.
The assistant will ensure that the survey rod is vertical by gently rocking
the rod back and forth until the surveyor has established a level reading;
(
White Mesa Mill -Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Page 3 of5 Book Ill 1: Environmental Protection Manual, SOP Section 5 .0
1.5
1.5.1
(vii) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "reference point
reading"), which represents the number of feet the survey instrument is
reading above the reference point;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth witi] the Surveyor has
established a level reading;
(x) lbc surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading").
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
Monitoring and Maintenance of Settlement Monitors
Monitoring and Documentation of Condition of Devices
The Settlement Monitors wm be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
monthly by Environmental Department staff. Any observations will be recorded on the monthly
tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additkmally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
The foJlowing records and documents will be maintained by the Environmental Department
staff:
a) Monthly tailings inspection forms
White Mesa Mill -· Standard Operating Procedures Date: 06/20 I I Revision: DUSA-2
Page 4 of5 Book #11: Environmental Protection Manual, SOP Section 5.0
b) Data files of monthly and annual survey information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
c) Annual photographs documenting site conditions at each settlement monitor
t) Annual Review of Settlement Monitors by Utah Licensed Professional Engineer
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of envirorunental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device.
Based on the last monthly survey, prior to the damage, the replacement device wil1 be placed as
near as practical at the same elevation and in the same location from which the damaged device
was removed. Data from the new device will be correlated to data from the removed damaged
device as follows:
1.6
I. When a new device is installed, a Utah-Licensed I ..and Surveyor will survey and map the
location of the new device as well as that of the two nearest (undamaged) devices
adjacent to the new device.
2. If the survey indicates there has been Jess than 0.1 foot of vertical change since the last
monthly survey in the elevation of the undamaged devices, no adjustment will be made to
the survey data of the new device.
3. If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
4. Also, based on the last monthly survey, prior to the damage, if the elevation of the new
device is greater than +/-0.1 foot from that of the damaged device, then the replacement
device will be designated with a new number (such as "Cell 2W2-R", as the replacement
for damaged device "Cell 2W2"). Elevation data for the new device, and the date of
installation of the new device, will be recorded in the data file adjacent to the information
from the damaged device, with a notation that this device is a replacement for the
damaged device.
Performance Criteria and Data Validation
When the monthly data has been collected, the infonnation will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
difference of 0.1 foot between two consecutive months, then an investigation and possible
corrective actions will be taken as follows:
White Mesa Mill -Standard Operating Procedures
Book # I I: Environmental Protection Manual, SOP Section 5.0
Date: 06/2011 Revision: DUSA-2
Page 5 of5
1. Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7 days of discovery of the problem.
2. Document site conditions.
3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses,
burrowing animals, etc.).
4. Report this infonnation to the Executive Secretary within 30 calendar days for approval
and include in that notification the investigation steps, movement evaluation, and
corrective actions taken, if needed. This report wilJ also be maintained within the
Environmental Department records and will be submitted annually as part of the ATER
as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review, analyze, correct (as
needed), submit and certify the annual data in writing, including an explanation of the methods
and basis used for the review, analysis, and corrections including ongoing graphical updates for
the Settlement Monitors. For movements attributed to expected settlement of the tailings sands,
the review will include comments on the graphical presentation of the data, and an evaluation of
the previous, current and expected rates of ongoing settlement.
This infonnation will be maintained within the Environmental Department records and will be
submitted annually as part of the ATER as required by RML Condition J 2.3.
White Mesa Mill-Standard Operating Procedures Date: 12/13 Revision: EFR-4
Page I of 4 Book # 11: Environmental Protection Manual, SOP Section 5 .1
1.
1.1
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERA TING PROCEDURES
MOVEMENT (DISPLACEMENT) MONITORING
Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of movement (displacement) monitors that are placed along the constructed
dike portions of the tailings cells. All data collected for these purposes, as described below, will
be included in an Annual Technical Evaluation Report (ATER) to be submitted to the Executive
Secretary of the Utah Division of Radiation Control (the Executive Secretary) pursuant to
License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of new dike construction activities, Movement Monitors will be
installed and surveyed by a Utah-Licensed Land Surveyor. Movement monitors, at a minimum,
without regard to each dike longitudinal direction, will be installed in single straight lines for
each pertinent dike. The line for the movement monitors will change direction at each pertinent
dike intersection, but will run continuous along and on top of, all exterior exposed dikes
comprising the southern boundary of the tailing cells.
All new movement monitors (installed after June, 2010) will be surveyed and mapped by a Utah-
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed after June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.
On an annual basis, a Utah-Licensed Professional Engineer will review, analyze, correct, and
certify the semi-annual and annual data in writing, which will be submitted as part of the ATER
as required by RML License Condition 12.3.
1.3 Design of Settlement Monitors
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The movement monitor placement will be established by digging a hole in the desired location,
to minimize accidental damage to the monument including, but not limited to, vehicle and
construction traffic damage. A piece of rebar, 24 inches in length, will be driven into the hole.
The new monument will be set in line with the other movement monitors for the given dike. The
(
White Mesa Mill -Standard Operating Procedures Date: 12/13 Revision: EFR-4
Page 2 of4 Book #11: Environmental Protection Manual, SOP Section 5.1
hole will be back-filled and the top of the rebar will be at least 4-inches below surface grade.
Each monument will be individually tagged and numbered.
1.4
1.4.1
Monitoring and Maintenance of Movement Devices
Monitoring and Documentation of Condition of Devices
The movement monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented in the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The movement monitors will be installed in such a way to prevent damage by equipment. All
new movement monitors installed after June 2010 will be installed near the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out of the
pathway for maintenance activities and traffic. The movement monitors will be installed such
that the monument is at least 4-inches below the actual ground surface level, so the potential for
damage by equipment is further minimized. However, if a monument is disturbed, the
information will be immediately given to the Environmental Coordinator, or designee. The
Environmental Coordinator, or designee, will make notification to the Corporate Compliance
Director and replacement and/or repairs to the damaged movement monitor and the surveying
and documentation of changes will be completed within 30 calendar days of the discovery of the
damage. The general condition of the movement monitors will be evaluated on a monthly basis
and the inspection documented as a part of Monthly Tailings Inspection.
If any movement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device within
30 calendar-days of the discovery of the damage. The replacement device will be placed in the
same excavated hole from which the damaged device was removed. Data from the new device
will be correlated to data from the removed damaged device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the adjacent devices, it will be assumed that no damage had occurred to
the adjacent devices and the new device will be installed at the vertical and horizontal
coordinates of the device prior to the damage.
3. If the survey indicated 0.1 foot or greater of vertical or horizontal change, from the
previous measurement, to either of the adjacent devices, the procedures in Section 1.6
will be implemented.
White Mesa Mill -Standard Operating Procedures Date: 12/13 Revision: EFR-4
Page 3 of4 Book #11: Environmental Protection Manual, SOP Section 5.1
1.5 Documentation
The Utah-Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors in relationship to the tailings cells. A
brief summary of work and analytical data will be provided in a written report by the Utah-
Licensed Land Surveyor. Vertical or horizontal movements of 0.1 foot or greater will be
evaluated according to the procedure described in section 1.6
The list ofrecords generated as a result of this SOP includes:
• Utah-Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
• ATER
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report
All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.
1.6 Performance Criteria and Data Validation
The data will be reviewed for any errors and or major changes in the vertical or horizontal
movement on the movement monitors. If there is a difference of 0.1 foot or greater between two
consecutive measurements, then the corrective actions will be taken as follows:
1. Resurvey the movement monitor that shows vertical or horizontal movement of 0.1 foot
or more, within 30 days of discovery of the problem.
2. Document site conditions.
3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
4. Report this information to the Executive Secretary within 45 calendar days for approval
and include in that notification the investigation steps, movement evaluation and
corrective actions taken. This report will be also be maintained with the Environmental
Department records and will be submitted as part of the ATER as required by RML
Condition 12.3.
Movement monitors that show vertical or horizontal movement of 0.2 foot or greater for two
consecutive monitoring periods may be subject to accelerated monitoring at a frequency and in a
manner approved by the Executive Secretary.
On an annual basis, a Utah-Licensed Professional Engineer will review, analyze, correct, certify
and submit the semi-annual and annual data in writing, including an explanation of the methods
and basis used for the review, analysis, and corrections including ongoing graphical updates for
the movement monitors. Movement data will be presented in a tabular format, showing all
previous annual and semi-annual data, for ease in evaluating the total record of movement
measurements. Data from all previous measurements will be compared against the current
measurement and an evaluation made as to any long-term trends which may be apparent.
(
White Mesa Mill -Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 12/13 Revision: EFR-4
Page4 of4
Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah-Registered Professional Engineer. This information
will be maintained with the Environmental Department records and will be submitted as part of
the ATER as required by RML License Condition 12.3, along with a description of any
corrective actions performed.
ALARA PROGRAM
Standard Operating Procedures Book 12
Energy Fuels Resources (USA) Inc.
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
White Mesa Mill
Book 12, ALARA Program
1. ALARA PHILOSOPHY
1.1. Licensee Management
1.1.1 Management Commitment
09/19 Revision EFR-4
Page 1 of 20
Energy Fuels Resources (USA) Inc. ("Energy Fuels") is committed to maintammg
occupational exposures of personnel, contractors and visitors and effluent releases at the
White Mesa Mill (the "Mill") as low as is reasonably achievable ("ALARA").
In order to achieve this objective, Energy Fuels and its management provide a strong
commitment to and continuing support for the development and implementation of the
radiation protection and ALARA Programs at the Mill.
The program that Energy Fuels utilizes to ensure that worker exposures and effluent
releases are ALARA is the sum total of:
• All the design barriers, operating procedures, management controls, and personnel
experience and expertise built into the Mill, including the equipment to control
and prevent effluent releases and to sample and monitor the working environment.
Potential releases, both in the Mill and to the environment, are held within the
performance capability of the control equipment through regular inspection and
maintenance of the equipment;
• Extensive programs to monitor both the work environment and releases from the
Mill are conducted. These include monitoring of the work environment;
personnel monitoring programs; and Mill area monitoring programs, which
include both external radiation surveys and airborne radionuclide monitoring;
• Bioassay programs;
• Contamination control programs;
• The qualifications of the staff. All management personnel involved with plant
radiation protection have extensive experience in similar positions, and are trained
to use appropriate technology.
Energy Fuels' commitment to this ALARA objective is supported by the trammg
program conducted for facility personnel, continuous reviews of radiation,
environmental, and industrial hygiene protection policies and procedures, and the
adoption of procedures and equipment that have been demonstrated to reduce
occupational exposures and releases to the environment.
This ALARA program is to be achieved through systematic worker monitoring and an
on-going review process between the radiation protection staff and plant operation
White Mesa Mill
Book 12, ALARA Program
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Page 2 of 17
management with secondary audits performed by corporate environmental and health and
safety personnel.
1.1.2 ALARA Committee
Energy Fuels has established an ALARA Committee to review all matters relating to the
ALARA Program. The ALARA Committee meets as required, but generally at least
once per quarter.
The members of the ALARA Committee shall include at least the following:
• The Mill's Radiation Safety Officer ("RSO");
• The Mill Manager;
• Corporate management personnel in charge of Mill operations;
• Corporate management personnel in charge of environmental and regulatory
matters.
All Mill matters that impact or could potentially impact public health, safety or the
environment are reviewed by the ALARA Committee to ensure that exposures to the
public, workers and the environment are ALARA.
1.1.3 foformation and Policy Statements
Energy Fuels provides information and policy statements to workers, contractors and
visitors as necessary. The underlying philosophy that radiation exposure to workers, the
public and to the environment will be maintained ALARA is a fundamental practice of all
Mill operations, and this concept is clearly explained to all workers and contractor
personnel during Mill orientation and worker training sessions.
It is the policy of Energy Fuels that occupational exposure records of each worker at the
Mill are readily available for review by the worker. The RSO and his staff will review
and discuss any aspect of radiation safety at any time.
1.1.4 ALARA Audit
Mill License condition 11.6 requires that Energy Fuels, as Licensee, perform an annual
ALARA audit of the radiation safety program at the Mill, that reviews procedural and
operational efforts to maintain exposures ALARA, in accordance with Regulatory Guide
8.31. This requirement is implemented through Section 2.3.5 of this Program. The
ALARA audit is performed each year by a member of the corporate environmental and
regulatory compliance management personnel of the Licensee and an independent
specialist. The results of this annual audit are summarized in the annual ALARA Report
White Mesa Mill
Book 12, ALARA Program
09/19 Revision EFR-4
Page 3 of 17
that is provided to the ALARA Committee for review, and maintained on file at the Mill
for inspection.
1.1.5 Continuing Management Evaluation
Through the ALARA Committee, Energy Fuels continually evaluates the Mill's radiation
safety (health physics) and environmental protection programs, including their staff and
whether or not adequate resources are allocated to the programs. Any issues relating to
radiation safety or environmental protection are reviewed by the ALARA Committee as
they arise. The ALARA Committee takes a pro-active role in scheduling periodic
reviews of various aspects of the Mill's radiation safety program to help ensure that any
potential areas of concern are identified and dealt with before a problem can arise.
1.1.6 Briefings and Training in Radiation Safety
Appropriate briefings and training in radiation safety, including ALARA concepts are
given to all uranium mill workers, both to new hires and to current Mill employees, as
part of their 24-hour training requirements under the Mine Health and Safety
Administration ("MSHA") for newly hired employees, and as part of their 8-hour
refresher training for all existing employees. In addition, appropriate training is provided
to contractors and visitors, as required. See Sections 2.5.8 and 2.5.9 below for further
details.
1.2. Radiation Safety Officer
The RSO has primary responsibility for the technical adequacy and correctness of the
radiation protection and ALARA program and has continuing responsibility for
surveillance and supervisory action in the enforcement of the program. The RSO reports
directly to the Mill Manager, but also has the authority to report to the President and
CEO, the Chief Operating Officer or to the Chief Financial Officer, General Counsel and
Corporate Secretary of Energy Fuels if he feels the need to do so in fulfilling his
responsibilities.
Specifically, the RSO's authority and responsibilities include the following:
• Major responsibility for the development and administration of the radiation
protection and ALARA program;
• Sufficient authority to enforce regulations and administrative policies that affect
any aspect of the radiological protection program, including the following:
o the authority to order cessation, postponement or modification of any
operation at the Mill that he deems violates the radiation protection
program, industrial hygiene or environmental procedures or standards, or
the ALARA program. The RSO is directly responsible for developing,
implementing, monitoring and reporting activities that ensure that the Mill
White Mesa Mill
Book 12, ALARA Program
09/19 Revision EFR-4
Page 4 of 17
radiation protection program, industrial hygiene practices and
environmental protection program meet applicable standards; and
o the authority to direct and participate in an investigation of any
circumstances of unusual exposures. Such investigation will include
recommended remedial action and documentation of corrective action;
• Responsibility to review and approve plans for new equipment, process changes,
Mill maintenance work, or changes in operating procedures, whether alone or as a
member of the Mill's SERP committee, to ensure that the plans do not adversely
affect the radiation protection program, or result in unsafe radiation safety,
industrial hygiene or environmental practices; and
• Responsibility to ensure that adequate equipment, supplies and laboratory
facilities are available, are well maintained in proper working order, and are used
properly in order to monitor relative attainment of the ALARA objective. To the
extent the Mill does not have adequate laboratory facilities or it would be
preferable to utilize an independent certified laboratory, the RSO has the authority
to utilize such an independent certified laboratory.
Demonstration of improvements in radiation safety, or in modifications sought,
considered, or implemented where reasonably achievable is the combined responsibility
of the RSO, Mill Manager and the ALARA Committee.
1.3. Uranium Recovery Workers
In order to better ensure compliance with the Mill's radiation protection and ALARA
program, all workers at the Mill are responsible for the following:
1.3.1 Adhering to all Procedures
Adoption, approval, and adherence to the designated policies and recommendations is the
assigned responsibility of Mill management. Mill management is responsible for all
aspects of the Mill operation, including the onsite radiation protection program, and is
responsible for approval and adherence to procedures for operation of the Mill in
reference to the ALARA concept.
Mill workers are responsible for adhering to all rules, notices, and operating procedures
for radiation safety established by Energy Fuels management and the RSO. All Mill
employees are advised of this responsibility during their annual refresher training and
during specific training relating to the job tasks associated with the issuance of specific
Radiation Work Permits ("RWPs").
1.3.2 Reporting Promptly to the RSO and Mill Management
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Book 12, ALARA Program
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Page 5 of 17
All workers are required to report promptly to the RSO, or Mill management, equipment
malfunctions or violations of standard practices or procedures that could result in
increased radiological hazard to any individual. This requirement is specifically
delineated in each standard operating procedure for all operating circuits at the Mill and
is emphasized in employee training sessions.
In addition, Mill supervisory personnel are responsible for notification to the RSO
whenever activities are planned or instigated that may involve a potential significant
increase in exposure to airborne radioactivity or significant increase in extended gamma
radiation.
1.3.3 Workers are Responsible for Suggesting Improvements
All workers are responsible for suggesting to the RSO or Mill management any
improvements for the radiation protection, environmental protection and ALARA
programs that arise from performing their jobs.
2. HEALTH PHYSICS ORGANIZATION AND ADMINISTRATIVE
PROCEDURES
2.1. Health Physics Authorities and Responsibilities
2.1.1 Health Physics Authorities and Responsibilities
The RSO is responsible for conducting the health physics program and for assisting the
Mill Manager in ensuring compliance with applicable regulations and license conditions
applicable to worker health protection. The RSO reports directly to the Mill Manager,
but also has the authority to report to the President and CEO, the Chief Operating Officer
or to the Chief Financial Officer, General Counsel and Corporate Secretaryof Energy
Fuels if he feels the need to do so in fulfilling his responsibilities.
In addition to the responsibilities and authorities delineated in Section 1.2 above, the
RSO has the following specific authorities and responsibilities:
• Directly responsible for supervising the health physics technicians, for overseeing
the day-to-day operation of the health physics program, and for ensuring that
records required by the State of Utah are maintained; and
• The responsibility and authority, through appropriate line management, to
suspend, postpone, or modify any work activity that is unsafe or potentially a
violation of the State of Utah's regulations or license conditions, including the
ALARA program.
The RSO may have other safety related duties, such as responsibility for programs of
industrial hygiene and fire and safety, but will have no direct production-related
responsibility.
White Mesa Mill
Book 12, ALARA Program
2.2. Operating Procedures
2.2.1 Standard Operating Prncedure
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Page 6 of 17
The Mill is required to maintain written standard operating procedures or Radiation Work
Permits ("RWPs") for all activities that involve handling, processing, or storing
radioactive materials, as well as health physics monitoring, sampling, analysis and
instrument calibration.
All such procedures include consideration of pertinent radiation safety practices, to the
extent not covered in the Radiation Protection Manual, Respiratory Protection Manual or
Environmental Protection Manual.
2.2.2 Policy-for Eating -Re tricted Area
Smoking is not permitted anywhere within the Mill's Restricted Area. Eating lunches or
snacks, or chewing tobacco is not allowed within the Restricted Area of the Mill except
for those areas so designated by the RSO. Such noted activity, as observed, results in a
supervisory review of employee actions, documentation of the incident, and retraining by
the Radiation Safety Staff. Repeated occurrences shall be cause for dismissal. This
policy is in effect to ensure that radiation and uranium ingestion exposures to Mill
workers are maintained ALARA.
The areas of the administrative office building located outside of the Mill's restricted
area, are designated as eating areas. The Restricted Area designated eating areas, are as
designated by the RSO from time to time. Each designated eating area must satisfy the
following criteria:
• Located in an area where work with uranium is not performed and there is little
likelihood of contamination;
• Wash facilities are located close by to allow workers to wash their hands etc. prior
to entering the designated eating area;
• Scanning machines are placed at each entry into the designated eating area; and
• Each worker entering a designated eating area must perform and record a personal
alpha scan in the same manner as if the worker were leaving the Mill's restricted
area, and must be free of contamination prior to entering the designated eating
area.
The designated eating areas are routinely monitored for alpha and beta-gamma
contamination as provided in the Radiation Protection Manual.
White Mesa Mill
Book 12, ALARA Program
2.2.3 Up-to-Date Copy of All Procedures Kept Acces ible
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Page 7 of 17
An up-to-date copy of each written procedure, including accident response and
radiological fire protection plans, are kept accessible to all workers under the Mill's
Document Control System.
2.2.4 Review by RSO and Documentation of Revisions
All written procedures involving radioactive material control have been compiled in a
manual (the SOP binders) that allows documentation of each revision and its date. In
accordance with the Mill's Radioactive Materials License condition 9.6, all written SOPs
for both operational and non-operational activities shall be reviewed and approved in
writing by the RSO before implementation and whenever a change in procedure is
proposed to ensure that proper radiation protection principles are being applied. In
addition, the Mill's Radioactive Materials License requires that the RSO shall perform a
documented review of all existing operating procedures at least annually, to ensure the
procedures do not violate any newly established radiation protection practices. The Mill
Manager also performs a documented review of all existing operating procedures at least
annually.
The Mill's Document Control System requires that the Master Control List (MCL) be
updated every time an SOP is revised or added. The revision date of the MCL is also
updated. A copy of the MCL is included in the front of every SOP book.
2.2.5 Radiation Work Permits
An RWP is designed to provide a job procedure plan to prevent excessive exposure when
any non-routine work is performed at the Mill.
When RWPs are issued, the Mill maintains employee exposure ALARA through
engineering controls and established management practices or by the use of respiratory
protection if no other means of controls are practical. Verification of the effectiveness of
these practices is monitored through various radiological samplings, including breathing
zone sampling, area airborne sampling, bioassay sampling, etc.
The procedure for issuance of RWPs is set out in Section 5.0 of the Mill's Radiation
Protection Manual.
2.3. Surveillance: Audits and Inspections
Daily, weekly, and monthly inspections of worker health protection practices serves to
provide management with the information necessary to conduct this ALARA program.
During non-operational periods, radiological monitoring may or may not be reduced in
frequency, depending on previous radiological trends or anticipated exposure potential.
Often such monitoring is conducted at the same frequency as but at fewer locations than
for operational periods.
White Mesa Mill
Book 12, ALARA Program
2.3.1 Daily Inspections
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Page 8 of 17
The RSO or designee conducts a daily walk-through (visual) inspection of all work and
storage areas of the Mill to ensure proper implementation of good radiation safety
procedures, including good housekeeping practices that would minimize unnecessary
contamination. The inspection includes observations of housekeeping practices,
ventilation equipment conditions, employee observance of radiation protection signs and
policies, and maintenance and operating conditions present during the inspection. The
inspection will include all work, storage, and lunchroom areas of the facility. These
inspections are documented and on file in the Radiation Safety Office. A copy of the
Daily Inspection of the Mill form is attached as Appendix A. If not included on the
inspection form, a report to the RSO on any items of non-compliance with operating
procedures, license requirements, or safety practices affecting radiological safety is also
made.
2.3.2 Weekly Inspections
Routine weekly inspections of all areas of the Mill are made by the RSO and Shift
Foremen or designees, to observe general radiation control practices and review required
changes in procedures and equipment. Particular attention is focused on areas where
potential exposures to personnel might exist and in areas of operation or locations where
contamination is evident. A copy of the Weekly Mill Inspection Report form is attached
as Appendix B.
In addition, the RSO, or his designee, will attend the routine production meeting or will
review the daily shift logs and work orders to determine that all jobs and operations
having a potential to exposing personnel to uranium were evaluated, either through a
properly completed RWP or authorized written job operating or maintenance procedure,
or were approved by the RSO, his staff, or designee prior to initiation of the work.
2.3.3 Documentation of Problems and Violations
Problems observed during all inspections are noted in writing in an inspection logbook,
inspection forms, or other retrievable record format. The entries are dated, signed, and
maintained on file for at least one year.
The RSO reviews all violations of radiation safety procedures or other potentially
hazardous problems with the Mill Manager or other Mill workers who have authority to
correct the problem.
2.3.4 Monthly Reports
At least monthly the RSO reviews the results of daily and weekly inspections, including a
review of all monitoring and exposure data for the month and provides to the Mill
Manager, and any other Mill department heads designated by the Mill Manager, for their
review a monthly report containing a written summary of the month's significant worker
White Mesa Mill
Book 12, ALARA Program
09/19 Revision EFR-4
Page 9 of 17
protection activities. The Monthly Report should contain, at a minimum, the following
information:
• a summary of the most recent personnel exposure data, including bioassays and
time-weighted calculations;
• a summary of all pertinent radiation survey records;
• a discussion of any trends or deviations from the radiation protection and ALARA
program, including an evaluation of the adequacy of the implementation of
license conditions regarding radiation protection and ALARA; and
• a description of unresolved problems and the proposed corrective measures.
Emphasis is placed upon maintaining activities ALARA.
These monthly reports are maintained on file and readily accessible for at least five years.
The RSO and Radiation Staff perform routine unannounced walk-through inspections of
all work and storage areas to ensure the radiation safety program is working as required.
Appropriate actions are taken promptly by the RSO to correct any problems or
deficiencies noted during inspections by the RSO and his designees. When unusual
exposures have occurred, the RSO will direst and participate in an investigation to
determine the cause, and the remedial actions necessary. Mill operations management
will decide on action to be taken, and the RSO will document the resultant action for later
review. These are reviewed by Mill operations management on a monthly basis.
2.3.5 Radfation Protection and ALARA Program Audit
An annual audit of the radiation protection, environmental protection and ALARA
program is performed, and a written report on the audit is submitted to the ALARA
Committee for review and action, if warranted.
All members of the ALARA audit team should be knowledgeable concerning the
radiation protection program at the Mill. In addition, one member of the team should be
experienced in the operational aspects of the Mill's radiation protection practices. One or
more of the audit team will be independent specialists. An example of an audit team is a
member of corporate environmental health and safety together with an independent
expert in radiation safety practices at uranium mills. The RSO should accompany the
team but should not be a member.
a) Radiation Protection Component of ALARA Audit
The audit report should summarize the following data relating to radiation protection at
the Mill:
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(i) Worker exposure records (external and time-weighted calculations);
(ii) Bioassay results;
(iii) Inspection log entries and summary reports of daily, weekly, and monthly
inspections;
(iv) Documented training program activities;
(v) Radiation safety meeting reports;
(vi) Radiological survey and sampling data;
(vii) Reports on overexposure of workers submitted to the Director of the
Division of Waste Management and Radiation Control ("DWMRC") or
MSHA; and
(viii) Operating procedures that were reviewed during this time period.
The audit report should specifically discuss the following:
• Trends in personnel exposures for identifiable categories of workers and types of
operational activities;
• Whether equipment for exposure control is being properly used, maintained, and
inspected; and
• Recommendations on ways to further reduce personnel exposures from uranium
and its daughters.
b) Environmental Component of ALARA Audit
Utah Administrative Code R313-15-101 (2) provides that the Licensee shall use, to the
extent practicable, procedures and engineering controls based upon sound radiation
protection principles to achieve occupational doses and doses to members of the public
that are ALARA. As a result, in addition to occupational data, the annual ALARA audit
also addresses all environmental monitoring data for the year.
The audit team will review during the annual ALARA audit the following items relating
to environmental matters at the Mill:
(i) Documented inspection reports;
(ii) Environmental radiological effluent and monitoring data, including
quality assurance data as necessary; and
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(iii) Reviews of operating and monitoring procedures completed during this
time period.
(iv) The audit specifically addresses:
• Trends in environmental radiological effluent and monitoring data;
• Performance of effluent control equipment; and.
• Administrative controls and policies and ALARA management of
retention systems and release.
c) Timing of AIARA Audit and Review of Audit Report
The ALARA audit for a particular calendar year will be performed as soon as reasonably
practicable in the following calendar year as all of the monitoring data and dose
calculations for the subject calendar year become available, and will be performed
generally in the first or second quarter of the next calendar year and will be completed by
April 30 of each year.
The ALARA report is reviewed by the ALARA Committee. The ALARA Committee
will make a determination whether or not any recommendations in the ALARA audit
report require follow-up or further actions. It will be the responsibility of the Mill
Manager to ensure that the decisions of the ALARA Committee are implemented.
The ALARA audit reports are maintained on file at the Mill.
2.4. Technical Qualifications of Health Physics Staff
2.4.1 Radiation Safety Officer
The RSO should have the level of education, training and experience recommended in
NRC Reg. Guide 8.31.
2.4.2 Radiation Safety Technicians
When the Mill is in full-scale operations, in addition to the RSO, there should be a
minimum of one full-time radiation safety (health physics) technician. The radiation
safety technician(s) should have the level of education, training and experience
recommended in NRC Reg. Guide 8.31. The radiation safety technician(s) should
demonstrate a working knowledge of the proper operation of health physics instruments
used in the Mill, surveying and sampling techniques, and personnel dosimetry
requirements.
White Mesa Mill
Book 12, ALARA Program
2.5. Radiation Safety Training
2.5.1 Periodic Radiation Training for Lhe RSO
The RSO is required to have refresher training once every two years.
2.5.2 Radiation Training for New Employees
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Page 12 of 17
All new workers are trained by means of an established course on the inherent risks of
exposure to radiation and the fundamentals of protection against exposure to uranium and
its daughters before beginning their jobs. This training program, which is set out in the
Mill's Training Program, takes 24 hours for inexperienced personnel and 8 hours for
experienced personnel, of which 4 hours is devoted to radiation training. The topics
listed in 2.5(1) to (6) of Reg Guide 8.31 are included in the Mill's Training Program. In
all cases, the training will be commensurate with the risks and hazards of the task.
A written or oral test with questions directly relevant to the principles of radiation safety
and health protection in uranium milling is covered in the training course given to each
worker.
The instructor reviews the test results with each worker; workers who fail the test are
retested after items of confusion are discussed. The tests and results are maintained on
file.
2.5.3 Hazard Training for New Employees
All new workers receive hazard training in accordance with the Mill's MSHA training
plan for new hires. This training takes 24 hours, which includes the 4 hour radiation
training referred to in section 2.5.2 above.
2.5.4 Radiation Safety Refre her Training
All Mill workers receive eight-hour refresher training in accordance with the Mill's
MSHA training plan each year. This training includes annual radiation safety training,
including relevant information that has become available during the past year, a review of
safety problems that have arisen during the year, changes in regulations and license
conditions, exposure trends and other current topics. Some of these topics are discussed
at various radiation safety meetings that are held during the year. The radiation refresher
training is set out in the Mill's Training Program. As part of this training, all workers are
required to retake the written test required of new hires.
A list of all workers who completed the retraining and copies of the written tests are
maintained on file at the Mill.
White Mesa Mill
Book 12, ALARA Program
2.5.5 Radiation Safety Meeting
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In addition to the 8-hour refresher training, relevant information that has become
available, a review of safety problems that have arisen and changes in regulations and
license conditions are discussed as they arise during radiation safety meetings. These
meetings are generally held once per month when the Mill is operating, and once per
quarter when the Mill is not operating.
2.5.6 Specialized Inst.ruction
All new workers, including supervisors, are given specialized instruction on the health
and radiation safety aspect of the specific job they will perform. All workers receive the
24-hour initial radiation and safety training when first employed. In addition, when the
employees get to their jobs, their supervisor gives them specific on-the-job training. This
training typically does not cover radiation protection, to the extent it is already covered in
the initial training. If specific radiation protection issues exist for any particular job, or
new job (such as may result from a new alternate feed material), such issues would
typically be addressed in a new procedure, RWP or Safe Work Permit ("SWP"). The
RSO will determine any new procedures or actions that are required in order to ensure
radiation protection is ALARA. If the job is a one-time type of job, then an RWP or
SWP will typically be employed. If the job is to be a recurring job, then a new procedure
may be adopted, or an RWP will initially be adopted, followed by a new procedure.
Specific radiation protection training is given on any new procedure or permit either at a
regularly scheduled radiation and safety meeting or at a radiation and safety meeting held
for the affected employees.
2.5.7 Acknowledgement of Training
All employees sign an attendance sheet for each training session. This sheet is dated and
is co-signed by the instructor.
2.5.8 Contractors
Contractors having work assignments in the Mill are given appropriate training and safety
instruction. Contractor workers who will perform work on heavily contaminated
equipment will receive the same training and radiation safety instruction normally
required of all permanent workers. Only job-specific radiation safety instruction is given
for contract workers who have previously received full training on prior work
assignments at the Mill or have evidence of recent and relevant radiation safety training
elsewhere. Basic radiation training is given verbally, unless more specific training is
required, which would be addressed on a case-by-case basis. Contractors are provided
with an instructional packet and are required to acknowledge their acceptance thereof.
White Mesa Mill
Book 12, ALARA Program
2.5.9 Visitors
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All visitors who have not received training are escorted by someone properly trained and
knowledgeable about the hazards of the Mill, or have received instructions specifically on
what they should do to avoid possible radiological and non-radiological hazards in the
areas of the Mill they will be visiting. Typically, all visitors are escorted by trained
personnel. In addition, the RSO or a member of his staff will also provide a short safety
briefing about possible hazards that exist at the Mill before any visitor, who is
accompanied by trained personnel, is permitted to enter the Mill's restricted area.
2.6. Surveys
2.6.1
The RSO and radiation safety office staff are responsible for performing all routine and
special radiation surveys as required by license conditions and by R313-15, in accordance
with NRC Regulatory Guide 8.30 (Health Physics Surveys in Uranium Mills). Under
certain SOPs (for example the Intermodal Container Acceptance, Handling & Release,
No. PBL-2 Rev. No. R-3 and End Dump Trailer Acceptance, Handling & Release, PBL-
9, Rev. No R-0), the RSO is given authority to delegate release surveys to other qualified
Mill personnel.
Radiological surveys are performed as set out in the Mill's Radiation Protection Manual
and Environmental Protection Manual.
2.7. Respiratory Protection
2. 7 .1 Responsibility for the Re piratory Protection Program
The RSO is responsible for the implementation and direct control of the respiratory
protection program. This program is set out in the Mill's Respiratory Protection Program
("RPP").
2.7.2 Adequate Supplie
It is the responsibility of the RSO to ensure that the Mill maintains adequate supplies of
respiratory devices to enable issuing a device to each individual who enters an airborne
radioactivity area, and that additional respiratory protection devices are located in the
respirator room.
2.7.3 Controlled Access
All airborne radioactivity areas have controlled access. The controlled access is marked
with warning signs and is either a separate room that can only be entered through a door
or is a roped or taped off area that one must knowingly cross over.
White Mesa Mill
Book 12, ALARA Program
2.7.4 Medical Evaluations
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The RPP provides that medical qualification will be required of each employee that might
be using a respirator in their normal work duties.
2.7.5 RPP Complies with Regulatory Requirements
The Mill's RPP must meet, at a minimum, the requirements of NRC Reg. Guide 8.15.
2.8. Bioassay Procedures
The RSO is responsible for implementing a bioassay program. The Mill performs
bioassays in accordance with U.S. NRC Regulatory Guide 8.22, "Bioassays at Uranium
Mills", which states that frequent bioassays are to be performed for employees that are
routinely exposed to yellowcake dust, uranium ore dust, or involved in maintenance tasks
in which potential yellowcake exposure may occur. Urinalysis measurements are
performed in accordance with the recommendations contained in Regulatory Guide 8.22.
The recommendations in Reg. Guide 8.22 provide corrective actions based on urinary
uranium concentrations. This program is set out in the Mill's Radiation Protection
Manual.
3. FACILITY AND EQUIPMENT DESIGN
3.1. Space Layout
As the Mill was licensed and constructed in 1980, it was designed to incorporate the
ALARA standards prevailing at that time, which generally are reflected in Reg Guide
8.31 (which was published in 1983). As a result, the space layout, access control,
ventilation systems, fire control, laboratory design features, ore and product storage and
general equipment considerations requirements specified in Section 3 of Reg. Guide 8.31
have been incorporated into the design of the Mill. Any new construction at the Mill
should observe these design features and considerations set out in Reg Guide 8.31.
3.1.1 Change Room and Shower Facilities
The Mill maintains change rooms and shower facilities so that all workers can remove
any possible radioactive contamination before leaving.
3.1.2 Di persion Control on Radioactive Materials
The Mill has dispersion control on radioactive materials moving from contamination
areas (e.g., grinding mill) to relatively contamination-free areas (e.g., grinding control
room). Lower contamination areas are isolated from higher contamination areas by self-
closing doors, and air flows are maintained from lower contamination areas into higher
contamination areas.
White Mesa Mill
Book 12, ALARA Program
3.1.3 Access to Airborne Radioactivity Levels Controlled
09/19 Revision EFR-4
Page 16 of 17
Access to airborne radioactivity areas are controlled or restricted by the use of caution
signs and operational procedures, or security locks when permitted by fire regulations. In
particular access to the yellowcake drying area is restricted by the radiation staff. Access
to the drying and packaging areas are restricted by locks on the doors.
3.2. Fire Control
The Mill maintains adequate firefighting equipment. Mill workers are trained in the
proper use of fire control equipment. This training is provided annually under the
MSHA-approved training plan and is also addressed quarterly during unannounced fire
drills.
As per MSHA requirements, fire detection systems are checked quarterly and fire
extinguishers are checked monthly.
3.3. Laboratory Design Features
Metallurgical. Bioassay and assay analyses are performed at the Mill site. In order to
prevent cross contamination of uranium from metallurgical analysis, there are different
laboratory facilities for metallurgical, bioassay and assay analyses.
Laboratory surfaces used for the preparation of bioassay samples are decontaminated to
levels as close to background as practicable but less than 200 dpm/100cm2• The results
of these surveys are recorded on a log sheet that is kept in the bioassay lab.
3.4. Ore and Product Storage
Ore and yellowcake will be stored in areas so that the material does not cause
unnecessary exposure to workers and so that the material is not dispersed by wind and
ram.
Adequate space will be provided in the yellowcake storage and packaging areas to
conduct initial surveys and spot smear tests of yellowcake packages and to enable
decontamination of drums to avoid transporting a contaminated package through other
Mill areas
Yellowcake storage and shipping areas will be located to minimize the handling time
required prior to shipment.
White Mesa Mill
Book 12, ALARA Program
09/19 Revision EFR-4
Page 17 of17
4. CONTROL OF AIRBORNE URANIUM AND ITS DAUGHTERS
4.1. Ore Storage, Handling, and Crushing Areas
Where ore is handled in the open the ALARA objective is to minimize blowing of dust.
The Mill's Utah Air Quality Approval Order specifies the steps the Mill must take for
fugitive dust management. Additional provisions are required under the Mill's license.
Inspection of the ore piles for dust conditions will dictate if dust suppression measures
are necessary. If dusty conditions are present, the roadways and ore stockpiles will be
sprayed with water or stabilizers to minimize dusting. In addition a weekly inspection of
the ore storage areas is conducted in accordance with the Discharge Minimization Plan
("DMT"). This inspection is documented by the Radiation Safety Staff and filed with the
Radiation Safety Department.
4.2. Precipitation, Drying, and Packaging Areas
4.2.1 Scrubber System on the Concentrate Drying aod Packaging Area
Drying and packaging of yellowcake is performed in an enclosure that is separated from
other areas of the Mill. Also, the drying and packaging enclosure is maintained under
negative pressure. An automatic malfunction alarm and interlock system has been
installed on the scrubber system for the yellowcake drying and packaging system
scrubber, to ensure that the yellowcake dryer will not operate unless the scrubber is also
operating. No modification to the system will be allowed to bypass the interlock system.
Operation of the yellow cake calciner will not be allowed to proceed without proper
scrubber operation.
Manometer readings or operation and instrument checks are recorded once per shift when
the system is operating and recorded in log books and operational data sheets
4.3. Interim Stabilization of Tailings
The active tailing retention system, when observed to be in a condition causing fugitive
tailing dust generation, will be treated using process liquor or other chemical dust
suppressant methods or engineering solutions to minimize tailing dust generation (See
Section 3.1 of the Mill's Environmental Protection Manual).
APPENDIX A
DAILY MILL INSPECTION Date: ____________ _
ROOF AREAS Work Place Time: By: ___________ _
Grind Yes Yes
Leach Yes Yes
Emergency Generator NA Yes
Yellowcake Precip & Pkg Yes Yes
Vanadium
cco
sx
Boiler Rooms
Oxidation
Alternate Feed Circuit
Maintenance
Change Rooms
Scalehouse
Feed Stockpiles
Mill Yard
Laboratory
Administration
Tailings Area
Other
NA Yes
NA NA
Yes Yes
NA Yes
NA NA
NA Yes
NA NA
NA NA
NA NA
NA NA
NA NA
Yes Yes
Yes Yes
NA Yes
NA
If an item is not checked off, the problem needs to be listed in the comments section. Items to be inspected for and
written in the comments section include housekeeping and cleanup, operating conditions, problems with ventilation fans,
safety concerns, employee observation of radiation policies and information pertaining to radiation safety and corrective actions.
INSPECTORS SIGNATURE
APPENDIXB
!weekly Mill Inspection!
To Energy Fuels Supervisors
From Date: _____ _
For the week of: ___ to
The following areas of the White Mesa Mill were inspected. A description of the potential safety hazards,
housekeeping, operational and radiological conditions are described. The color code breakdown is for those
departments I feel are responsible, but not limited to for repair of said items:
Green -Maintenance ·c111rn -Safety/Rad Red -Operations Blue -Utility
Leach Tank Area:
Pulp Storage:
Ore Storage:
CCDArea:
Administration Building:
CCR: No problems identified.
Reagent Tanks:
Labor Change Room:
SX:
Vanadium:
Yellowcake Packaging:
Maintenance:
Warehouse:
Alternate Feed:
Sag Mill:
Lunch Room:
Tails:
Miscellaneous: Please sign and turn in by Monday.
RSO _~~~~~-Mill Superintendent/ Safety __________ _
White Mesa Mill
Book #13 Training Manual
Date: 12/19 Revision: EFR 3.5
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Training Manual
Energy Fuels Resources (USA) Inc.
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
White Mesa Mill
Book #13 Training Manual
Contents
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1.0 INTRODUCTION ................................................................................................................................................ 4
2.0 EMPLOYEE TRAINING .............................................................................................................................................................................................................. 4
2.1 Newly Hired Employee (Inexperienced) ............................................................................... 4
2.2 Newly Hired Employee (Experienced) .................................................................................. 5
2.3 Testing Newly Hired Employees ............................................................................................ 5
2.4 Specialized Training ............................................................................................................... 6
2.4.1 Respirator Training ............................................................................................................ 7
2.4.2 Pre-Natal Training ............................................................................................................. 8
2.5 Annual Refresher Training .................................................................................................... 8
3.0 CONTRACTOR TRAINING ................................................................................................. 9
3.1 Delivery Personnel ................................................................................................................ 10
4.0 VISITORS ............................................................................................................................... 10
5.0 RECORD KEEPING AND DOCUMENTATION ............................................................. 10
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Book #13 Training Manual
Appendix A -Statutory Rights of Miners
Appendix B -NRC/State of Utah
Appendix C -Safety Training Modules
Appendices
Module C 1 -Communication and Transportation
Module C2 -Emergency Procedures
Module C3 -First Aid
Module C4 -Hazard Recognition
Module C5 -HAZCOM
Appendix D -Employee Radiation Training
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Module Dl -RADIATION AND RESPIRATORY PROTECTION SAFETY
TRAINING OUTLINE FOR NEWLY HIRED INEXPERIENCED MILL
WORKERS
Module D2 -RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED
EXPERIENCED MILL WORKERS
Addenda D 1 -Handouts
Appendix E -Annual Refresher Training
Appendix F -Contractor Safety Rules
Appendix G -Forms
Form 1 -Alpha Contamination Training Acknowledgement
Form 2 -Radiation Exposure Request Form
Form 3 -Radiation Exposure to Pregnant Women Employees
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Book # 13 Training Manual
1.0 INTRODUCTION
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The purpose of the Energy Fuels Resources (USA) Inc. ("EFR") training program is to instruct
and educate all workers of the inherent risks associated with the job. The training will acquaint
workers with the practices instituted by management to minimize occupational exposures and
ensure that workers have an understanding of the fundamentals of radiation, health, safety and
environmental protection procedures before beginning their assigned tasks.
EFR's training program provides education for a newly hired employee (inexperienced and
experienced), existing employees, contractors, all delivery personnel and visitors.
2.0 EMPLOYEE TRAINING
2.1 Newly Hired Employee (Inexperienced)
Any new employees that has not receiver MSHA Part 48 Training and is expected to work 40
hours or more a year are considered inexperienced miners and will receive training to meet
federal and state requirements for safety, radiation and environmental stewardship.
All newly hired inexperienced Mill workers are required to complete their initial 24-hour
training required by MSHA. Training is conducted by the RSO, Safety Coordinator, or a
qualified designee. The following topics are covered as required by the MSHA Approved
Training Plan:
• Introduction to the Workplace
• Electrical Hazards, Traffic Control and Communication Systems
• Emergency Procedures (first aid, evacuation, and firefighting)
• Health and Safety Standards
• Statutory Rights of Miners
• Hazard Recognition
• HAZCOM (hazard communication)
• Radiation Protection Program
• Respirator Protection Program
• Regulation Overview
• Environmental Programs -SWPPP and SPCC
Training outlines are provided in Appendices A through D. A quiz will be given following the
training to document the employees understanding of safety precautions and procedures utilized
at the Mill. Quizzes are reviewed in the classroom so that if any further instruction is needed it
can be given at this time to assure employees understanding of the materials presented. Tests will
be given to employees on radiation safety and respirator protection which is described in Section
2.3.
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Once the training and quiz are complete there are various forms required to be signed and put to
file. At a minimum, the following forms are included in Appendix G and include:
• The Alpha Contamination Training Acknowledgement Form (Form 1),
• Radiation Exposure Request Form (Form 2) -for employees with previous work-related
radiation exposure
• Radiation Exposure to Pregnant Women Employees (Form 3)
2.2 Newly Hired Employee (Experienced)
Newly hired Mill workers will be considered "experienced" Mill workers if:
a) They have received the full 24-hour Part 48 training for inexperienced miners hired
employees; or
b) They were previous Mill workers who satisfied the initial training requirements at the
Mill at some time in the past, and completed their last annual refresher training,
including radiation refresher training, within the last five years; or
c) They have satisfied either ( a) or (b) at another facility where the Mill RSO has
determined there is a comparable radiation safety training program.
Newly hired experienced Mill workers are required to complete the MSHA Eight-Hour
Refresher Training as outlined in the Approved Training Plan before beginning work. Training
will be provided by the RSO or a qualified designee.
Outlines for each topic described are provided in Appendices A through D. A quiz will be given
following the training to document the employees understanding of safety precautions and
procedures utilized at the Mill. Quizzes are reviewed in the classroom so that if any further
instruction is needed it can be given at this time to assure employees understanding of the
materials presented. Tests will be given to employees on radiation safety and respirator
protection which is described in Section 2.3. Once the training and quiz are complete there are
various forms required to be signed and put to file.
2.3 Testing Newly Hired Employees
As a component of the initial training program for both newly hired inexperienced and newly
hired experienced Mill workers, as well as for annual refresher training for all Mill workers,
written tests on radiation safety and respiratory protection are required to be completed. The
radiation safety test will have questions directly relevant to the principles of radiation safety and
health protection covered in the initial training course for newly hired inexperienced Mill
workers
The respiratory protection test will have questions directly relevant to respiratory protection and
the proper use of respiratory protection equipment covered in the initial training course for newly
hired inexperienced Mill workers.
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Employees are required to attain a passing score of 70% on each of these tests in order to
proceed or continue with Mill related work assignments. After completion of the tests, the
instructor will review the test results with each worker. Any wrong answers will be discussed
with the worker until he/she fully understands the subject of the question and the correct answer.
Workers who fail either test will receive additional training and be re-tested until a passing score
is attained. All test results are maintained on file with the Radiation Safety Department.
In special circumstances, where it is not possible or practicable for the individual to take one or
both of the written tests, the RSO or his designee may give the tests orally. In those
circumstances, the RSO or his designee will make a written record of the questions asked and
answers given.
2.4 Specialized Training
In addition to the new hire training described above, all new workers (including supervisors) are
given specialized training on health and radiation aspects of their specific jobs, including non-
radiological hazards. When the worker gets to his or her particular job, the supervisor will give
the worker individualized on-the-job training. This training typically does not cover radiation
protection, to the extent it is already covered in the initial training. If specific radiation
protection issues exist for any particular job, or new job (such as may result for a new alternate
feed material), such issues would typically be addressed in a Procedure or Radiation Work
Permit (RWP) or, in certain circumstances, by specific training given by the RSO or his
designee. In all cases, the training should be commensurate with the risks and hazards of the
task.
Specific radiation protection training is normally given on any new Procedure or RWP either at a
regularly scheduled radiation and safety meeting or at a radiation and safety meeting held for the
affected workers, prior to implementation of any such Procedure or RWP. New employees that
are required to be given training on Procedures or RWPs or other training specific to their jobs
will be given such training prior to commencement of their jobs.
Such specialized training will be by the RSO or qualified designee. With respect to RWPs, any
required training is given verbally by the member of the Radiation Safety Department who issues
theRWP.
If determined necessary by the RSO, supervisors will be provided additional specialized training
on their supervisory responsibilities in the area of worker radiation protection. However, given
the nature of Mill operations and activities, the comprehensive training given to all workers,
including supervisors and the supervisory role on radiation safety matters provided by the
Radiation Safety Department, such specialized training for supervisors is usually not required.
In addition, radiation safety matters of concern that may arise during Mill operations or activities
will, at the discretion of the RSO, be discussed with all affected workers during regular meetings,
such as tailgate meetings for maintenance and/or operations personnel, or at specially called
radiation safety meetings.
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Book #13 Training Manual
2.4.1 Respirator Training
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The initial four-hour training course for new inexperienced workers includes trammg for
respirator users as necessary, at the discretion of the instructor, depending on the level of
knowledge and experience of the worker. The course work is described in in Appendix D. This
training will include hands-on training and will take place prior to fit testing.
Under the respirator protection training for newly hired inexperienced Mill workers, each worker
will:
d) be informed of the hazard to which the respirator wearer may be exposed, the effects of
contaminants on the wearer if the respirator is not worn properly, and the capabilities
and limitations of each device that may be used;
e) be shown how spectacle adapters communications equipment, and other
equipment that will be used directly in conjunction with the respirator are to be attached
and operated properly;
f) be able to demonstrate competency in donning, using, and removing each type of
respiratory protective device that may be used;
g) be instructed in how to inspect each type of respiratory protective device that may
be used and be instructed to perform such an inspection before donning any device;
h) be instructed in how to perform a user seal check on face-sealing devices and be
instructed to perform this user seal check each time this type of device is donned;
i) be informed that any respirator user may leave the work area at any time for relief from
respirator use in the event of equipment malfunction, physical or psychological distress,
procedural or communications failure, significant deterioration of operating conditions or
any other condition that might necessitate such relief; and
j) be advised that in case of respirator malfunction or wearer distress, the respirator may be
removed as the respirator user exits the airborne contamination area.
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Book # 13 Training Manual
2.4.2 Prenatal Training
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In addition to the foregoing training requirements, prenatal trammg is provided to workers
pertaining to the content and requirements of NRC Reg. Guide 8.13 while attending the "new-
hire" training session. This section can be skipped at the discretion of the trainer if there are no
females in the training. The purpose of this training it to provide for radiation monitoring of
declared pregnant women and for the calculation dose to an embryo-fetus. Radiation protection
regulations allow a pregnant worker to decide whether she wants to formally declare her
pregnancy to her employ, thereby taking advantage of special dose limits provided to protect the
developing embryo-fetus.
This program is voluntary. Lower dose limits for pregnant women only apply if they have
declared pregnancy in writing. The choice to declare pregnancy and thereby work under lower
dose limits is the woman's choice, not EFR's. An employer may not remove a person from a job
because they appear pregnant.
Please note: Verbal declaration or statement is not the same as telling an employer a person is
pregnant.
These workers are required to sign the Form 3 found in Appendix G, attesting to the fact that
they have received this pre-natal training.
2.5 Annual Refresher Training
All Mill workers receive eight-hours of refresher training in accordance with the Mill's MSHA
training plan each year. The eight-hour annual refresher training is normally divided into 10
modules, which are generally given during monthly safety meetings. One or more of these
meetings comprise the required one-hour radiation safety training. The annual refresher radiation
training will be given by the RSO or qualified designee on topics outlined in Appendix E
The one hour of radiation safety training, includes discussions of relevant information that may
become available during the past year, a review of safety problems or exposure trends that arose
during the year, as well as changes in regulations, license conditions, or policies that may have
occurred within the annual period. In addition, further radiation safety training may, at the
discretion of the RSO, be given at other monthly or periodic safety meetings.
The 10 modules generally covered during the monthly safety meetings include:
• Mandatory health and safety standards
• Radiation and respiratory
• Accident prevention
• First Aid
• Hazard Communications
• Escape and emergency evacuation plan and fire warning
• Electrical hazards and quarterly radiation
• Transportation communication systems and ground control
White Mesa Mill
Book #13 Training Manual
• First aid and emergency procedures
• Quarterly radiation
3.0 CONTRACTOR TRAINING
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Mandatory (MSHA, OSHA, State or company, etc.) safety and radiation awareness training must
be completed by any and all contract employees working at the Mill prior to performing work on
site. Training is completed dependent on the contractors work specifications and is
commensurate with the risks and hazards of the task. There are two types of contractors
considered and each receives training specific to the work. The first type is full-time or long-
term contractors. The second type is casual or short-term contractors.
Contractors who provide services on a full-time or long-term basis or who will perform work on
heavily contaminated equipment will be given the same training as Mill workers. Job-specific
radiation safety instruction is necessary for contract workers who have previously received full
training on prior work assignments at the Mill or have previously received full training
elsewhere. A copy of the Contractor Safety Rules (Appendix F) is given to contractors.
Contractors are required to sign the last page of the safety rules document acknowledging their
acceptance thereof.
Casual or short-term contractors working at the Mill, where there is little or no risk of any
significant exposure to radiation, are given abbreviated job-specific training and safety
instructions specific to their assignments. A basic radiation training is given to contractors
verbally, unless more specific training is required, which will be addressed on a case-by-case
basis and will be provided by the RSO or his designee.
The following topics are presented for on-site full-time or long-term contractor training:
• Personal Protection
• Radiation Protection and Awareness
• Housekeeping and Storage
• Fire Protection
• General Site Safety Requirements
• Lockout Procedures
• Flame Permits
• Confined Space Entry
• Mobile and Heavy Equipment
• Tools and Pressurized Vessels
• Explosives and Blasting
• Regulatory Agency Requirements
• Accident Reporting
• Monitoring Employees
• Weather Hazards
• Archaeological Discovery
• Emergency Procedures
White Mesa Mill
Book #13 Training Manual
• Storm Water Pollution Prevention
• Spill Prevention Controls and Countermeasures
Contractors are required to receive training annually.
3.1 Delivery Personnel
Date: 12/19 Revision: EFR 3.5
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Training is provided to personnel who deliver ore, sulfuric acid, 1 le.(2) byproduct material and
reagent. Training is also given all personnel that deliver freight such as UPS, FedEx and Old
Dominion. The training addresses general and radiation hazards associated with access to the
Mill site. This training is addressed in Book 1, Section 2 for all delivery drivers except those
delivering lle.(2) byproduct which is found in PBL-10. The RSO, Safety Coordinator or
qualified designee performs the training.
Delivery personnel are required to receive training annually.
A master list of annual Hazard Awareness Training for delivery personnel/drivers is maintained
by the RSO. The list is available at the entry gates for gate personnel to check the training status
of delivery personnel. This list is checked daily by the RSO and compared to the
"Contractorffruck Driver Personnel to be Alpha Scanned" form to verify that all deliver
personnel have been trained before departing the Mill site. The RSO also checks all delivery
training records against off-hours gates personnel and drivers, and maintains thorough records of
all such checks, which he signs and dates then files according to those observed and verified
4.0 VISITORS
All visitors at the Mill must receive Hazard Recognition Training by the RSO, Safety
Coordinator or qualified designee prior to being escorted anywhere on site. Hazard recognition
provides the instruction on what a person should do to avoid possible radiological and non-
radiological hazards in the areas of the facility they will be visiting. Visitors will be provided a
Hazard Recognition Training form by the aforementioned staff to review and sign. Once training
is complete, the signed Hazard Recognition Training form will be maintained on file and visitors
may then be escorted to the desired location Procedures (SOPs).
5.0 RECORD KEEPING AND DOCUMENTATION
Each training described above requires employees, delivery personnel and visitors to sign the
training specific form as instructed by the trainer. Signed and completed forms are maintained
on file with the Radiation and Safety Departments.
White Mesa Mill
Book #13 Training Manual
Appendix A
Statutory Rights of Miners
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Statutory Rights of Miners
1.0 INTRODUCTION
In accordance with the Federal Mine Safety and Health Act of 1977 (the "Mine Act") and the
Mine Improvement and New Emergency Response Act of 2006 (the "MINER Act") and Title 30
of the Code of Federal Regulations (30 CPR) grant a variety of rights for individuals employed
as miners, designated representatives of miners, and applicants for employment in mine related
jobs. Congress encourages each to take an active, responsible role in matters of mine safety and
health.
2.0 DEFINITIONS
Mine -any surface or underground location involved in the extraction, preparation, or processing
of coal or other minerals.
Miner -generally any person working in a mine, including contractors, construction or
demolition workers, and truck drivers who are regularly exposed to mine hazards. Therefore, all
persons working in a mine may exercise the rights given them by the MINER Act. Supervisors
who may not normally perform actual physical mining activities but who work in a mine are also
considered miners.
3.0 MINER'S RIGHTS
If you are a miner or repre entative of miners:
You have the right to request that MSHA inspect your mine when you believe that an imminent
danger, a violation of the MINER Act, or a violation of a safety or health standard exists. You
also have the right to be informed of, and participate in, enforcement proceedings under the
MINER Act.
If you are a miner:
You have the right to be paid for certain periods of time when a mine, or part of a mine, has been
closed because of a withdrawal order.
You have the right to receive health and safety training during your normal working hours and to
be paid for that time at your regular rate of pay.
You, and a fellow miner, have the right to have a representative accompany an MSHA inspector
during inspections at your mine.
If you are a representative who is also a miner:
You have the right to be paid for time spent participating in health and safety inspections at your
mine under certain circumstances.
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Book #13 Training Manual
4.0 MINER'S RESPONSIBILITIES
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As a miner you have the responsibility to comply with all Federal and State laws and regulations,
and company safety and health policies.
When refusing to work in unsafe or unhealthy conditions, you have the responsibility to notify
the operator, supervisor, or other responsible person. This gives the operator an opportunity to
address the situation.
You have the responsibility to provide truthful statements and representations (orally or in
writing) during any inspection or investigation, or on any applications, records, reports, plans,
training certificates, or other documents required to be kept or filed with MSHA.
5.0 MINER'S PROTECTIONS
You may not be fired, demoted, harassed, intimidated, transferred, refused employment, suffer
any loss of wages, or discriminated against for exercising your rights under the MINER Act.
You are protected under Section 105( c) of the MINER Act when you engage in the following
activities:
• File or make a complaint of an alleged danger or safety or health violation to a Federal or
State agency, a mine operator, an operator's agent, or a miners' representative.
• File a complaint with the Federal Mine Safety and Health Review Commission, testify, or
otherwise participate in any proceeding.
• Become involved in any inspection or investigation conducted under the MINER Act.
• Have a medical evaluation or are considered for transfer to another job location because
of harmful physical agents and toxic substances. For example, coal miners have the right
to a chest x-ray and physical examination for black lung disease (pneumoconiosis) and
potential transfer to a less dusty position if the diagnosis is positive.
• Withdraw from the mine for not having the required health and safety training.
• Refuse to work in conditions you reasonably believe to be unsafe or unhealthy.
• Use any statutory right given by the MINER Act, such as being paid as a miner's
representative while accompanying an MSHA inspector during an inspection or the right
to be paid while receiving required training under the MINER Act.
For additional information on miner's rights, please visit http ://www.MSHA.gov.
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Book #13 Training Manual
AppendixB
Regulatory Overview
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NRC / State of Utah / l\ilSHA Training
This section of New Hire Training will cover the United States Nuclear Regulatory Commission
(NRC) and State of Utah standards.
A. The State of Utah, Division of Radiation Control has primary responsibility for radiation
Protection.
1. Workers and the Public are protected from excessive exposure to radiation.
B. Employer Responsibility
1. Company must comply with the State of Utah regulations at R313-15, which
incorporate the NRC Regulations at 10 CFR Part 20.
2. Failure to comply -fined, license modified, license suspended, or revoked
3. DRC Radiation requirements
a. Will be covered in Radiation Health Safety section of training.
C. Employee Responsibility
1. Follow all rules
2. Protective clothing
D. Report Violations
E. Occupational Safety
1. MSHA jurisdiction
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Book #13 Training Manual
Appendix C
Safety Training Modules
Module Cl: Introduction to the Workplace
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Module C2: Emergency Procedures, Evacuation, and Firefighting
Module C3: First Aid
Module C4: Hazard Recognition
Module CS: Hazard Communication Standards (HAZCOM)
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Module Cl: Introduction to the Workplace
1. Organization
A. Organization Chart
B. Safety Rule Book handed out
2. Reporting unsafe conditions and inquiries
A. Immediate notification of unsafe activities to supervisors
B. Green Card-All accidents must be reported.
C. Accident/Incident Reports
D. Doctor's return to work slip
3. Exposure Sheets
A. Explain weekly exposure sheets and how to fill out
4. Conduct
A. Discussion of conduct expected of employees at the White Mesa Mill
B. Rules
5. Safety Glasses
A. Company policy on purchasing prescription glasses
B. Goggles -areas where worn
6. Noise
A. Audiograms
B. Posting -Areas -Equipment
C. Discussion on Noise Dosimetry
D. Discussion on Sound Levels
E. Allowable decibels
7. Vehicles -authorization
A. Safety Rules
B. Equipment check lists
C. Valid driver's license
D. Use of seat belts
E. Speed Limits
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Book #13 Training Manual
8. Warehouse
A. Safety shoes or boots -issue
1. Company policy on leather boots
B. Safety glasses with side shields -issue
C. Hard hats -issue
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1. Discussion on painting or applying stickers
9. Mill Tour
A. Schematic of mill area
B. Tanks and contents -labels
C. Piping -labels
D. Postings
1. Radioactive Materials
ii. Hearing protection
m. Respirator Areas
1v. Restricted Areas
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Module C2: Emergency Procedures, Evacuation, and Firefighting
1. Fire
A. Basic Elements of Fire
1. Discussion of fire triangle
1. Heat
2. Fuel
3. Oxygen
B. Classes of Fires -Extinguishing Media
1. Class A Fires
1. Wood, cloth and paper
a. Extinguishers for Class A
b. Water, dry chemical, AFFF foam
11. Class B Fires
1. Vapor -air mixture over the surface of flammable liquids.
a. Extinguishers for Class B
b. Dry Chemical, AFFF foam, water, fog, carbon dioxide
iii. Class C Fires
1. Electrical
a. Extinguishers for Class C
b. Dry chemical and carbon dioxide
C. Characteristics of Flammable Liquids
1. Flash Point
ii. Fire Point
111. Ignition Temperature
1v. Flammable or explosive range
D. Schematic of Fire Systems
1. Location of fire pump, plugs, valves
11. Location of SX foam system
iii. Explanation of fire equipment and hose stations
iv. Explanation of SCBA's and Turnout Gear
v. Tour of pump house, hose stations, and SX building
E. Fire extinguishers -Different types
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i. Classes -A, AB, ABC, BC
11. AFFFfoam
F. Fire alarm -Break glass on fire alarm button
G. Actual hands on 2 ½" fire hose -basic
H. SCBA an SX escape bottles
i. Explanation of their use and demonstration
2. Emergency Evacuation Procedures
A. Emergency Response Plan
i. Available for review in the Central Files
11. Roles and responsibilities
111. Organizational chart
B. Evacuation Siren
1. Break glass on evacuation alarm button -Steady Siren
ii. Response team will respond to emergency
C. Assembly Areas
1. Administration parking lot is the primary location
ii. Scalehouse secondary east location
111. Propane storage is the secondary north location
1v. Gate to tails is the secondary west location
v. Determination of when to evacuate to which area
D. Emergency Response Team
i. Operational
1. Leach Operator
2. Yellowcake Precipitation Operator
3. "A" Operator
4. Mill Trainee
5. Shifter -will be in charge on off shift
ii. Non-operational
1. Scalehouse Operator
2. Operations Personnel
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3. Maintenance Personnel
E. Emergency Response Procedures
F. On Site Emergency Equipment
1. Company vehicles
ii. SCBAs
iii. Firefighting equipment
G. Off Site Emergency Equipment
1. Local emergency medical services
ii. Blanding Fire Department
iii. Local law enforcement
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Module 3:
I. Triage
A. Feel, Talk, and Observe
i. Life-saving first aid
First Aid
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B. Brain and Spinal Cord-Fractures and Wounds
i. Secondary first aid
IL Basic Life Support
A. Causes
i. Clinical death -heart attacks, etc.
ii. Choking -Foreign object
B. Procedure -Pulseless victim
i. Establish unresponsiveness
11. Open the airway
iii. Look-listen-feel for breath
1v. No breath -artificial ventilation -2 slow full breaths
v. Check pulse
vi. No pulse -start CPR
C. Procedures -choking
1. 1 thru 4 above
ii. Re-establish open airway and try again
m . Administer Heimlich Maneuver
1v. Check and clean mouth
D. Other special cases
i. Infants, small children, etc.
E. Practice
III. Control of Bleeding
A. Circulatory System -Heart, blood vessels, lungs
i. Blood -1/12 -1/15 of total body weight
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11. 10-12 pints in 150-pound adult
iii. Loss of 2 pints -serious shock, loss of 3 pints may be fatal (2 hours or
less)
1v. Rupture of main artery in neck, arm or thigh may be fatal in 1-3 minutes;
rupture of main artery in trunk may be fatal in 30 seconds.
B. Loss of blood almost always causes physical shock
1. Insufficient blood flow
11. Death could occur if not treated
C. Review of blood vessels
1. Arteries -Immediate action is needed
11. Veins -Immediate action if possible
111. Capillaries -Usually not serious
D. Methods of controlling bleeding
i. Direct pressure and elevation
11. Digital pressure -direct pressure
iii. Tourniquet -LAST RESORT
E. Internal bleeding
IV. Shock
1. Blood from mouth -dark red, bright red, foamy
ii. Shock, guarding
111. Medical emergency -need doctor's care as soon as possible
1v. Treat for shock
v. Apply cold packs
v1. Transport injured in the recovery position
v11. Keep airway open -victim could vomit
viii. Victim is in need of IV
A. Collapse or a depression of the cardiovascular system due to an accident or
sudden illness. Shock interferes with the normal action of the heart, respiration,
and circulation system. Shock may result from a variety of causes.
a. Cerebrospinal System -Brain and spinal cord (voluntary)
b. Sensory nerves leaving cord (heat, cold, pain, touch, etc.)
c. Sympathetic -vital organs -heart, lungs, digestive, trunk, etc ... , all
involuntary
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B. Causes of Shock
a. Injuries
b. Pain
c. Blood loss
d. Burns
e. Electrical shock
f. Gas poisoning
g. Sudden illness
h. Allergic reactions (bites, stings, etc ... )
1. Fear, apprehension, emotional stress
J. Poisons internally
C. Signs and symptoms of shock
a. Skin -pale, cool and clammy
b. Eyes -dull, lackluster, dilated
c. Respiration -shallow, irregular, labored
d. Pulse -rapid, weak
e. Blood pressure -low -below 90
D. Treatment of shock
a. Assure open airway and adequate breathing
b. Treat and control cause -example bleeding, fracture, etc ...
c. Keep person laying down
d. Head level or slightly lower than body -about 1 foot
e. Remove foreign objects from mouth (false teeth, gum, etc ... )
f. Access fresh air or give oxygen if available
g. Loosen tight clothing around neck, check, waist
h. Keep person warm and dry
i. Never give water, food or medication by mouth
J. Reassure!
E. Anaphylactic shock
a. True emergency -get to clinic as soon as possible, take cause with you if
possible.
V. Head, Neck, Spine Injuries
A. Head Injury
1. Fracture dangerous -possible brain damage
2. Pupils dilated or unequal in size
3. Depression of skull
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4. Always consider an unconscious victim as having a head or spine injury
B. Treatment for Head injury
1. Lay person down -elevate head and shoulders
2. Maintain airway
3. Control bleeding from scalp with minimal pressure
4. Do NOT control bleeding in ears or nose.
5. Never give a stimulant
6. Follow other shock treatment
7. Keep victim from resting head on suspected fracture area -
might have to place on side or recovery position to help with breathing.
C. Suspected Neck and Spine
1. Spinal Column
a. 24 bones called vertebra
b. Protects spinal cord and specific nerve roots
2. Fracture
a. May occur at any point -cord may be cut, or broken bone or
dislocated bone may be resting against cord
3. Symptoms
a. Pain and tenderness at site
b. Deformity
c. Cuts and bruises
d. Paralysis
e. Loss of sensation
f. Unconscious -Always suspect fracture
4. Treatment
a. Almost always takes four people -work as team
b. Traction applied to neck and maintained by hand until a cervical collar
or other padding is available
c. Speed is not important -complete immobilization of head, neck and
back is important.
d. Follow shock treatments
5. Practice
VI Fractures and Dislocations
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1. Broken or cracked bone. Most commonly caused by direct blows, indirect
blows or twisting forces.
a. Compound fracture (open)
b. Simple fracture ( closed)
2. Signs and Symptoms
a. Pain and tenderness
b. Deformity
c. Loss of function
d. Moderate or severe swelling
e. Discoloration
f. Victims information (felt bone snap)
g. Grating
3. First Aid Treatment
a. Treat for shock
b. Immobilize joint above and below fracture site
4. Types of Splints
a. Air or plastic inflatable
b. Cardboard
c. Board splint
d. Improvised splints
5. Guidelines for Splinting
a. Remove all clothing from fracture site
b. Never attempt to replace or re-align bones
c. Do NOT attempt to re-align limb
d. Cover open wounds
e. Pad hard splint with soft material
f. Pad all naturally occurring arches -knees, wrist, etc.
g. Support injured part with hand traction while splint is being applied
h. Splint firmly, but not so tight as to interfere with circulation -leave
fingers and toes visible to perform a capillary refill test
1. Elevate injured part if possible
j. Keep reassuring victim and transport to doctor
6. Practice
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VIL Burns
1. Types and classes of burns
a. 1st, 2nd and 3rd degree
b. Thermal, Chemical, Electrical and Radiation
2. Severity of burns (Rule of 9)
a. Face-9%
b. Body front -9%
c. Body back -9%
d. Arm-9%
e. Leg-18%
f. Genitals -1 %
3. Critical Burns
a. 2nd degree -25% of body
b. 3rd degree -10% of body
c. 3rd degree -Critical areas -face, hands, feet or genitals
4. Moderate Burns
a. 1st degree sunburn over 25% of body
b. 2nd degree burn up to 25% of body
c. 3rd degree burn up to 10% of body
5. First Aid treatment for Burns
a. Remove victim from source
b. Maintain airway and assure breathing
c. Control any bleeding and treat for shock
d. Remove any clothing from burn area except if it adheres to the skin
e. Separate burned surfaces when it could contact one another such as
fingers, toes, inside arms or legs
f. Cover with clean sterile sheet or burn blanket or dry dressings
g. Use cool moist dressings if moderate or minor burn
h. If chemical burn, flush with water for a minimum of 15 minutes
1. Use of Water-Gel blankets
6. Electrical Burns
a. Make sure source is removed or de-energized
b. Look for entrance and exit
c. Cover both with dry cloth dressings
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d. Be ready to provide Basic Life Support
VIII. Other First Aid Topics
1. Transportation
2. Medical emergencies
a. Heat stroke
b. Heat exhaustion
c. Heat cramps
d. Frost bite
e. Hypothermia
f. Diabetic emergencies
g. Epileptic seizure
h. Stroke
i. Poisons and drugs
j. Snake bites
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Module C4: Hazard Recognition
1. Scale House Injury Hazards
I.
11.
iii.
IV.
V.
2.
I.
11.
iii.
3.
a. Delivery trucks -See attached sheet
b. Ore haulers -See attached sheet
c. Product haulers -See attached sheet
d. Loaders -Haulage Trucks (EFR)
e. Jaw Crusher and drying unit in bucking room -pinch points -heat
f. Stockpile hazards
Falling rocks on stockpiles
Tripping hazards during sampling operation
Radiation hazards from stockpile
Lifting of sampling buckets
See Sampling SOP for additional hazards
Scale House Health Hazards
a. Hearing protection when operating equipment
b. Silica dust
C. Radiation
Airborne uranium -sampled monthly
Beta/gamma -sampled monthly
Radon Daughters -sampled monthly
Mill Feed and Stockpile Injury Hazards
a. Delivery Trucks -Speed Limit is 15 mph
b. Ore Haulers -Speed Limit is 15 mph
c. Product Haulers -Speed Limit is 15 mph
d. EFR equipment has right-of-way. BE AW ARE OF ALL PERSONNEL AND
TRUCKS IN YOUR AREA.
e. Grizzly
1. Safety belt must be used during operation work inside the grizzly,
maintenance work on the grizzly. Safety chain must be installed when the
grizzly is not in use.
f. Dust collection
1. System must be started before ore is fed to SAG Mill -possible electrical
shock.
g. Cleaning of reclaim tunnel
1. Conveyor must be locked out to clean underneath
2. Respirator required -radiation and silica dust.
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4.
5.
3. Hearing protection must be worn when dust collection system is operating
4. Replace guards when finished cleaning
5. Biggest hazard in tunnel is moving conveyor
h. SAG Mill area -Hazards
1. Rotating mill
ii. Moving conveyor
iii. Vibrating feeder
IV. Guards must be in place
v. Falling rocks from SAG Mill feed chute -above vibrating feeder
v1. Hot oil system
vii. Foaming of #1 and #2 Pre-Leach Tanks
vm. Traffic in North Door of Mill building
IX.
1.
ii.
lll.
1. Use of forklift equipment to remove rejects -BEW ARE OF
TRAFFIC AND PERSONNEL
Lifting of sample buckets
Mill Feed and Stockpile Health Hazards
a. Silica
b. Hearing Protection
C. Radiation
Airborne Uranium
Radon Daughters
Beta/Gamma
Hazard Recognition -SAG Mill Operator
a. Conveyor
b. Rotating Mill
c. Vibrating feeder -apron feeder
d. Hot oil system
e. Falling rock from SAG Mill feed chute above vibrating feeder
f. these are not and no plan for them to be used. Use of forklift equipment to
remove reject bin -BE AW ARE OF PERSONNEL AND TRAFFIC near north
door of Mill Building
g. Acid lines -pump storage
h. Steam lines
i. High pressure air lines
J. Guards
k. Pinch points
i. Idlers and rollers
ii. Head and tail pulley
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iii. All guards must be in place before running
iv. Cleaning up around pumps
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1. Overhead crane use during loading grinding balls into SAG Mill
m. Overhead crane use during relining SAG Mill -Must be roped off
n. Overhead crane must not be used when SAG Mill is rotating
o. Caution wet decks are slick and present fall hazard
6. Health Hazards -SAG Mill Operator
a. Radiation
1. Radon Daughters
ii. Airborne Uranium
iii. Beta/Gamma
b. Silica
c. Hearing Protection
7. Hazard Recognition -Leach Circuit
a. Sulfuric Acid
1. Hot liquor in tanks
11. Leak detection of tanks
111. Leak detection of lines and valves
b. Steam lines
i. Insulated
ii. Opening and closing of valves
111. Valves hot-use gloves
C. High pressure air lines
1. Caution when operating valves
11. Whip checks on connections
iii. Do not use to blow off clothing
d. Water lines
1. Open slowly -100 psi
11. No water fights
e. Safety belts
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1. Leach tank tops
ii. Work beyond handrail requires safety belt
f. Obstructions in walkways
1. Hoses
ii. Drums
111. Tools
iv. Sampling equipment
g. Overhead crane
1. Assume it is always in use
11. Needs roped off during use
m. Look up when entering Mill Building
iv. Rope off area and check safety latch on hook
h. Ladders
i. Guards
1. Drive units
ii. Pumps
j. Health hazards
1. Radon build-up when SAG Mill is in operation
ii. Leach #7 overflow line to CCD
m. Gamma radiation in SX feed line
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1v. H2S fumes above leach tanks, and pulp storage tanks when adding acid
v. Hearing protection needed when SAG Mill is running
v1. Respirator usage
v11. Airborne uranium
k. Decks and walkways
1. Slippery when wet
11. Slippery when reagents are spilled on walkways and decks
8. Hazard Recognition -CCD Circuit
a. Sulfuric acid lines
1. Hot solutions in CCD #1
11. Detection of leaks in area
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b. Air lines
i. Open valve slowly
11. Whip checks on hose connections
iii. Do not use to blow off clothing
c. Ladders
i. East tails system
11. Ladders used on tanks must be tied off
d. Safety belts
i. Must be worn when outside handrails
e. Trip and fall hazards
1. Hoses in walkway
11. Spilled floe
iii. Tools
1v. Cleanup bottom floor
v. Deck and walkways slippery when wet
v1. Matting under control panels
vii. Ice build-up during winter months
f. Guards
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1. Guards must be in place before starting any equipment
11. Do not remove guard on floe mix device during mixing
g. Health hazards
i. Sulfuric acid solutions
11. Gamma radiation in SX feed line
m. All raffinate lines
1v. Airborne uranium
v. Radon daughters
vi. Silica
9. Hazard Recognition -SX Circuit
a. Sulfuric acid lines
1. Open slowly
11. Use personal protective equipment (PPE)
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b. Caustic tank and lines
1. Open valve slowly
ii. Use PPE
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iii. Air pressure during unloading is to be no more than 30 psi
c. Ammonia tanks and lines
i. Open valves slowly
ii. Use PPE
m. Report leaks promptly
d. Kerosene tanks and lines
i. Open valves slowly
ii. Use caution around pumps -guards
iii. Use PPE
e. Soda ash bins and tanks
1. Use caution around pumps, feed auger
ii. PPE
iii. Open valve slowly
1v. Open steam lines slowly
f. Sodium chlorate tanks and lines
1. Open valves slowly
ii. Caution around pumps
iii. Use PPE
g. Amines
1. Burning -itching
ii. Caution when dumping drums
h. Air lines
i. Open valves slowly
ii. Whip checks on hose connections
m. Do not use to blow off clothing
i. Steam lines
i. Open valves slowly
ii. Valves hot
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j. Fire systems
i. Overhead foam sprinkler system
11. Fire extinguishers
iii. 3 -5-minute escape bottles under observation platform
1v. 4-SCBA's, two each located on the north and south end of the building
v. Know where the exits are
k. Health hazards
1. Sulfuric acid
1. burns -flush with water at least 15 minutes
2. fumes -respirator required
11. Caustic soda
1. burns -flush with water at least 15 minutes
iii. Ammonia
1. fumes -respirator required
2. large spill or fire requires SCBA
3. burning -flush with water at least 15 minutes
1v. Kerosene
1. burning -itching -wash with soap and water
v. Amines
1. burning -itching -wash with soap and water
v1. Soda ash
1. burning -itching -flush with water at least 15 minutes
vii. Sodium chlorate
1. fire hazard
a. rubber gear, boots, gloves, goggles or face shield
b. discard clothing if contamination with chlorate shows
2. chlorine gases
a. pH adjustment tank
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I. Gamma radiation
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1. times when respirator is required
1. Posted for Gamma radiation on SX uranium extractor mix tanks
ii. Uranium SX feed line
m. Ladders
1. Ladder on caustic tank
ii. Ladders on soda ash tanks
111. Ladders on salt tanks
iv. Ladder to sump -chain must be in place
v. SX VPL feed tank
v1. Strip make up tank
n. Decks and grating
i. Slippery when wet
o. Airborne uranium
p. Radon daughters
10. Hazard Recognition -Yellowcake Precipitation and Yellowcake Packaging
a. Sulfuric acid lines
i. Open valves slowly
ii. Use PPE
b. Ammonia
1. Open valves slowly
ii. Use PPE
111. Report leaks promptly
1v. Adjust pH properly so as not to use excessive ammonia
c. Steam lines and valves
i. Open valves slowly
11. Caution hot valve handles
d. Air lines and valves
i. Open valves slowly
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ii. Whip checks on hose connections
iii. Do not use to blow off clothing
e. Guards
1. Pump
11. Drive units
iii. Centrifuges
1v. Driven rollers
v. Augers
f. Centrifuges
1. Lock out when operator changes keys
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11. Check guards on auger before working on centrifuges
g. Health hazards
i. Ammonia
11. Sulfuric acid -H2S in area
iii. Airborne uranium
1v. Beta/Gamma-Radon daughters
1. yellowcake precipitation
2. enclosure
3. centrifuge area
4. packaging area
v. scrubber-barometric tank
vi. Radiation Wok Permit will be issued for any work in departments other than
Operations.
vii. Sampling will be done in this area on regular basis
1. radon -monthly
2. airborne
a. weekly
b. monthly
3. ammoma
a. monthly -or whenever need arises
4. silica
a. at least two samples yearly
h. Decks and walkways
1. Slippery after washdown
ii. Hoses in walkway and on deck
iii. Sampling equipment
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1. Heat
1. Dryer enclosure -up to 150°F
ii. Scrubber deck -off gas dryer ducting
m. Scrubbers
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11. Hazard Recognition -AMV (vanadium) Precipitation
a. Sulfuric acid lines and valves
i. Open slowly
11. Use PPE
iii. Report leaks immediately
b. Ammonium sulfate
1. Open valves slowly
ii. Caution when lifting and dumping bags
iii. Use PPE
c. Anhydrous ammonia
i. Open valves slowly
ii. Report leaks promptly
iii. Use PPE
d. Soda ash
i. Open valves slowly
11. Caution when lifting and dumping bags
iii. Use PPE
e. Steam lines
i. Open valves slowly
ii. Caution hot valve handles
iii. Use PPE
f. Air lines
i. Open valves slowly
ii. Whip checks on hose connections
iii. Do not use to blow off clothing
g. Roof
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1. Caution when climbing ladders -pipe in deck at bottom of roof access ladder
ii. Cleaning bucket elevator on roof requires equipment lock out
iii. Caution when cover plate is removed on bucket elevator
h. Precipitation area
i. Guards
1. drives
2. demister fan
ii. Low roof beams
1. above #1 precipitation tank
2. above #2 precipitation tank
iii. decking
1. sections lift up for sampling
2. holes for sampling
3. decks slippery when wet
4. ladders and stairs slippery when wet
5. slip and trip hazard when carrying and dumping soda ash
i. Filtrate belts
i. Head and tail pulleys -pinch point
ii. Return idlers -pinch points
iii. Drive -pinch points
j. Augers
1. #1 auger has to be stepped over
ii. Guards
iii. Concrete floor slippery when wet
k. Hoisting and dumping Wet AMV from drums
i. Caution around drum dumper
ii. Caution around rollers
iii. Caution around propane gas lines
iv. Caution around auger with covers removed
1. Hazards at Ammonium Sulfate Mix Area
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i. Guards
11. Augers
iii. Deck and stairs slippery when wet
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iv. Caution while lifting and dumping ammonium sulfate bags
m. Hazards at VPL tanks
i. Hot liquid
11. Steam lines and controls -PPE
iii. Deck slippery when wet
IV. Guards on pumps
n. Hazards at Ammonium Sulfate pump area
1. Guards on pump
ii. Deck slippery when wet
0. Hazards at Wet Storage Bin
1. Augers
ii. Guards
lll. Head and tail pulleys on feed belt
iv. Deck and stairs slippery when wet
p. Hazard at Bucket Elevator Bottom
1. Lock out before cleaning
ii. Caution when shoveling wet material into bucket elevator -with bottom cover
removed
iii. Caution around cyclone -very hot
q. Health Hazards
i. Ammonia fumes
1. full face respirator with combination filters required
11. Hearing protection -required in Vanadium Building
iii. Radiation
1. airborne -sampled monthly
2. beta/gamma -sampled monthly
3. radon daughters -sampled monthly
1v. PPE-gloves, rubber boots
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12. Hazard Recognition -AMV (vanadium) Dryer Area
a. Rotary dryer
1. Guards must be in place
ii. Open carrier rollers
111. Dryer is hot
iv. Propane gas lines
v. Auger and conveyor
1. feed belt -guards
2. return idlers -covered
3. feed belt to Deammoniator -idlers not covered
4. auger to Deammoniator feed belt
vi. Bucket elevator
1. caution when cleaning up with door off
2. cyclone is hot
3. fan east of bucket elevator
b. Health hazards
1. Fumes -ammonia and vanadium required full face respirator with dual cartridges
ii. Vanadium dust from rotary dryer
iii. Heat from dryer and heat rising from Deammoniator and fusion furnaces
1v. Decks and stairways are slippery when wet after washdown
v. Hearing protection
v1. Radiation
1. airborne uranium
2. radon daughters
3. beta/gamma
13. Hazard Recognition -AMV (vanadium) Packaging Area
a. Drums
1. Stacking of empty drums
11. Rolling full drums on rollers
iii. Training and forklift safety
1. seat belts must be worn at all times
iv. Impact wrench-safe use of
b. Filling of drums
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1. Auger outside enclosure
1. guard must be in place
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11. Drum tops must be up close to feeder hood to eliminate dust exposure
c. Health hazards
1. Vanadium dust
1. coveralls must be worn
2. full face respirators
3. gloves
11. Heat
1. from fusion furnace area
2. hydration liquids provided
m. Hearing protection
1. required in vanadium building
iv. Radiation
1. airborne uranium
2. radon daughters
3. beta/gamma
14. Hazard Recognition -Deammoniator Area
a. Hazards
1. Heat or hot surfaces
1. ducting (steel)
2. cyclone -auger and bin
3. deammoniator (surface)
4. doors
a. opening of outer doors
i. use of gloves
11. close doors when finished raking
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b. inner doors
1. use of gloves
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11. hearths average 500°F to 1000°F
iii. caution when raking clinkers from deammoniator
1v. caution -do not rake material past outer door
v. rake handles and doors are extremely hot
v1. handrails are hot in all areas around deammoniator
v11. close doors when finished raking clinkers
11. V 20s Control Room
1. MCC panel
a. Keep all doors closed on panel
b. Be careful when washing down
c. Floor is slippery when wet
d. Air conditioner installed to relieve heat from control room
e. Only company electricians can access.
111. Fusion furnace area
1. fusion furnace feed augers
a. hot -approximately 500 -l000°F
b. guards on drives
c. guards on deammoniator drive
d. augers must be locked out before cleaning or maintenance
work
e. door on chute must be replaced prior to starting auger
2. fusion furnaces
a. spouts
1. be extremely cautious when drilling or chipping out
spout with casting wheel running
ii. splattering caused from material (hot) falling off
casting wheel
iii. rotating casting wheels are hot
1v. No One is permitted beyond handrails above casting
wheel while in operation
v. Handrails are extreme I y hot
3. casting wheels
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a. points for accident potential
1. between bucket elevator and wheels
11. between fusion furnaces and wheels
iii. between augers and casting wheels
lV. Deammoniator
1.
V. Fusion furnaces
1.
b. Health hazards
chipping of fused material off rabel arms
a. safe work permit
b. lock out all equipment
C. air lines -whip checks
d. PPE
1. Leather gloves
11. Full face respirator
iii. Cotton coveralls
chipping of spouts
a. rotating casting wheels
b. using bars above rotating casting wheels
c. if completely plugged
1. shutdown lock out
ii. air drill -whip check, long steel and be qualified to
operate air drill
iii. lock out feed auger
iv. adjustable spout burners will be adjusted before
starting casting wheels
i. Heat
1. ice water and or Gatorade will be supplied
2. cotton coveralls -sleeves intact will be worn in this area -
furnished by company
3. leather gloves
11. Vanadium dust
1. coveralls -furnished by company
2. leather gloves -furnished by company
3. one-half hour paid for showers
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4. eye wash stations
5. full face respirators are required
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6. sampling for vanadium dust will be accomplished per corporate
directives
7. hearing protection required
iii. Radiation
1. airborne uranium
2. radon daughters
3. beta/gamma
15. Hazard Recognition -Vanadium Black Flake Packaging Area
a. Heat
i. From fusion furnaces
11. From V 20s bin
iii. From bucket elevator
1v. Casting wheels
v. Dearnmoniator
vi. Coveralls long sleeved will be supplied
v11. Water or Gatorade will be supplied
b. Drums
1. Stacking of drums
11. Rolling drums on rollers
iii. Standing on rollers to install drum lids
1v. Training and forklift safety
v. Seat belts must be worn when using equipment
v1. Safe use of impact wrenches
c. Filling of drums
i. Hood on feeder must be on rim of drum
11. V20s bin must not be leaking above operator area. If it leaks, report immediately.
m. Caution when working on star feeder -MUST BE LOCKED OUT
1v. Caution around casting wheel dump chute when shoveling spilled material.
v. Use of air to blow off scales only. Use water for rest of area.
vi. Do not spray water onto fusion furnace shells.
d. Health hazards
i. Vanadium dust
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1. coveralls -long sleeve
2. full face respirators
3. gloves
4. vanadium dust sampling will be done as needed
5. ammonia fumes from V 20s scrubber thickener
ii. Hearing protection
iii. Radiation
1. airborne uranium -sampled monthly
2. radon daughters -sampled monthly
3. beta/gamma -sampled monthly
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Module CS: HAZCOM
1. Hazardous Material
a. Any substance or material in a quantity and form which may pose an
unreasonable risk to Safety, Health, Property and Environment
2. Hazard Classes
a. Corrosive -A material that causes the destruction of living tissues and metals
b. Flammable Liquid-A liquid with a flash point below 100°F.
c. Combustible Liquid-Liquids with a flash point between 100° -200°F.
d. Flammable Gas -Any compressed gas which is either a mixture of 13 present or
less (by volume) with air that forms a flammable mixture or the flammable range
with air is wider than 12 percent regardless of lower limit.
e. Non-Flammable Gas -Any compressed gas other than a flammable compressed
gas.
f. Oxidizer -A substance that yields oxygen readily to stimulate the combustion of
organic matter such as chlorate.
g. Toxic -The ability of a chemical, such that very small amount are able to produce
injury to susceptible tissues by a chemical action.
h. Radioactive -A material that spontaneously emits radiation.
3. Product Identification
a. Manufacturer
b. Address
c. Emergency telephone number
d. Chemical name
e. Trade name
4. Hazardous Ingredients
a. Chemical names
b. Percent of Hazardous Ingredients
c. Exposure Limits
i. PEL -Permissible Exposure Limit
ii. TL V -Threshold Limit Value
iii. TWA -Time Weighted Average
5. Physical Data
a. Boiling Point
b. Vapor density (Air= 1)
c. Solubility in Water
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d. Specific Gravity (H20 = 1)
e. Percent Volatile (volume)
f. Evaporation Rate
g. Vapor Pressure
h. Appearance (color)
1. Odor
6. Fire and Explosion
a. Flash point
b. Flammable limits
c. Extinguishing Media
d. Special fire-fighting procedures
e. Unusual fire and explosion hazards
7. Health Hazard Information
a. Threshold Limit Valve
b. Symptoms of Overexposure
I. Inhaled vapor
ii. Skin contact
111. Eye contact
IV. Swallowed
V. Aspiration into lungs
C. First aid emergency procedures
I. Swallowed
ii. Eye contact
111. Skin contact
IV. Inhaled
V. Suspected cancer agent
8. SDS
a. Safety Data Sheets
b. Why are they important
c. Information contained
d. What chemicals must have them
9. Labeling requirements
a. New products
b. Day use products
c. Multiple shift products
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AppendixD
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Radiation Safety Training
Module Dl: RADIATION AND RESPIRATORY PROTECTION SAFETY TRAINING
OUTLINE FOR NEWLY HIRED INEXPERIENCED MILL WORKERS
Module D2: RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED
EXPERIENCED MILL WORKERS
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Module Dl: RADIATION AND RESPIRATORY PROTECTION SAFETY TRAINING
OUTLINE FOR NEWLY HIRED INEXPERIENCED MILL WORKERS
1. Video -"Practical Radiation Safety" or "Radiation Naturally"
2. Fundamentals of Health Protection
a. The radiologic and toxic hazards of exposure to uranium and its daughters
1. U-238 is a kidney toxin
11. Lungs
iii. Liver
iv. Skin
b. How uranium and its daughters enter the body
i. Inhalation
ii. Ingestion
m. Skin penetration
c. Why exposures to uranium and its daughters should be kept ALARA
1. Definition/explanation of the ALARA principle
11. Identification of postings in elevated areas
iii. Reference potential hazards with material and why it is important to
maintain levels to ALARA
d. Different types of radiation
1. Alpha
1. Will not penetrate dead layer of skin
2. Travels about 2 inches in air
3. Can be blocked by a single sheet of paper
4. Large particle that is the easiest to protect against, but the one that can
cause the most damage when taken internally. The delicate internal
workings of the living cell forming the lining of the lungs or internal
organs, most certainly will be changed (mutated) or killed outright by
the energetic alpha particle.
5. Housekeeping and good personal hygiene are critical.
ii. Beta
1. Can be blocked with plastic or PPE
2. Penetration greater than Alpha
3. Can penetrate the first two layers of skin
4. Second largest particle.
5. Travels about one meter in the air.
iii. Gamma
1. Smallest in size
2. Can be blocked by lead
3. Is capable of damaging living cells as it slows down by transferring
energy to the surrounding cell components
1v. Radon Progeny
1. Inert gas
2. Transported by carrier (water, diesel smoke, etc ... )
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3. Ventilation is principle remedy
4. Found in soils worldwide
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e. Various types of radiation exposure potential at the Mill
1. Conventional Ore -stockpiles and in process
11. Yellowcake product -in process and final product
iii. Alternate feed materials -stockpile (by various supplier) and in process
1v. Miscellaneous -sealed sources
3. Personal Hygiene at the White Mesa Mill
a. Wearing protective clothing
1. Importance -how the PPE protects against Alpha and/or Beta/Gamma
activity
11. Types of PPE available
1. Tyvek
2. Coveralls
3. Rubber suits/gloves
4. Respiratory Protection
b. Using respiratory protective equipment correctly -See item 4
c. Eating, drinking and smoking only in designated areas
1. Regulated by the State of Utah and MSHA
ii. Weekly alpha survey
111. Reducing potential for exposure
iv. Wash hands regardless of job assignment
d. Using proper methods for decontamination
1. Showers requirements
1. Mandatory for Yellowcake Operators
11. Laundry facility
4. Respiratory Protection Training
a. General
i. Video on Respiratory Protection
11. Program evaluation and revisions and record keeping
m. Employee training and documentation
iv. Fit Testing
1. Medical Clearance
2. Fit Tester 3000
3. Irritant smoke
v. Exchange/Issuance requirements -Daily Exchanges are required for all
devices
vi. Storage and care of device
b. Hazards to which the respirator wearer may be exposed, the effects of
contaminants on the wearer if the respirator is not worn properly and the
capabilities and limitations of each device that may be used
1. Respiratory Hazards
1. Uranium airborne and effect
2. Radon daughters and effect
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3. Chloride and effect
4. Ammonia and effect
5. Airborne vanadium dust and effect
6. Acid gases and effect
7. Other potential effects
11. Respirator selection
1. Types of respirators, their function, limitations
a. Full-face with combo cartridges -good for all environments at the
facility (pf of 50)
b. PAPRs -good for only dusty environments, not good for any
environment that may contain chemical mists (pf 1000)
c. SCBAs -good for all environments, has one thirty-minute bottle of
air (pf 10000)
d. NIOSH and MSHA approved respirators only
2. Identification of hazards
a. 02 content
b. Routine hazards
c. Non-routine hazards
c. Spectacle adapters, communications equipment and other equipment that will be
used directly in conjunction with the respirator are to be attached and operated
properly
i. At the White Mesa Mill, we only use the spectacle adapters. Spectacle
adapters are used for individuals who have prescription eyewear. The
adaptor is used so that there is not an issue with the arms of the glasses
potentially breaking the seal of the device.
11. Each employee who has to wear prescription eyewear must present a copy
of their current prescription to the Safety Department and the devices will be
ordered.
111. After the spectacle adapter has arrived, the Safety Department will train
each wearer on the proper care, maintenance and installation of the device.
This training is documented with a signed training certificate by both the
instructor and wearer and the document is then placed in the file in the
Radiation Office files.
d. Demonstration in donning, using and removing each type of respiratory protective
device that may be used
1. Wearing Instructions and training
1. Donning, wearing and removing the respirator
2. Adjusting the respirator so that its respiratory-inlet covering is properly
fitted on the wearer and so that the respirator causes a minimum amount
of discomfort to the wearer
3. Allowing the respirator wearer to wear the respirator in a safe
atmosphere for an adequate period of time to ensure that the wearer is
familiar with the operational characteristics of the respirator
4. Have each employee perform the donning for each device they may have
to wear while on property
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e. Instruction in how to inspect each type of respiratory device that may be used and
be instructed to perform such an inspection before donning any device
1. Field Inspection
1. Valves
2. Body of Mask
3. Straps
4. Lens
5. Air lines
1x. Respirator Sealing Problems
1. A person who has hair (stubble, mustache, sideburns, beard, low
hairline, bangs) which passes between the face and the sealing surface of
the face piece of the respirator shall not be permitted to wear such a
respirator.
2. A person who has hair (mustache, beard) which interferes with the
function of a respirator valve(s) shall not be permitted to wear such a
respirator.
3. The only facial hair that will be authorized while wearing a full-face
respirator is a small maintained mustache that does not extend below the
corners of the mouth. For use of a half mask respirator, the wearer must
be clean shaven. For the half mask wearer this means no beards, goatee
or mustaches.
4. A spectacle which has temple bars or straps which passes between the
sealing surface of a respirator full face piece and the wearer's face shall
not be used.
5. A head covering which passes between the sealing surface of a respirator
face piece and the wearer's face shall not be used.
6. The wearing of a spectacle, or goggle, a face shield, a welding helmet, or
other eye and face protective device which interferes with the seal of a
respirator to the wearer shall not be allowed.
7. If scars, hollow temples, excessively protruding check bones, deep
creases in facial skin, the absence of teeth or dentures, or unusual facial
configurations prevent a seal of a respirator face piece to a wearer's face,
the person shall not be permitted to wear the respirator.
8. If missing teeth or dentures prevent a seal of a respirator mouthpiece in a
person's mouth, the person shall not be allowed to wear a respirator
equipped with a mouthpiece.
9. If a person has a nose of a shape or size which prevents the closing of
the nose by the nose clamp of a mouthpiece/nose clamp type of
respirator, the person shall not be permitted to wear this type of
respirator.
k. Instruction in how to perform a user seal check on face sealing devices and how
to perform this user seal check each time this type of device is donned
1. Refer to "d" of this section.
2. Demonstrate the proper techniques for performing a field positive and
negative pressure test.
3. Have each employee perform this task. (pass/fail)
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4. Emphasis to each employee the importance of performing this task each and
every time the seal has been broken.
1. Information that any respirator user may leave the work area at any time for relief
from respirator is in the event of equipment malfunction, physical or
psychological distress, procedural or communications failure, significant
deterioration of operating conditions, or any other condition that might necessitate
such relief
1. A respirator wearer shall be permitted to leave the hazardous area for any
respirator-related cause. Reasons which may cause a respirator wearer to
leave a hazardous area include, but are not limited to, the following:
a. Failure of the respirator to provide adequate protection
b. Malfunction of the respirator
c. Detection of leakage of air contaminant into the respirator
d. Severe discomfort in wearing the respirator
e. Increase resistance to breathing
f. Illness of the wearer, including: sensation of dizziness, nausea, weakness,
fatigue, breathing difficultly, coughing, sneezing, vomiting, fever or chills.
g. Claustrophobia, anxiety or other psychological factors that may affect the
wearer
h. Emergency respirator use
i. SCBA -Self-Contained Breathing Apparatus
ii. Emergency respirator issuance
iii. Only Certified individuals may use these devices
Be advised that in case of respirator malfunction or wearer distress, the respirator
may be removed as the respirator user exits the airborne contamination area
m. Each respirator wearer must understand that during any problem with the device
or distress, the device can be removed upon exiting the contamination area. A
report of the incident should be given the Safety Watch and the Safety
Department immediately.
5. Facility Provided Protection
a. Ventilation systems and effluent controls
1. Explain the Demister and Scrubber system
ii. Negative pressure is Yellowcake Dryer and Packaging Enclosures
b. Cleanliness of the workplace
i. ALARA and the importance of the principle
11. Prevention of the spread of materials
m. Wash down of work areas
1v. Prompt notice and cleanup of materials if spilled
v. Wash hands regardless of job assignment
c. Features designed for radiation safety for process equipment
1. Ventilation system in the process areas
ii. Remote access for packaging operations
d. Standard operating procedures
1. Each circuit's SOP addresses the specific radiation concerns
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ii. Knowledge of the SOP's and radiation concerns of one's circuit is
needed prior to commencement of any work activity
111. Radiation Work Permit (RWP)
e. Security and access control to designated areas
1. Restricted Area requirements
ii. Identification cards needed to access the Restricted Area
111. Access to the Product Storage Yard
1v. Surveillance cameras around the facility
v. 24-hour coverage by a member of the Radiation Staff
f. Electronic data gathering and storage
g. Automated processes
i. Nuclear Density Gauges
h. Postings
1. "Radioactive Materials Area" -This sign designates the Restricted
Area and signifies that one may come in contact with radioactive
materials once one has pasted the signage.
11. "Caution Radiation Area" -Beta/Gamma values at or above 5.0
rnR/hr. This posting means reduction in time and increase distance
from source or added shielding is required.
111. "Caution Airborne Radioactivity Area" -Alpha activity value at or
above 25% of the corresponding DAC value. Respirators required
prior to entering area and increased bioassays.
6. Health Protection Measurements
a. Measurements of airborne radioactive materials
1. Alpha Monitoring
11. Area Airborne
iii. Radon Progeny
1v. Beta/Gamma
v. Breathing Zones
b. Bioassays to detect uranium (urinalysis)
1. Entrance/Exit Monitoring
11. Schedule
1. Monthly during production periods for all employees
2. Bi-monthly for employees working in ore handling and yellowcake
packaging operations. Also for declared pregnancy workers.
111. Action limits of uranium detection in the bioassays
1. 0 to 14 µg/L
a. Continue to review further bioassay results
2. 15 to 35 µg/L
a. Obtain additional sample
b. Identify the cause of the elevated sample
c. Examine air sampling data to determine the source of intake
d. Determine if other workers could have been exposed.
e. Consider work assignment limitations
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f. Improve uranmm confinement controls or respiratory
protection
3. Over 35 µg/L
a. Take actions given above
b. Continue operations only if it is virtually certain no other
worker will exceed the concentration
c. Establish work restrictions for affected employees
d. Weekly bioassays
1 v. Investigation of potential uptake
v. Mitigation of uptake
c. Surveys to detect contamination of personnel and equipment
1. Exit Alpha Monitoring -leaving the Restricted Area
ii. Break Times -Entering into a designated eating area
111. Spot checks
1v. Equipment releases and the limits for the facility
1. Alpha Personnel Release Rate (1,000 dprn/100 cm2)
2. Alpha values for unrestricted release
a. Removable 1,000 dprn/100 cm2
b. Average 5,000 dprn/100 cm2
c. Maximum 15,000 dprn/100 cm2
3. Beta/Gamma limits for unrestricted release
a. Average 0.20 rnR/hr.
b. Maximum 1.0 mR/hr.
d. Personnel dosimetry
1. OSL
e. Potential Sources of Exposure at the facility
1. Conventional Ore Dust
11. Alternate feed materials
iii. Yellowcake
1v. Tailings
v. Obsolete Equipment
f. Ways to reduce exposure
1. Time -limiting the amount of time one spends in a given work
environment. Example is only allowing a certain amount of time to be
allowed in an RWP.
ii. Distance -creating a separation between oneself and the source of
exposure. Example is remote handling of material.
111. Shielding -placing a barrier between oneself and the source. Example
is a respirator.
7. Alpha Contamination Training
a. Proper use of the personnel alpha monitor
b. What to do if the alarm were to sound and who to contact
c. Documentation of the training session and acceptance of possible disciplinary
actions for failure to comply with the regulation
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8. Prenatal Radiation Exposure
a. Presentation of NRC information
b. Discussion of increased monitoring
c. Completion of Form
9. Any Handouts -Addenda D1
10. Radiation Protection Test
11. Respiratory Protection Test
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Module D2: RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED
EXPERIENCED MILL WORKERS
The following topics will be discussed:
1. Review of Key Radiation Safety Topics
(a) At the discretion of the instructor, review selected key radiation safety topics, such as one
or more of the topics set out in the handouts included in Addenda D 1 or in the Radiation Safety
Training outline, as necessary to ensure that the worker has an equivalent level of knowledge
as a newly hired inexperienced worker who has completed his or her training, depending on the
level of knowledge and experience of the worker.
(b) At the discretion of the instructor, distribute one or more handouts for the worker's
review and reference, such as one or more of the documents entitled "Radiation Protection at
the Mill," or "Radiation Information Handout" set out in Addenda Dl
2. Site Specific Training
(a) Where the worker has received his or her previous radiation safety training at another
facility, provide site specific training as necessary, in the discretion of the instructor.
3. Relevant information that has become available since the worker's last radiation safety
training or refresher training
(a) Processing changes that may affect exposures
(b) Posting changes, if any
(c) Discussion of air, radon and beta/gamma survey results
(d) Changes to SOP's that affect Radiation Safety
4. Review of safety problems that have arisen since the worker's last radiation safety
training or refresher training
(a) Discuss issues that have been raised through daily and weekly inspections
(b) Housekeeping issues
(c) RWP's
5. Changes in regulations and license conditions since the worker's last radiation safety
training
(a) Discuss changes that affect the operation or other activities in the Mill
(b) Discuss NOV's or recommendations from the DRC
6. Exposure trends
(a) Average exposure for the previous year
(b) Highest exposure for the previous year
( c) Comparison of exposures versus background
(d) Discussion on the exposures rates received and how those results compare with the
ALARAgoals
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7. Other current topics
(a) Discuss any problem areas that may have arisen
8. Respirator Training
The following are to be completed
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• Worker will demonstrate how spectacle adapters communications equipment, and other
equipment that will be used directly in conjunction with the respirator are to be attached
and operated properly;
• Worker will demonstrate competency in donning, using, and removing each type of
respiratory protective device that may be used;
• Worker will demonstrate how to inspect each type of respiratory protective device that
may be used and instruct the worker to perform such an inspection before donning any
device;
• The Worker will check on face-sealing devices and instruct the worker to perform this
user seal check each time this type of device is donned;
• Inform the worker that any respirator user may leave the work area at any time for relief
from respirator use in the event of equipment malfunction, physical or psychological
distress, procedural or communications failure, significant deterioration of operating
conditions or any other condition that might necessitate such relief; and
In case of respirator malfunction or wearer distress, the respirator may be removed as the
respirator user exits the airborne contamination area.
9. Prenatal Training
(a) Presentation of NRC information
(b)
(c)
Discussion of increased monitoring
Completion of Form
10. Radiation Protection Test
11. Respiratory Protection Test
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Addenda D1: HANDOUTS
Handout 1: RADIATION PROTECTION AT THE WHITE MESA MILL
Handout 2: RADIATION INFORMATION HANDOUT
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Handout 1: RADIATION PROTECTION AT THE WHITE MESA MILL
1. Radiation
High levels of radiation are harmful to us. The amount of radiation a person is exposed to is
refen-ed to as his or her "dose" and is typically measured in millirems (mrems) per year.
We are exposed to radiation from natural sources such as the sun, the soils and rocks around us
as well as the air we breathe. We are also exposed to radiation from other sources such as x-rays
performed in connection with medical and dental examinations. In the Blanding area, each
member of the general population is exposed to about 400 mrem per year from these natural
sources, not counting things such as x-rays.
2. Exposure Limits
In order to protect workers from excessive exposure to radiation, the Nuclear Regulatory
Commission (NRC) has set maximum doses that workers can receive each year from working at
facilities such as the White Mesa Mill. Under these standards, the maximum total dose from all
sources at the Mill, over and above background radiation from natural sources, is 5,000 mrem
per year.
In addition, the NRC requires that each facility make efforts to keep exposures to workers As
Low as is Reasonably Achievable (ALARA) below the 5,000 mrem/yr. limit. In accordance
with this requirement, the Mill has set an ALARA goal at 1,250 mrem/yr. for each worker, over
and above natural background. This goal is 25% of the regulatory standard of 5,000 mrem/yr.
Exposures to Mill workers are typically well below this ALARA goal, being usually in the 80
mrem/yr. to 400 mrem/yr. range above background.
3. How we Keep Exposures to Radiation to a Minimum
One of our prime objectives is to keep radiation exposures to Mill workers to a minimum. This
not only requires the efforts of Energy Fuels. It also requires the efforts of each Mill worker to
keep his or her exposures to a minimum. In order for workers to be able to do this, a proper
understanding of radiation, how you can be exposed to it and what precautions you can take are
extremely important. These topics are summarized below.
4. Types of radiation
There are five types of ionizing radiation: alpha, beta and gamma radiation, being the prevalent
sources of exposure at the Mill, as well as x-ray and neutron radiation, which are of lesser
concern at uranium milling facilities.
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4.1 Alpha Radiation
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Here at the White Mesa Mill, we work with uranium, one of those elements that is naturally
radioactive. Uranium is an alpha emitter. Alpha radiation doesn't travel very far, even in air.
The range in air for alpha radiation is about 1.25 inches. A single sheet of paper can block
alpha radiation. Even the skin layer on our bodies stops alpha radiation. So, outside of our
body, alpha radiation is really no problem. What about inside the body? Breathing uranium
dust or swallowing uranium dust is the problem. Uranium in the human body tends to seek
the bones and kidneys (i.e., to collect there), where it can cause damage.
In addition, radon gas, which comes primarily from uranium ores and tailings, emits alpha
radiation and is in the air we breathe at the Mill. There is no smell or taste to radon gas, and
you can't see it. Breathing high levels of radon in the air is also harmful to us.
4.2 Beta Radiation
Beta radiation does not travel very far in air, but it can penetrate the body, so merely being
close to a source of beta radiation will result in exposure to radiation. It is not necessary to
breathe in or swallow beta emitting particles, although that would also be another way that
beta radiation could enter your body.
However, because most of the radiation associated with the uranium process is alpha
radiation, beta radiation is not much of a problem at the Mill. While exposures to the body
merely from being close to beta radiation are minimal at the Mill, internal exposure to beta
radiation that enters the body through inhalation or ingestion of radioactive dust is a concern.
For example, as uranium decays some beta radiation is emitted, especially where aged
yellowcake is concerned, so personal hygiene in the yellowcake processing portion of the
Mill is important.
4.3 Gamma Radiation
Gamma rays are constantly being emitted from the raw ore. Like beta radiation, gamma
radiation can penetrate the body, so being close to a source of gamma radiation will result in
exposure to radiation. However, gamma radiation is stronger, can travel further in air and
can penetrate the body more readily than beta radiation. As with beta radiation, it is not
necessary to breathe in or swallow gamma emitting particles, although that would also be
another way that gamma radiation could enter your body.
Gamma radiation at the Mill is mainly associated with raw ores, tailings solids and some
alternate feed materials. So the people working in the ore piles, bucking room, tailings or
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close to certain alternate feed materials should have the highest exposure to gamma radiation
here at the Mill site.
In addition to these sources of gamma radiation, there are 11 nuclear density gauges in the
Mill complex. These gauges contain the gamma emitter Cs-137. The Cs-137 is retained in a
container which is in-turn housed within a shielded containment (referred to as the "pig") in
order to provide protection to workers from the unshielded source. These devices are labeled
with the tri-foil radiation symbol, and in-plant gamma surveys are conducted in the
immediate area of these sources to assure that gamma radiation levels are maintained
ALARA. These sources of Cs-137 must remain in their shielded containment. They must
also be tested periodically. However, they may only be removed from their shielding, tested,
serviced or removed from installation by a specifically licensed outside contractor.
4.4 X-Rays
There are no direct sources of x-radiation at the Mill, thus exposure to x-rays is minimal and
only related to minor emissions of x-radiation associated with the uranium decay chain. X-
radiation is similar to gamma radiation in that it is penetrating and considered to be an
external source of exposure to the body. Because the Mill's radiation safety staff measures
gamma radiation and any x-rays will be an element of those readings, the protections
provided for gamma radiation also protect from the minor influence of x-rays at the facility.
For these reasons, x-rays require no additional consideration at the Mill.
4.5 Neutrons
There are no sources of neutron radiation associated with the uranium milling process.
However, when earthen construction projects are underway at the Mill, such as tailings cell
construction, construction contract personnel may use neutron gauges to measure soil
moisture and density conditions for construction purposes. These devices are not owned or
operated by Energy Fuels, and any licensing of the gauges is the responsibility of such
contractors. As a result, Energy Fuels employee exposure to these sources is negligible and
could only occur near the gauge when in operation.
4.6 Radioactive Dust is the Main Concern at the Mill Site
As can be seen from the discussion above, radiation that enters the body through the
inhalation or ingestion of dust is the main concern at the Mill site. Keeping dust to a
minimum and providing protection to workers to minimize their exposure to radioactive dust
is therefore a primary objective. Radon is usually not a problem, unless in confined spaces.
Exposures from being close to beta/gamma radiation is also not usually as big a concern at
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the Mill site, due to the relatively low levels of those types of radiation found at the Mill. X-
rays and neutron radiation are of minor concern at the Mill.
5. Exposure Pathways and Precautions to be Taken
Radiation can enter the body in three different ways:
5.1 Being Close to a Source of Gamma Radiation
Being close to ore, tailings or certain alternate feed materials will expose the worker to
gamma and beta radiation. The stronger the source, the closer you are and the longer you
spend close to the source will increase your exposure. Shielding, such as lead can be used in
some circumstances to reduce exposures to gamma and beta radiation, although shielding is
not commonly used at the Mill, due to the generally low beta/gamma radiation experienced at
the Mill.
Each worker is required to wear an OSL badge that records his or her exposure to beta and
gamma radiation. The OSL badge must be worn on the torso and must not be shielded by
clothing.
Areas where beta/gamma radiation is high (i.e. over 5 mrem/hr) must be posted as "Radiation
Areas").
The precautions we take at the Mill to keep exposure to beta/gamma radiation to a minimum
are:
• Keeping workers away from areas with high beta/gamma radiation. When you see an
area posted as a "Radiation Area" do not go near that area unless required to do so for a
specific task;
• Minimizing the time each worker is required to work in areas with elevated beta/gamma
radiation. This also involves rotating workers so that the time each worker spends in the
"Radiation Area" is kept to a minimum;
• Using shielding in some cases; and
• Engineered controls in our process to reduce exposures faced by workers.
5.2 Breathing in Radioactive Dust or Radon
Any dust at the Mill can be radioactive. Ore dust is radioactive. Dust from the ore pad is
radioactive. Dust from around the facility buildings can be radioactive. Yellowcake dust is
radioactive, and tailings dusts are radioactive. In addition, radon gas is radioactive and can be
found in all areas of the Mill facility and property. Radon gas is particularly dangerous in
closed areas, where it can accumulate.
The Mill monitors various areas of the Mill facilities and Mill properties for radioactive dust
and radon gas. Each worker is required to keep track of the time he or she spends in each area
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of the Mill each day and record these times on his or her Exposure Time Sheet. This allows
Mill Radiation Safety Staff to calculate how much exposure to radiation the worker has had
each day by determining how much time each worker spends in each area and by calculating
the exposure for the time spent in each area based on the monitoring results for that area.
This is why it is important for each worker to carefully and accurately fill out his or her
Exposure Time Sheet each day.
The precautions we take to keep exposures to radioactive dust and radon to a minimum are
the following:
• Good housekeeping is important in order to keep dust to a minimum within facility
buildings;
• Water is sprayed on the ore pad and other areas of the Mill property in order to keep dust
to a minimum;
• Posting and restricting access to areas where there is a potential for higher exposures to
radioactive dust;
• Respiratory protection is required in areas where there is a potential for higher exposures
to radioactive dust and/or radon, such as in the yellowcake packaging area where uranium
concentrate is being handled;
• Showers are available to all workers, and yellowcake workers are required to shower at
the end of their work shift;
• Non-routine projects that may result in radiation exposure are controlled by a Radiation
Work Permit where personal protective equipment (PPE) and additional monitoring (such
as breathing zone sampling) requirements can apply; and
• Work clothing remains at the Mill, and all workers entering the restricted area are
required to survey for alpha contamination prior to leaving the facility.
5.3 Ingesting Radioactive Particles
Ingestion of radioactive materials at the Mill is minimal but can occur directly by swallowing
dust that has entered your mouth or indirectly from contamination of food or other items a
person might put into his or her mouth. For these reasons, smoking, eating, chewing gum or
tobacco etc. are not permitted in working areas of the Mill. Eating is restricted to only
designated eating areas. You may smoke only in a designated area outside of the Mill's
restricted area. This exposure pathway is best controlled by personal hygiene principles such
as cleaning your hands before eating.
6. Monitoring and Calculation of Total Dose Received by the Worker
In order to ensure that worker exposure is maintained within the regulatory limits and the Mill's
ALARA goal, various monitoring methods are used to assess the worker's exposure. Air
samples are collected throughout the plant to assess concentrations of radioactive dust and radon
in the air, and the amount of time spent by workers in the various plant areas is recorded to
determine the inhalation exposure of each worker given his/her particular job assignment. In
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addition, gamma and beta exposure is monitored by means of personal exposure badges (OSL) to
assess individual exposure to external sources. The amount of exposure a worker receives from
radioactive dust, radon and beta/gamma radiation to the body are added up to determine the total
dose (referred to as the worker's Total Effective Dose Equivalent or TEDE) received by the
worker for the year. The worker's TEDE is then compared to the regulatory limits and the Mill's
ALARA goal.
Urine samples are also collected from workers to ensure that internal uptake of uranium is not
damaging kidneys and in some instances to determine uptake due to unusual circumstances. In
addition, and as mentioned above, workers are required to scan for alpha contamination as they
exit the restricted area to protect against offsite contamination and exposure.
7. Leaving the Mill Each Day
As can be seen from the information provided above, contamination control is important as a
means of minimizing exposure to radiation at the Mill. One of the more important places where
this control is necessary is when a worker leaves the Mill. Taking a shower, leaving work
clothes at the workplace and scanning out to ensure that you are not taking contaminants home
on your person are good practices to protect you and your family from offsite exposure. All
workers must scan before leaving the Mill's restricted area. All yellowcake workers must also
shower before leaving the restricted area.
8. Reporting
In order to determine that employee exposures are being maintained within the regulatory limits
and company goals, annual exposure calculations for each worker are completed by the
Radiation Safety Department. These reports are utilized to demonstrate compliance with the
standards, assess any trends in exposure and to provide a record to the individual worker. Each
worker receives an exposure report annually from the Radiation Safety Department.
9. Conclusion
Uranium is a naturally occurring radioactive element which can have harmful effects if not
properly monitored and controlled. At the Mill we can be exposed primarily to alpha, beta and
gamma radiation, and our exposures to those forms of radiation are limited by regulation and
company policy. Because uranium is primarily an alpha emitter, alpha radiation is the principle
type of radiation exposure at the Mill. This means that minimizing the inhalation or swallowing
of radioactive dust at the Mill is a primary objective.
The radiation you may be exposed to at the Mill is monitored by sampling the air you breathe
and measuring the external radiation received by your personnel exposure badge. The results of
this monitoring are evaluated and reported to you annually so that you are made aware of your
exposure.
While the company provides engineering controls to protect you from sources of radiation, each
employee must remain aware of conditions at the Mill. A voiding high radiation areas, wearing
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respirators where/when required, cleaning your hands before eating, avoiding dusty situations
and using contamination control procedures when you leave the property are individual
protections you can use to minimize your exposure to radiation at the Mill.
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Handout 2: RADIATION INFORMATION HANDOUT
(Summary of Key Concepts)
The following are items that are central to one's understanding of the Radiation Protection
Program for Energy Fuels Resources (USA) Inc. at the White Mesa Mill.
Definitions:
DACs:
• DAC -Derived Air Concentration
• ALARA-As Low As Reasonably Achievable
• NRC -Nuclear Regulatory Commission
• DWMRC-Division of Waste Management and Radiation Control
• TEDE -Total Effective Dose Equivalent (total dose from beta/gamma, as
measured by the OSL badge, air particulate and radon)
• CEDE -Cumulative Effective Dose Equivalent (dose from radon and air
particulate. Does not include the dose from beta/gamma)
• P APR -Powered Air Purifying Respirator
• SCBA -Self Contained Breathing Apparatus
• RWP-Radiation Work Permit
• OSL -Optically Stimulated Luminescence. Device used to monitor
beta/gamma exposure. Device must be worn in the center of the chest not on
the back of the hardhat.
• Restricted Area -Consists of all operational and disposal areas.
Radioactive dust (air particulate) has a different impact on our bodies depending on what stage
of the process or location of the facility we are in. This is because the combinations of uranium
and its daughters (Radium 226, Thorium 230 and Lead 210) are different in the different stages
of the process. For example uranium and its daughters have equal radioactivity levels in
conventional ores on the ore pad, but yellowcake is mostly uranium and has hardly any daughters
present. The DAC is the acceptable level of radioactivity in a particular area of the Mill, taking
into account the mixtures of radionuclides found in the area. It sets the level of radioactivity in
air particulate that you could breathe on a fulltime basis for an entire working year in that area of
the Mill before exceeding the regulatory limit. For example, the DAC for the ore pad is more
restrictive than the DAC for the yellowcake area, reflecting the fact that the mixture of
radionuclides on the ore pad is more harmful to our bodies for any given level of radiation.
However, even though the mixture of radionuclides found on the ore pad is more dangerous than
the mixture of radionuclides found in the yellowcake packaging area for any given level of
radiation, the radiation levels in the yellowcake area are much higher than on the ore pad, thus
making the yellowcake packaging area an area of higher radiation concern than the ore pad.
Postings:
• "Radioactive Materials Area" -signifies that anywhere beyond that point
there is the potential of coming into contact with radioactive materials. That
includes disposal areas, operational areas, product and raw ore.
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Bioassays:
• "Caution Radiation Area" -signifies that that area contains material that has
beta/gamma values at or above 5 mrem/hr. Areas that are posted as this are
the yellowcake dryer enclosures, centrifuges, packaging enclosure and some
alternate feed locations.
• "Caution Airborne Radioactivity Area" -signifies that an area contains
airborne alpha activity at or above 25% of the corresponding DAC and
respiratory protection is required. Areas that are posted as this are the
yellowcake dryers and packaging enclosure. The SAG Mill is sometimes
posted as an airborne activity area. It will all depend on the grade of ore being
processed.
Bioassays are collected from all employees. These samples are collected to test to see if
there has been a possible ingestion or inhalation of uranium. During production periods, every
employee is tested monthly. Some individuals, depending on their job assignment can be tested
weekly or every two weeks. Samples are also collected after the completion of special work
assignments, such as an RWP. Also, all newly hired individuals are tested to see if there is a
baseline of uranium in their urine. All employees upon their termination must submit a final
sample.
All bioassays are to be given prior to the beginning of one's shift and before one enters
the Restricted Area.
Exposure Limits:
The NRC states that all occupationally exposed employee shall not exceed 5 rem/yr. Our
ALARA limit is 25% or 1.25 rem/yr.
Scanning:
Every person who enters into the Restricted Area must scan themselves prior to exiting or
entering an eating area (within the Restricted Area). A proper scan consists of a slow brush of
the detector over the hands, arms, chest, legs and shoes. The meter should be kept at ¼" away
from the body in order to not puncture the mylar face of the probe. If the alarm sounds, hit reset
and scan that affected area again. If the meter alarms again, contact the Radiation Department.
A proper scan should take approximately 30 seconds.
Health and Hygiene:
Wash your hands regardless of your job assignment. Some positions at the facility
require mandatory showers. You are paid for that shower time, so make sure you do it. Also,
the facility is equipped with a laundry. Make sure you wash your work clothes periodically. Do
not take home any clothing or materials without having them scanned by a member of the
Radiation Department first.
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Radiation:
• Alpha-
o Will not penetrate dead layer of skin
o Travels about 1.25 inches in air
o Can be blocked by a single sheet of paper
o Large particle that is the easiest to protect against, but the one that can
cause the most damage when taken internally. The delicate internal
workings of the living cell forming the lining of the lungs or internal
organs, most certainly will be changed (mutated) or killed outright by
the energetic alpha particle.
o Housekeeping and good hygiene are critical
• Beta-
o Can be blocked by plastic or PPE
o Penetration greater than Alpha
o Can penetrate the first two layers of skin
o Second largest particle
o Travels about one meter in air
• Gamma -
o Smallest in size
o Travels furthest in air
o Can penetrate into and through your body
o Can be fully or partially blocked by lead or other shielding, depending
on the strength of the source, the distance you are from the source and
the type and thickness of the shielding
o Is capable of damaging cells as it slows down by transferring energy to
the surrounding cell components.
• Radon-
a Inert gas
o Transported by carrier (water, diesel smoke, etc.)
o Ventilation is principal remedy
o Found in soils worldwide
Three ways to reduce exposure from beta/gamma radiation:
• Time -by limiting the amount of time one spends in an area, one can reduce
the amount of exposure they receive.
• Distance -by creating a space between one's self and the source you can
reduce exposure.
• Shielding -by placing something between one's self and the source you can
reduce exposure. This can be done by placing a barrier, such as a wall, PPE
or other physical barriers between yourself and the source.
Ways to reduce exposure to alpha radiation:
• Dust minimization
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o Good housekeeping
o Water sprays on ore pad and roadways
o Dust collection systems at various points in the process
• Enclosed areas of high potential exposure to air particulate, such as
yellowcake areas
• Use of respiratory protection in areas of high potential exposure to air
particulate
• Designated eating areas
• Personal hygiene to minimize ingestion (e.g., washing hands before eating,
washing work clothes)
• Mandatory showers for yellowcake workers
• Mandatory alpha scan for everyone who leaves the Mill's restricted area
Respiratory Protection:
• Types of devices on site
o Full-face -with combo cartridges is good for both chemical and dusty
environments; has a protection factor of 100.
o P APR -is only good for dusty environments. Will not protect you in
a chemical mist type of environment; has a protection factor of 1,000.
o SCBA -is good for all environments, but only has a 30-minute bottle
of air; has a protection factor of 10,000.
• Exchange policy -all respirators must be turned into the Radiation/Safety
Department on a daily basis.
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Annual Refresher Training
RADIATION SAFETY TRAINING OUTLINE FOR ANNUAL REFRESHER TRAINING
The following topics will be discussed in this training:
1. Relevant information that has become available during the past year
(a) Processing changes that may affect exposures
(b) Posting changes, if any
(c) Discussion of air, radon and beta/gamma survey results
(d) Changes to SOPs that affect Radiation Safety
2. Review of safety problems that have arisen during the year
(a) Discuss issues that have been raised through daily and weekly inspections
(b) Housekeeping issues
(c) RWP's
3. Changes in regulations and license conditions
(a) Discuss changes that affect the operation or other activities in the Mill
(b) Discuss NOVs or recommendations from the DRC
4. Exposure trends
(a) Average exposure for the previous year
(b) Highest exposure for the previous year
( c) Comparison of exposures versus background
(d) Discussion on the exposures rates received and how those results compare with the
ALARAgoals
5. Other current topics
(a) Discuss any problem areas that may have arisen
6. Review of Key Radiation Safety Topics
(a) At the discretion of the instructor, selected key radiation safety topics, such as one or
more of the topics listed on the handouts included in Addenda D 1 or on the Radiation Safety
Training outline.
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CONTRACTOR SAFETY RULES
[See Attached]
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CONTRACTOR SAFETY RULES
Contractor shall be responsible for compliance with all local, State, Federal and Company safety,
health and environmental laws and regulations in effect. Contractor shall also be held to
understand that this site is a State of Utah Division of Radiation Control licensed facility and is
governed by the rules and regulations of the Owner, State of Utah DRC and MSHA. Owner
requires that all work conducted by Contractor and its employees be performed in a responsible
manner with special attention and mutual cooperation on the part of everyone involved including
Contractor, its employees and the employees of the Owner.
As part of its Contractual obligation, Contractor and its employees are expected to abide by all
applicable safety rules. Mandatory (MSHA, OSHA, State or Company, etc.) safety and health
training must be received by all workers prior to starting any work on site. The rules listed
below are minimum basic Owner Safety Rules and Regulations; they do not in any way contain
every necessary rule. If the Contractor has questions concerning Safety Rules and Regulations,
Contractor shall consult with Owner's Representative before starting work.
The fact that other applicable rules, regulations or requirements (Federal, State or local) are not
printed herein will not be an excuse for any violation. Any violations of these rules and
regulations be it accidental or intentional may be cause for termination of this contract.
OWNER SAFETY RULES AND REGULATIONS
I. TRAINING
All contract employees must receive the training required by Owner prior to starting
work on site.
II. PERSONNEL PROTECTION
Hardhats, safety glasses, identification badges and steel toe shoes will be required
when entering the mill area. Whenever, work is performed in an environment, which
requires special protection, such as respirators, hearing protection, goggles or face
shield, wet suits, etc. this protection must be worn. If there is a question as to
whether this special equipment is required, contact the Owner's Representative.
Persons with hair that extends longer than two (2) inches below the T-shirt collar
must confine the hair.
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If respiratory protection is required a respirator fitness physical and fit test are
required. Any question regarding this subject shall be directed to the Owners
Representative.
Appropriate fall protection shall be worn at locations where there is a danger of
falling and/or where required by Owner.
III. RADIATION PROTECTION
The White Mesa Mill has a radioactive materials license with the State of Utah
Division of Radiation Control. Under that license, there are certain items that must be
observed by all parties on site. Those are, but not limited to:
a. Eating, drinking and chewing are only authorized in designated areas. These
areas are determined and posted by the Radiation Safety Officer. Potentially
contaminated PPE is not allowed in these areas.
b. All personnel, equipment and vehicles that enter into the restricted area, must be
surveyed for radiological release prior to leaving the restricted area. All mobile
equipment must travel through the decontamination wash station before being
presented for release from the site.
c. Before work assignments commence, the Contractor must present their job
assignment to the Radiation Department. The Radiation Department will
determine exposure potential and will issue a Radiation Work Permit if
applicable.
d. All Contractor personnel must submit to periodic bioassay monitoring for the
determination of potential uptake or ingestion of uranium.
e. Respiratory protection may be needed if there is determined that an area is
contaminated. If respiratory protection is required, the Contractor will provide
medical clearance for their personnel. Respiratory devices will only be issued
upon the successful completion of the medical evaluation and onsite respirator fit
testing.
f. Personnel must monitor him or her with the use of an alpha monitoring device
prior to leaving the restricted area. Monitoring locations are under surveillance to
ensure that proper techniques are being applied. Contractor personnel will be
trained in the proper use of these instruments.
g. Failure to comply with these items and others as deemed necessary by the
Radiation Safety Officer will be grounds for immediate termination of services at
the facility.
IV. HOUSEKEEPING AND STORAGE
Debris will not be allowed to accumulate. Regular removal to designated areas is a
requirement. Tools, equipment and materials will be stored in a safe and orderly
fashion that minimizes interference with operations or traffic. Upon completion of
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the job, Contractor shall remove all construction debris and leave the site neat and
orderly.
V. FIRE PROTECTION
a. Fire extinguishers are to be provided by Contractor and will be kept immediately
available when burning or welding in areas adjacent to combustible material.
They must not be obtained by removing Owner's extinguishers from established
locations.
b. The White Mesa Mill is a smoke free workplace. Therefore smoking is prohibited
in the administration building and the restricted area. It is necessary however to
post areas as no smoking areas wherever flammables are stored.
c. No person shall use open flames within 50 feet of where flammable materials are
stored.
d. Combustible material; i.e., grease, lubricants, flammable liquids, etc. shall not be
allowed to accumulate where they can create a fire hazard.
e. Personnel must be familiar with site emergency procedures; i.e. fire drills
evacuation drills, etc. as instructed by the Owner's Representative.
f. Fire alarm procedures will be provided by Owner's Representative.
g. Flammable liquids (flash points below 100°F) shall not be used for cleaning
purposes.
h. Containers of combustible or flammable liquids shall be bonded and grounded
whenever liquid is being transferred; hose must be in metallic contact during
transfer.
1. Flame permits will be used where required by Owner's Representative.
J. Flammable or combustible materials must be stored in spill proof containers and
properly labeled.
VI. GENERAL
a. Utilities -Connection to or disruption of service of any utility, such as electricity,
steam, water, gas, etc., requires notice to and approval of Owner's Representative
before action is taken.
b. Alcohol and Drugs -No person will be permitted to work while under the
influence of or in the possession of alcohol or drugs. Persons taking medication
will not be permitted to work if is affects their performance or judgment. A drug
and alcohol testing policy is in place at this facility. All Contractor personnel will
be subject to random and accident investigation samplings.
c. Signs and Warnings -Anytime work is performed which could present a hazard
to others; the area must be roped off or barricaded. All posted signs and other
warnings devices shall be strictly observed.
d. Horseplay -Horseplay will not be tolerated.
e. Eating Areas -Eating, drinking and chewing is permitted only in designated areas
by the Owner.
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f. Restricted Area -A radiation survey must be performed on all personnel and
equipment prior to leaving the restricted area. The restricted area consists of all
operational and disposal areas.
g. All contractors while working on Company property are subject to Energy Fuels
Resources (USA) Inc.'s Drug and Alcohol Testing Policy. Testing may include
accident investigation, behavioral changes or impaired job performance,
perceived drug or alcohol influence and random testing. A copy of the policy will
be provided for each contracting company.
VII. SPECIAL PROCEDURES
a. Lockout Procedures -When work is to be performed on any equipment, tanks or
lines, the "Zero Energy" concept will apply.
Each job requiring lockout must be authorized by Owner's Representative before
any equipment is turned off or locked out. Owner's Representative will assist
Contractor to assure proper lockout procedure is followed.
To assure that the correct drive switch has been locked out; an attempt must be
made to start the equipment before work is started. The assurance can be gained
on interlocked systems by attempting to start the equipment at its local control
station. If this proves satisfactory, push the stop switch again.
Any gas or chemical lines that enter work locations must be blanked or have the
valve locked in the closed position. The valve must be locked or tagged so it can
easily be identified as a Contractor lockout. It will be the responsibility of the
Contractor, to assure lockout knowledge and compliance from their employees.
b. Flame Permits -A flame permit will be required and must be displayed when
welding or torching anywhere a fire hazard exists. A fire extinguisher and a
pressurized water hose must be ready at the job location during all welding and
torching. A person must be standing by and able to watch for any sparks which
could start a fire.
No welding or cutting will be done within 50 feet of fuel storage areas.
c. Confined Space Entry -Whenever work is done that involves entry into tanks,
bins or similar enclosures, a Confines Space Entry Evaluation and Safe Work
Permit will be required.
Other Safe Work Permit area include: working on chemical lines, working on any
high-pressure system, operating equipment close to electrical lines or any
hazardous operation as determined by the Site Safety Coordinator.
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Where a hazardous or oxygen deficient atmosphere is possible, special
precautions will be needed in addition the normal safety precautions, such as
lockout, air fans, respirators, safety ropes, etc. Safety precautions may be found
in the Safe Work Procedure, which will be furnished by the Owner's
Representative if applicable.
d. Process Lines -Process lines which contain or may have contained hazardous
chemicals or gases can be worked on only with specific approval of the Owner's
Representative.
VIII. MOBILE EQUIPMENT
Equipment will be kept in safe operating condition and be checked frequently. All
equipment must be operated by experienced operators and will be confined to the
work areas or places designated by the Owner's Representative. Drivers must be
licensed if driving on public roads. Speed limits and traffic rules will be observed.
Owner's equipment has the right-of-way. Observe caution, yield to traffic control
signs. Speed limits on property shall not exceed 15 mph.
Cranes, power shovels and similar equipment will be directed by a responsible person
on the ground when being moved through congested areas. Special attention mu t be
paid to overhead wires. piping and other obsu·uctions. (The ten-foot rule must apply)
All suspended loads which are being moved by mobile equipment; i.e., winch truck,
cherry picker, etc., shall be secured with a tagline to prevent it from swinging.
All persons shall ride inside the cab or truck bed; absolutely no one is to ride on the
fenders or running boards. All persons riding in a vehicle shall keep both body and
feet within the protective area of the vehicle frame.
Protruding material that extends (2) feet beyond the rear of the vehicle shall be
flagged.
Operators of gasoline powered vehicles shall stop the engines and place the ignition
in the off position when refueling.
Drilling equipment must not be operated within (50) feet of any energized power line.
IX. HEAVY EQUIPMENT
a. All self-propelled equipment shall have adequate overhead protectors (Rollover
Protective Structures, or ROPS) to insure worker protection.
b. All self-propelled equipment (except wheeled tractor scrapers) shall be equipped
with backup alarms and the alarms must function when equipment is in use. A
White Mesa Mill
Book # 13 Training Manual
Date: 12/19 Revision: EFR 3.5
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second person will be responsible to guide tractor scrappers when scrapers are in
reverse.
c. Buckets, lifts or blades shall be left down when equipment is not in use.
d. Dump truck beds shall be in the down seat position while traveling.
e. No person shall place any part of his/her body under a suspended load. Push -
never pull. A suspended load, thereby keeping one's feet and body in the clear.
Whenever possible, use a device to direct the load.
f. After a piece of equipment has been down, the operator shall walk around and
inspect the equipment before moving it.
g. Persons shall not get on or off moving equipment.
h. Operators of equipment shall not work under overhanging walls until all safety
precautions have been taken and then only after a Safe Work Permit has been
issued.
i. Travel speed of equipment shall be consistent with road conditions.
X. TOOLS AND EQUIPMENT
Tools and equipment will be kept in safe condition with all safety devices and guards
kept operable. Electrical tools will be provided with grounding protections (separate
ground wire, double insulated and or Ground Fault Interrupter). All portable
electrical lights will be properly guarded. Extension cords hoses; etc. will be kept in
good condition and strung so as not to create a hazard. All electrical devices will be
checked prior to start of work for resistance to ground to ensure proper grounding is
provided.
Compressed gas cylinders will be secured in an upright position. Gauged bottles will
be protected and guarded and shut off when unattended. Hoses and leads will be
checked for leaks prior to each use and repaired or replaced if found defective.
The "quick opening" coupling on compressed air, steam or any other high-pressure
hose must be pinned and whip checked. All bull hose must be securely chained.
XI. EXPLOSIVES AND BLASTING
a. All explosives shall be properly stored per ATF "Table of Distance" as to
distance. The construction of the magazine shall meet the A TF specifications.
b. All magazines shall be licensed.
c. No open flame shall be permitted in or within 100 feet of any explosive magazine.
d. Explosives and detonators (primers) shall not be transported together. When
being transported in the same vehicle, they shall be in different compartments,
with appropriate signs on vehicle (see local regulations).
e. All unused explosives and detonators shall be returned to their proper magazine.
f. All blasts shall be properly guarded.
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g. Warning signs shall be used to halt use of two-way radios during the loading and
blasting cycle when electrical blasting caps are used.
h. For blasting in open pit works, Owner's Representative shall be notified of each
blast prior to the blast. All blasting plans and guarding procedures shall be
approved by the Owner's Representative.
1. All blasting materials and magazines will be removed by Contractor upon
completion of job.
XII. REGULATORY AGENCIES
Code of Federal Regulations specifies that independent contractors will be held
responsible for compliance with all standards. The regulations require that the
independent contractor provide Owner with the following;
a. Contractor's trade name, business address, telephone number, contractor's ID
number for MSHA/OSHA or State and name of person in charge of project.
b. A description of the work to be performed and the place where it will be
performed.
Contractor must provide Owner with the same information for each subcontractor
before each subcontractor begins work on Owner's Work Site.
XIII. ACCIDENT REPORTING
All accidents and/or injuries shall be reported to Owner's Representative
immediately.
XIV. TRAFFIC CONTROL
Only those vehicles authorized by the Owner's Representative will be permitted in
the restricted area. All Contractor vehicJes, equipment and per onnel wilJ be scanned
for radiological release prior to leaving the restricted area.
XV. MONITORlNG CONTRACTOR S EMPLOYEES
Owner may perform certain monitoring on Contractor's employees, from time to
time, to ascertain the exposure of such employees to various substances they may
encounter in the course of their work under Contractor's contract with Owner.
Owner will select the times, the conditions and the equipment to be used for such
monitoring. Owner will conduct such monitoring using its own personnel but will do
so solely as an agent for the Contractor, and on the Contractor's behalf. Owner's
White Mesa Mill
Book #13 Training Manual
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monitoring may have for the protection and surveillance of the Contractor's
employees and the performance of such monitoring shall not be deemed a waiver by
the Contractor or as an assumption by Owner of such responsibilities.
XVI. ADDITIONS OR CHANGES TO RULES
Additional area restrictions, rules or procedures not defined in the Special Rules, etc.,
will be provided by Owner's Representative or the department supervisor as
necessary and must be observed. Contractor personnel must immediately contact
Owner's Representative if there are any concerns about potential hazards or proper
methods before proceeding.
XVII. ARCHAEOLOGICAL DETERMINATION
During the course of any work performed by Contractor, if any archaeological
evidence is discovered, i.e., artifacts or remains, the work must cease immediately,
and Contractor must notify the Owner Representative immediately.
XVIII. LIGHTNING
If you hear thunder, lightning is close enough to strike you. Immediately stop what
you are doing and seek safety in a substantial building or metal topped vehicle with
the windows up. In the event that thunderstorm conditions develop, Energy Fuels
Safety Department will notify all on site personnel to seek shelter. Stay in until 30
minutes after you hear the last thunder or until the Safety Department determines it is
safe to resume work activities.
XIX. STORM WATER AND SPILL CONTROL
The White Mesa Mill is a zero-discharge facility and no water effluents leave the site.
Control mechanisms for maintaining the zero-discharge status of the site include but
are not limited to the earthen berms surrounding the site.
Any activity conducted on site should avoid disturbing the berms if possible. This
includes but is not limited to vehicular traffic, construction, drilling, grading etc. If a
berm is damaged or compromised please notify a Radiation Technician or
Environmental Technician immediately.
Operational and management practices should be employed to minimize and prevent
spills. In the event of a spill on site, EFRI has specific procedures that are followed.
For the purposes of these procedures a spill is defined as any amount of solid or
liquid (except water) that is on the ground. In the event of a spill, take photographs
White Mesa Mill Date: 12/19 Revision: EFR 3.5
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of the spill and notify a Radiation Technician or Environmental Technician
immediately. The Radiation Technician or Environmental Technician will implement
the Mill procedures and complete the required paperwork.
HAZCOM
Inform the all contractors and subcontractors of the chemicals used in the area or
areas in which they will be assigned to work. Discuss White Mesa Mill's chemical
labeling, MSDS locations, the health hazard, personal protective equipment and first
aid treatment for the potential chemical exposure. The contractor will immediately
contact an owner's representative in case of a chemical emergency so the appropriate
Emergency Response can be implemented. Contractors will be trained to the
Emergency Evacuation Procedure.
The Contractor and all subcontractors will provide a list and approximate volume of
any hazardous chemicals they will use on Mill property and will make available
copies of any SDSs upon request.
XX. SIGNATURE
Name:
By signing this acknowledgement, each Contractor denotes acceptance of all of the
above safety requirements of this Contract and agreement to abide by all federal, state
and local laws and regulations.
Date: -------------------------(Print)
Signature: _____________________ _
Brief Job Description:
White Mesa Mill
Book #13 Training Manual
Appendix G
FORMS
Date: 12/19 Revision: EFR 3.5
83 of 86
Form 1 -Alpha Contamination Training Acknowledgement
Form 2 -Radiation Exposure Request Form
Form 3 -Radiation Exposure to Pregnant Women Employees
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Forml
Date: 12/19 Revision: EFR 3.5
84 of 86
Training on Proper use of Personnel Alpha Monitor
Revised 8/22/2018
On _____ , I received training on the proper use of the alpha monitor, and the importance
and need to conduct alpha survey of all personnel leaving the restricted area. What constitutes a
proper survey with the alpha meter was discussed, along with the possible use of disciplinary
actions for not complying with the survey policy. I have received the above training and
understand the importance of conducting a proper personal alpha survey and the possible
disciplinary actions that can be taken for noncompliance with this license requirement.
Training Conducted by:
Training Received by:
White Mesa Mill
Book #13 Training Manual
Energy Fuels Resources (USA) Inc.
6425 South Highway 191
Blanding, UT 84511
TO: __________ _
Form2
DATE:
RE:
SSN:
DOB:
Date: 12/19 Revision: EFR 3.5
85 of 86
---------------
The above-named person is employed, or is being considered for employment by Energy Fuels
Resources (USA) Inc. In accordance with provisions of the United State Nuclear Regulatory
Commission Regulations 10 CFR 19.13 (b), Energy Fuels Resources (USA) Inc. requests that
you provide a report of the occupational exposure to radiation while in your employ.
Sincerely,
Terry Slade
Radiation Safety Officer
Energy Fuels Resources (USA) Inc.
I, ______________ , hereby authorize release of my Total Radiation
Exposure History, as requested below, to Energy Fuels Resources (USA) Inc.
TOTAL RADIATION EXPOSURE HISTORY
1. Period Employed: _________ to ___________ _
2. Place of Employment: ___________________ _
3. Total exposure during period of employment: ___________ _
Signed: ____________ _
Date: --------------
Title: --------------
White Mesa Mill
Book #13 Training Manual
Form3
Date: 12/19 Revision: EFR 3.5
86 of 86
Subject: Radiation Exposure to Pregnant Women Employees
On this date, I was advised by my employer, Energy Fuels Resources (USA) Inc. of the White
Mesa Mill, Utah, of the possible risks associated with prenatal radiation exposure and of the
precautions that I should I become pregnant and continue to work. I was also advised of the
alternatives that I might consider in this regard.
I discussed this subject with my employer and understand the possible risks to children of
women who are exposed to radiation during pregnancy and the alternatives that I might consider
as explained by my employer as contained in the appendix to Regulatory Guide 8.13 from the
United States Nuclear Regulatory Commission, a copy of which was given to me for reference.
Employee Date
Employer Representative Date
Hire Date: _______ _
SSN: ________ _
Employee Number: ___ _
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
Date: 12/19 Revision EFR-7
Page 1 of32
RESPIRATORY PROTECTION PROGRAM
Table of Contents
1.0 APPLICABILITY
2.0
3.0
4.0
1.1 Respiratory Protection Policy
1.2 Supervisory Positions and Responsibilities
1.2.1 Radiation Safety Officer
1.2.2 Radiation Technicians and Other Radiation Safety Department
Staff
1.2.3 Respirator Program Administrator
1.2.4 Training and Re-Training Requirements
1.2.5 Qualifications for Appointment
1.3 Policy Regarding Facial Hair (Face to Face piece Seal Integrity)
1.4 Physiological or Psychological Limitations to Respirator Use
1.5 Equipment
PROCEDURES FOR RESPIRATOR USE
2.1 Supervision of the Program, Including Program Audits
2.2 Training and Minimum Qualifications of Respiratory Program Supervisors
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
2.11
2.12
2.13
and Implementing Personnel
Training of Respirator Users
Fit Testing
Selecting Respirators
Maintaining Breathing Air Quality
Seal Tests
Inventory Control and Issuance of Respiratory Protection Equipment
Storage of Respiratory Protection Equipment
Maintenance, Repair, Testing, and Quality Assurance of Respiratory
Protection Equipment
Record keeping
Limitations on Periods of Respirator Use and Relief from Respirator Use
Monitoring, Including Air Sampling and Bioassays
PROCEDURES FOR MEDICAL EVALUATIONS AND AUDITS
3.1 Performing and documenting the Required Medical Evaluation
3.2 Maintaining TEDE ALARA and Performing ALARA Evaluations of
Respiratory Protection
PROCEDURES FOR RESPIRATOR APPLICATONS
4.1 Routine Respirator Use
4.2 Non-routine Respirator Use
4.3 Emergency Respirator Use
4.4 Safety
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Date: 12/19 Revision EFR-7
Page 2 of32
RESPIRATORY PROTECTION PROGRAM
1. APPLICABILITY
This Respiratory Protection Program sets out the Mill's procedures regarding:
• selection, fitting, issuance, maintenance, and testing of respirators, including
testing for operability immediately prior to each use; supervision and training of
personnel; monitoring, including air sampling and bioassays; and record keeping;
and
• Determination by a physician that the individual user is medically fit to use the
respiratory protection equipment.
1.1 Respiratory Protection Policy
The Respiratory Protection Program is established for the Mill to protect its workers from
occupational exposure to harmful concentrations of radioactive and/or toxic materials in
the air.
As noted in United States Nuclear Regulatory Commission ("NRC") Regulatory Guide
8.15, "it is widely recognized among safety professionals that the use of respiratory
protection devices in the workplace can impose physiological and psychological stresses
on workers, obstruct their vision, hinder their movements, and make effective
communications difficult. These factors increase the risk of physical injury to respirator
wearers that, in many cases, far exceeds any potential risk associated with the inhalation
of a small quantity of airborne radioactive material." Therefore, process or engineering
controls should be used to the extent practical to control the concentration of radioactive
material in air, and the use of respiratory protection devices should be contemplated only
after other measures to limit intake have been considered.
The following is the Mill's policy with respect to respiratory protection:
a) Process or other engineering controls will be used whenever feasible to reduce
the need for use of respirators;
b) For work in areas in which respirators must be routinely used to reduce
exposures, standard operating procedures ("SOPs") will detail use of
respiratory protection. Non-routine use of respirators will be performed under
Radiation Work Permits. Self-Contained Breathing Apparatus ("SCBA")
respirators will only be used for evacuation and emergency response situations;
c) Due to the added physical stress of working while using a respirator, work
periods will be alternated with rest periods; and
d) Respirators will not be issued to workers unless they are to be used.
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Date: 12/19 Revision EFR-7
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Respirators are provided to workers for their personal protection and the proper use of
respirators in areas in which such protection is required is a condition of their
employment. Violating the established rules for respirator use may result in disciplinary
action up to and including dismissal.
1.2 Supervisory Positions and Responsibilities
In general, the Mill Manager is responsible for providing the equipment and resources
necessary for the successful implementation of this Respiratory Protection Program and
for facilitating the application of engineering controls to reduce the need for the use of
respiratory protection devices.
The Mill's Radiation Safety Officer ("RSO") has primary responsibility for
implementation and oversight of all aspects of the respiratory protection program,
including supervisory and technical responsibilities. The RSO is assisted by one or more
Radiation Technicians or other Radiation Safety Department staff.
The Mill Manager and the RSO will coordinate efforts to use, to the extent practical,
procedures and engineering controls based on sound protection principles to maintain
radiation exposures as low as reasonably achievable ("ALARA").
1.2.1 Radiation Safety Officer
The RSO is responsible for the implementation and direct control of the respiratory
protection program. The RSO's responsibilities include:
a) Supervision of respirator selection procedures;
b) Establishment of training sessions about respiratory equipment for workers;
c) Establishment of a continuing program of cleaning and inspecting the
equipment;
d) Designation of proper storage areas for respiratory equipment;
e) Establishment of issuance and accounting procedures for uses of respiratory
equipment;
f) Establishment of medical screening programs and procedures for workers
assigned to wear respiratory equipment;
g) Establishment of a periodic inspection schedule of those workplaces/conditions
requiring respiratory equipment to determine exposure and/or changing
situations; and
h) A continuing evaluation of the above aspects to ensure their continued
functions and effectiveness.
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Date: 12/19 Revision EFR-7
Page 4 of 32
1.2.2 Radiation Technicians and Other Radiation Safety Department Staff
In administering the program, the RSO will be assisted by one or more Radiation
Technicians, who may perform supervisory and technical functions, as determined by the
RSO, and one or more other members of the Radiation Safety Department Staff, who
may perform technical functions. Each such individual must have adequate training to
undertake his or her assigned responsibilities, as determined by the RSO.
1.2.3 Respirator Program Administrator
The RSO is the Respiratory Program Administrator. However, the RSO may appoint a
Radiation Technician as Respirator Program Administrator, in his stead, to administer the
program under the direction and supervision of the RSO.
1.2.4 Training and Re-Training Requirements
The RSO and any Radiation Technician will be required to have satisfied the
requirements for those positions as set out in NRC Reg. Guide 8.31 and to be current in
their refresher training as set out in that Reg. Guide. Any other member of the Radiation
Safety Department who has been given technical responsibilities under this program will
have adequate training in order to undertake those responsibilities, as determined by the
RSO. Each Radiation Technician will also have completed the training specified in
Section 2.2 below.
1.2.5 Qualifications for Appointment
The RSO and, if so appointed by the RSO, one or more Radiation Technicians, will have
supervisory responsibility and may also have direct responsibility for various technical
aspects of this program. Such individuals will meet the requirements for the position of
RSO and Radiation Technician as set out in NRC Reg. Guide 8.31 and will have
completed the training specified in Section 2.2 below.
Any other members of the Radiation Safety Department who perform technical functions
under this program will have the qualifications and training required to perform the
function, as determined by the RSO.
1.3 Policy Regarding Facial Hair (Face to Face piece Seal Integrity)
The licensee shall ensure that no objects, materials or substances, such as facial hair, or
any conditions that interfere with the face and face piece seal or valve function, and that
are under the control of the respirator wearer, are present between the skin of the wearer's
face and the sealing surface of a tight-fitting respirator face piece. Materials in this area
might interfere with the seal of the respirator, might prevent proper exhalation valve
function, or might impair the operation of a face piece-mounted air regulator. Leakage of
air into the mask will nullify the purpose of the respiratory device.
The list of prohibited materials includes (but is not necessarily limited to) facial hair of
any kind in the seal area (the worker must be clean-shaven), hair from the head intruding
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
Date: 12/19 Revision EFR-7
Page 5 of32
into the seal area, cosmetics, spectacle temple bars, protective clothing, and equipment.
A respirator wearer is not required to shave more than once during each 12-hour period.
The only facial hair that will be authorized while wearing a full-face respirator is a small
maintained mustache that does not extend below the corners of the mouth.
The policy of the Mill concerning facial hair is:
As a condition of employment, those workers who may at any time be
required to wear a respirator as part of their employment, will not have
any facial hair or other features that will restrict the proper fitting of a
respiratory device.
1.4 Physiological or Psychological Limitations to Respirator Use
This section describes physiological and psychological (including emotional) factors,
which may limit an individual's ability to wear or work in a respirator. Any questions or
problems concerning respirators or their use, such as the types described in this section,
should be addressed to the RSO.
1.4.1 Physiological Limitations
As described below in Section 3 .1, medical qualification will be required of each worker
that might be using a respirator in his or her normal work duties. This is necessary to
evaluate the individual's limitations to wearing respirator devices. A licensed physician
must determine that the individual user is medically fit, through a medical evaluation, to
use respiratory protection equipment. The physician will report on any physiological
factors that may limit an individual's ability to wear a respirator.
1.4.2 Psychological Limitations
Mental factors must also be taken into consideration when workers are required to wear
respirators. Some individuals become claustrophobic when wearing a respirator. These
individuals should not be required to wear respirators if the condition is severe enough to
cause panic.
1.4.3 Other Factors
Other factors, which may cause problems in respirator sealing, must be considered when
performing fit testing. These may include such factors as facial structure, scars, skin
creases, or dentures.
1.5 Equipment
Only National Institute for Occupational Safety and Health ("NIOSH") tested and
certified and Mine Safety and Health Administration ("MSHA") approved respiratory
protection devices will be used at the Mill. In addition, these devices must be used,
maintained, and stored in such a manner that they are not modified and are in like-new
White Mesa Mill -Standard Operating Procedures
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Date: 12/19 Revision EFR-7
Page 6 of32
condition at the time of issue. A reasonable amount of wear that does not affect
performance is acceptable.
The Mill will provide adequate equipment or material, as necessary to supplement
respiratory protective equipment, to reduce the likelihood that respirator use might
contribute to workplace accidents or injury. Examples of such equipment are:
• Spectacle adapters;
• Voice amplification equipment; and
• Material or equipment to prevent or reduce fogging of respirator lenses.
Safety or protective equipment used in conjunction with respirators should not interfere
with the proper fit or operation of the respirator. Manufacturer-supplied equipment (e.g.,
welder's shields, communications devices) specified on the approved subassemblies list
for the respirator may be used in accordance with the manufacturer's instructions.
Equipment or devices supplied by a company other than the respirator manufacturer may
be used as long as they do not alter the form, fit, or function of the respirator. Any such
device that attaches to or requires penetration of the respiratory inlet covering is likely to
void the NIOSH approval for the device and should not be used.
2. PROCEDURES FOR RESPIRATOR USE
2.1 Supervision of the Program, Including Program Audits
The Respiratory Protection Program is administered by the RSO. Quarterly ALARA
Reports from the RSO are sent to members of the ALARA Committee. The effectiveness
of the Respiratory Protection Program is reviewed, and exposure data evaluated, during
annual ALARA audits.
2.2 Training and Minimum Qualifications of Respiratory Protection Program
Supervisors and Implementing Personnel
A supervisor, that is, a person who has the responsibility of overseeing the work activities
of one or more persons who must wear respirators, shall be given adequate training to
ensure the proper use of respirators. Supervisor training shall include but shall not
necessarily be limited to the following subjects:
a) Basic respiratory protection practices;
b) Nature and extent of respiratory hazards to which persons under his/her
supervision may be exposed;
c) Principles and criteria of selecting respirators;
2.3 Training of Respirator Users
Each worker who may wear a respirator will be required to receive training for the proper
use of the device, including the requirement for each user to inspect and perform a user
White Mesa Mill -Standard Operating Procedures
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Date: 12/19 Revision EFR-7
Page 7 of32
seal check on a respirator each time it is donned. The required training for all potential
respirator users is found in Addendum 9 of the Mill's Training Manual, SOP Book 13.
Such training shall cover the topics necessary to ensure that each trainee will:
a) Be informed of the hazard to which the respirator wearer may be exposed, the
effects of contaminants on the wearer if the respirator is not worn properly, and
the capabilities and limitations of each device that may be used;
b) Be shown how spectacle adapters, communications equipment, and other
equipment that will be used directly in conjunction with the respirator are to be
attached and operated properly;
c) Be able to demonstrate competency in donning, using, and removing each type
of respiratory protective device that may be used;
d) Be instructed in how to inspect each type of respiratory protective device that
may be used and be instructed to perform such an inspection before donning
any device;
e) Be instructed in how to perform a user seal check on face-sealing devices and
be instructed to perform this user seal check each time this type of device is
donned;
f) Be informed that any respirator user may leave the work area at any time for
relief from respirator use in the event of equipment malfunction, physical or
psychological distress, procedural or communications failure, significant
deterioration of operating conditions, or any other condition that might
necessitate such relief; and
g) Be advised that in case of respirator malfunction or wearer distress, the
respirator may be removed as the respirator user exits the airborne
contamination area.
2.4 Fit Testing
2.4.1 General
Fit testing must be performed for all face sealing respirators, even if they will be used in a
positive pressure mode in the field. The worker should be fit-tested with the same make,
model, style and size of respirator that will be used in the field.
Each person being fit-tested should already have been trained in how to properly don, and
perform a user seal check on, a face-sealing respirator. Therefore, during the test, no
person (including the person administering the fit-test) should assist or coach fit-test
subjects who are not obtaining a satisfactory face piece seal.
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
Date: 12/19 Revision EFR-7
Page 8 of32
Qualitative fit-testing and quantitative fit testing must be accomplished with the face
piece operating in the negative pressure mode, regardless of the mode of operation in
which it will be used in the field.
Filters used during fit-testing should be at least 99.97% efficient, even if less efficient
filters will be used in the workplace. The fit-test is intended to measure only face-to-face
piece leakage, so filter efficiency on the test respirator should be as high as possible.
During training or operation, perceptible outward leakage of breathing gas from the face-
to-face piece seal area of any SCBA is unacceptable, and the wearer should not be
permitted to continue to use the device. Such leakage will quickly deplete the available
breathing gas and if used in an emergency could easily place the wearer in jeopardy.
2.4.2 Frequency of Testing and Re-testing
Fit testing must be performed annually for every worker who is required to wear a
respiratory protective device.
Retesting should be performed before the next respirator use when the RSO has
knowledge that a potential respirator wearer, since the last fit-test, has had:
a) A weight change of 10% or more;
b) Significant facial injury or scarring in the area of the face piece seal;
c) Significant dental changes (e.g., multiple extractions without prosthesis or
acquisition of new dentures;
d) Reconstructive or cosmetic surgery in the area of the face piece seal; or
e) Any other condition that might change the fit of a face-sealing respirator.
The Mill will advise respirator users of these retest criteria either during general training
sessions or during initial fit testing and will advise users to advise the RSO of any of the
foregoing circumstances.
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
2.4.3
2.4.3.1
Quantitative Fit Testing
General
Date: 12/19 Revision EFR-7
Page 9 of32
Quantitative fit testing is acceptable for testing all face-sealing devices.
If quantitative fit testing is used to test face pieces that will be operated in the negative
pressure mode in the field (e.g., full face respirators), an overall fit factor of at least 10
times the assigned protection factor ("APF") should be demonstrated. Requiring that the
overall fit factor meet the acceptance criterion means that the fit factor for one or more of
the individual test exercises might be less than the acceptance criterion, but a satisfactory
overall fit-test can still be achieved.
If quantitative fit testing is used to test face pieces that in the field will be operated only
in a positive pressure mode, an overall fit factor of at least 500 (not 500 times the APF)
should be demonstrated with the face piece operating in negative pressure mode. Face
sealing devices that operate in a positive pressure mode are powered air purifying
respirators ("PAPRs") and SCBA.
During all quantitative fit-tests, the sample point inside the face piece should be midway
between the mouth and the nose of the test subject.
2.4.3.2 Quantitative Fit Testing Procedure
Quantitative fit testing measurements will be performed in accordance with 29 CFR
1910.134 using the FitTester 3000, or equivalent, as follows:
a) Input the worker's name, style of respirator and size;
b) Select "perform fit test" -the computer will walk you through a series of five
tests;
c) During the testing program, the computer will evaluate the worker;
d) If there is a failure during any test, the worker will adjust the respirator and try
again;
e) If after several attempts to pass a test and the worker still fails, try a different
size respirator;
f) Once the worker passes each of the five tests, a document will be printed
certifying the successful completion of the examination;
g) The document will then be signed by both the worker and the facilitator of the
examination; and
h) The document will then be filed with the worker's other Safety documents in
the Radiation Safety Department.
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
2.4.4
2.4.4.1
Qualitative Fit Testing
General
Date: 12/19 Revision EFR-7
Page 10 of32
While no numerical measure of face piece leakage is directly obtained from qualitative
fit-testing protocols, they are designed and validated quantitatively. NRC Reg. Guide
8.15 requires that a qualitative fit test must be capable of verifying a fit factor of 10 times
the APF for full face (negative pressure) respirators and a fit factor of 500 for PAPR and
SCBA (positive pressure) respirators. Currently, qualitative fit testing methods are only
capable of verifying a fit factor of 100. Therefore, qualitative fit testing methods are only
appropriate for respirators having an APF of 10 (such as half face respirators) and are not
capable of verifying a fit factor of 500 (i.e., 10x50) needed for full face respirators, or
500 for PAPRs and SCBA. However, the use of qualitative fit testing in conjunction with
(but not in lieu of) the quantitative fit testing procedures described above is considered to
be advisable and is performed at the Mill. It is recognized that only credit for an APF of
10 will be taken based on the qualitative fit test alone, even though the APF is higher for
the device.
2.4.4.2 Qualitative Fit Testing Procedure
Qualitative fit testing measurements will be performed in accordance with 29 CFR
1910.134 using an MSA ventilation smoke tube, Part No. 5645 or equivalent, aspirator
bulb. Steps for respirator issuance fit testing are as follows:
a) Respirators equipped with high-efficiency filters will be used for this test
(red/green filters);
b) Both ends are broken on an MSA ventilation smoke tube. One end is inserted
into the tube connected to the positive pressure of a two-way aspirator bulb and
the other end covered by a ½ inch length of tygon, surgical or rubber tubing.
The test aerosol is generated by squeezing the aspirator bulb;
c) The test subject will don the respirator and a visual inspection of the face piece
to face seal made by the tester. An obvious leak in the face piece to face seal
shall be reason to abort the test and record the mask as unsatisfactory.
Expression of discomfort created by the mask shall also be reason to abort the
test;
d) The smoke will be generated in all areas surrounding the mask. The smoke is
not harmful however it is sufficiently irritating that if there is a leak in the seal
of the mask, it will be discovered immediately; and
e) Any indication of detection of the smoke by the test subject during fitting
indicates a failure of that respirator. If leakage is detected the face piece to face
seal shall be visually inspected for obvious leakage. If any doubt about the
condition of the respirator or the filter exists, another like respirator shall be
tested to ensure the leakage was due to the face piece to face seal.
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2.4.4.3 Irritant Smoke
Date: 12/19 Revision EFR-7
Page 11 of32
Only stannic chloride smoke tubes, such as the MSA ventilation smoke tube, Part No.
5645, will be used. Similar tubes that generate smoke of a different chemical
composition may not be sufficiently irritating to the test subject to be sensed at low
concentrations. Smoke tubes that use chemicals other than stannic chloride are not
acceptable
If irritant smoke is used as the challenge aerosol during qualitative fit-testing, the RSO
must take steps to protect the person administering the test from repeated exposures to the
irritant smoke. These steps could include using a containment chamber around the head
and torso of the fit-test subject to contain the smoke, providing the test area with a
ventilation or air filtration system, performing the test outdoors, assigning a respiratory
protection device to the person performing the fit-testing, or other measures. The fit-test
protocol will also be performed to limit the test subject's exposure, especially when
performing the sensitivity screening checks that determine whether the test subject can
detect the irritant smoke.
2.5 Selecting Respirators
2.5.1 General
Respirator selection will be determined by the type of environment in which the worker
will be working. The concentration of oxygen and the type and concentration of
hazardous contaminants in the work area atmosphere must be considered during the
selection process.
2.5.2 Types of Respirators Available for Use at the Mill
Three types of respiratory protection are used at the Mill. These are:
a) full face respirators (which are air purifying respirators);
b) PAPRs (which are air purifying respirators); and
c) SCBAs (which are supplied air respirators). The SCBA devices used at the
Mill are full face respirators with an attached hose mechanism that draws air
from a compressed air tank worn on the back of the worker. The Mill does not
use supplied air hoods or supplied air suits.
d) Half face, single use respirators, and dust masks can be used in certain
circumstances. These respirators are not normally kept at the Mill. The RSO
will evaluate the conditions of use and approve or disapprove their use. If half
face or quarter face respirators are used only MSHA, OSHA, or NIOSH
approved respirators can be used and still have an APF. All fit test procedures
for the particular respirator should be followed also.
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Date: 12/19 Revision EFR-7
Page 12 of 32
Dust masks may be used occasionally at the Mill, for protection against non-radioactive
dust, but such masks are not part of the respiratory protection program
One model of respirator from one manufacturer is adequate, so long as different sizes of
face pieces are available and adequate fit factors are obtained for greater than 99% of test
subjects who are free of facial characteristics that preclude an adequate respirator fit. To
those individuals who achieve a fit factor >500 with a negative-pressure full face piece
but who are unable to achieve a fit factor 10 times the APF, consideration will be given to
assigning a positive pressure face-sealing device or to a device for which a face seal is
not necessary.
2.5.3 Application of Assigned Protection Factors
The APF for each of the three types or respirators in use at the Mill are as follows:
• Full face respirators have an APF of 100;
• P APR respirators have an APF of 1,000;
• SCBAs have an APF of 10,000; and
• Half face and single use respirators have an APF of 10. To use an APF the
conditions below must be followed.
Use of the APF assumes that:
• The respirator user has been trained to properly don the device;
• The user has been satisfactorily fit-tested;
• The user properly performs a user seal check to ensure that there is no gross seal
leakage;
• The respirator performs properly; and
• Individual wearing a respirator has medical clearance to wear a respirator.
APFs are to be used for selecting a specific type of respirator to be used in the
performance of a specific task, to keep the total effective dose equivalent ("TEDE") of
exposed workers ALARA, and to be applied in the derived air concentration
("DAC")/hour calculation to determine the dose from exposure to air particulate. Using
APFs to estimate intake and then dose, in conjunction with air survey data and the
application of the applicable DAC, is the method of choice for determining the intake and
dose for workers at the Mill. Bioassay measurements are taken in order to corroborate
such calculations (see Section 2.13.3 below for a summary of the Mill's bioassay
program).
In estimating the dose to individuals from intake of airborne radioactive materials, the
concentration of radioactive material in the air that is inhaled when respirators are worn is
initially assumed to be the ambient concentration in air without respiratory protection,
divided by the assigned protection factor. If the dose is later found to be greater than the
estimated dose, the corrected value must be used. If the dose is later found to be less than
the estimated dose, the corrected value may be used.
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Date: 12/19 Revision EFR-7
Page 13 of 32
2.5.4 Survey Program
A survey program that is adequate to identify potential respiratory hazards, to permit
selection of the proper respiratory protection method and to evaluate actual or suspected
intakes is contained in Section 2.0 of the Mill's Radiation Protection Manual SOP PBL-
RP-2 and described in part in Section 2.13 below.
2.5.5
2.5.5.1
Procedures to be Followed When Selecting a Respirator
General
Prior to selecting a specific type of respirator, the work environment must be thoroughly
evaluated for respiratory hazards. The following questions must then be answered:
a) What are the hazards the worker will be exposed to?
b) What are the contaminants and their concentration?
c) Are there any contaminants in the workplace environment that may damage or
irritate the eyes, nose, or skin?
(i) Yes -a full-face style is recommended;
d) Is the oxygen concentration in the workplace atmosphere between 19.5% to
23%?
(i) Yes -combination cartridges will be used if the concentration of the
contaminant is within the acceptable limits for the cartridge;
(ii) No -The workplace or area may only be entered if the 02 concentration is
between 19.5 and 23%. The workplace environment will be remediated
(i.e., ventilated) by safety engineering controls such that the oxygen
concentration falls between these limits before it may be entered;
e) Do the contaminant concentrations in the work environment exceed the limits
listed for the combination cartridge being used?
(i) Yes -Modify the air contaminant concentration by safety engineering
measures;
(ii) No -combination cartridges may be used if oxygen concentration is
between 19.5% and 23%.
Limitations appropriate to the type and mode of use of the respirator will also be
considered. When selecting respiratory devices provision will be made for vision
correction (see Section 2.15), adequate communication (see Section 2.14), low
temperature work environments (see Section 2.16), and the concurrent use of other safety
or radiological protection equipment. Equipment will be used in such a way as not to
interfere with the proper operation of the respirator
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2.5.1.1 Air Purifying Respirators
Date: 12/19 Revision EFR-7
Page 14 of 32
The inventory of air purifying respirators will consist of full face and PAPR units.
There is only one type of air purifying respirator cartridge used for air contaminants for
the full-face respirators. This is a red/green GME-H universal cartridge, which is
normally effective for removing all air contaminants and atmospheric hazards, and is
approved by NIOSH for use under the following conditions:
a) Organic Vapors -less than 1,000 ppm;
b) Pesticides;
c) Mists of Paints, Lacquers, and Enamels;
d) Dust -less than 0.5 mg/m3 (99.97% efficient against all particulate aerosols
including oil-based aerosols);
e) Fumes -less than 0.5 mg/m3;
t) Mists -less than 0.5 mg/m3;
g) Chlorine;
h) Hydrogen chloride;
i) Sulfur dioxide;
j) Ammonia;
k) Methylamine;
1) Chlorine dioxide;
m) Hydrogen sulfide (escape only);
n) Formaldehyde; and
o) Hydrogen fluoride.
The P APR units are not designed for areas that may come in contact with chemical mists
or high humidity. The PAPR units use an Optifilter XL Filter Assembly HE that is only
good for dusty environments. These units are ideal for the packaging enclosure,
Yellowcake Dryers, Ore Storage, and Tails.
The P APRs must have the battery fully charged prior to usage. The battery charge on
each unit will last approximately eight continuous working hours. All maintenance and
cleaning techniques utilized with the full-face respirators will be used for the PAPR units.
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2.5.1.2 SCBA and Supplied Air Apparatus
Date: 12/19 Revision EFR-7
Page 15 of32
SCBA will only be used for evacuation or emergency purposes. The Mill does not use
supplied air apparatus.
SCBA will be appropriate for use in emergency situations when the length of the work
will not exceed 20 minutes.
If at any time the atmosphere contains materials that might be corrosive to the worker or
respiratory device, the area will be evacuated. The area must be ventilated until the
corrosive materials fall to a safe level before work may resume.
2.6 Maintaining Breathing Air Quality
The quality of air delivered to all SCBA and supplied-air respirators shall meet the
requirements for Grade D air for breathing air systems as defined in Compressed Gas
Association (CGA) publication G-7 .1, "Commodity Specifications for Air." 1997 ed.
And included in 29 CFR 1910.134(i)(l)(ii)(A) through (E), (2007). Grade D quality
breathing air criteria include: oxygen content (volume/volume) of 19.5 to 23.5%;
hydrocarbon (condensed) content of 5 mg/m3 of air or less; carbon monoxide (CO)
content of 10 ppm or less; carbon dioxide content of 1,000 ppm or less; and the lack of a
noticeable odor.
The Mill obtains the air for its SCBA devices from the local fire department. The Mill
does not have its own breathing air supply system. The local fire department is the only
nearby facility that can refill the oxygen bottles for the SCBA. The local fire department
is certified for such activities by the State of Utah Fire Marshall.
2.7 Seal Tests
Each respirator wearer must perform both the Positive-Pressure and Negative-Pressure
seal checks, set out below, each time a face-sealing respirator is used (which includes any
time a face shield is removed, or the seal is broken and re-donned). A user seal check is
performed immediately prior to exposure to ensure that the respirator is properly seated
on the face. -
a) Positive-Pressure Check
Close off the exhalation valve and exhale gently into the facepiece. The face fit is
considered satisfactory if a slight positive pressure can be built up inside the facepiece
without any evidence of outward leakage of air at the seal. For most respirators this
method of leak testing requires the wearer to first remove the exhalation valve cover
before closing off the exhalation valve and then carefully replacing it after the test.
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b) Negative-Pressure Check
Date: 12/19 Revision EFR-7
Page 16 of32
Close off the inlet opening of the canister or cartridge(s) by covering with the palm of the
hand(s) or by replacing the filter seal(s), inhale gently so that the facepiece collapses
slightly and hold the breath for ten seconds. The design of the inlet opening of some
cartridges cannot be effectively covered with the palm of the hand. The test can be
performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove.
If the face piece remains in its slightly collapsed condition and no inward leakage of air is
detected, the tightness of the respirator is considered satisfactory.
It should be noted that a user seal test is not a substitute for a fit test. See Section 2.4
above for the fit test requirements.
2.8 Inventory Control and Issuance of Respiratory Protection Equipment
Mill Radiation Safety Staff shall maintain positive control over the issuance of
respiratory protection devices, such that persons not authorized to wear such devices are
effectively prevented from obtaining them. To this end, the following procedures will be
followed:
a) Respirators will not be issued to workers unless they are to be used;
b) Storage cabinets that will be used for routine respirator issuance will be located
in the respirator cleaning facility. Only persons authorized by the RSO to issue
respirators will have access to the storage cabinets;
c) When a worker needs a clean respirator, he or she will obtain one from the
storage location where clean respirators are packaged and kept. After obtaining
a clean respirator, the worker will enter the pertinent information on the log
sheet that is kept in the cabinet with the clean respirators;
d) When a used respirator is exchanged for a clean unit, the dirty respirator will be
placed in the receptacle provided for such use;
e) All workers who wear a respirator must exchange their respirators daily; and
f) Workers that need to be issued a PAPR unit will need to see the RSO or his
designee to be checked out on the proper usage of the unit. All PAPR's are
inventoried and only key operators or Radiation Work Permit ("RWP")
individuals will be issued one of these units.
Personnel who issue respirators must ensure that each person issued a respirator has been
medically screened (see Section 3.1), trained (see Section 2.3) and fit-tested (see Section
2.4) within the period prescribed.
Persons may only be issued respirators for which they have been fit-tested (i.e., same
make, model, style and size).
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Page 17 of32
2.9 Storage of Respiratory Protection Equipment
When in storage and not available for use, respirators and component parts of respiratory
protection devices will be stored in such a way as to prevent damage to such components
and devices. The following procedures shall be followed:
a) Respirators shall be stored in a manner sufficient to protect the device against
dust, sunlight, extreme cold, excessive moisture, or damaging chemicals;
b) The cleaned respirators will be stored in cabinets in the respirator cleaning
facility outside the safety department. The respirators will be stored in layers
with the face pieces and exhalation valves in a more or less normal position to
prevent the rubber or plastic from cracking;
c) When respirators are not being used, they must be stored in the plastic bags in
which they were issued. Dirty respirators will be placed in receptacles located
in the respirator storage room. They will be gathered from these locations for
cleaning and repairs;
d) All respirator users must exchange their respirators daily;
e) The cabinets containing emergency respirators will be located in areas that are
readily accessible and in areas in which a hazard may arise. Emergency
cabinets are located on the north side of the Mill building outside of the SAG
Mill doors, outside the SX on the north wall, on the south end of SX on the fire
cabinet and at the fire hose station at the front gate. All workers should be
made aware of these locations; and
f) The cabinets will not be locked, but they will have seals attached to the hasps.
The seals will prevent workers from using the respirators for routine use but
will allow emergency access. During emergencies, the seal will be broken, and
a respirator may be selected in a matter of seconds.
2.10 Maintenance, Repair, Testing, and Quality Assurance of Respiratory
Protection Equipment
2.10.1 Maintenance and Repair
Respirators and component parts will be maintained and repaired only by persons
specifically trained to perform this work. Repairs and maintenance will be performed in
accordance with the procedures detailed below. Parts used for repairs will be purchased
only from the manufacturer of the unit being repaired or from their agents.
Each used respirator must be disassembled before cleaning; the cartridges must be
removed and discarded, and any hoses or regulators must be removed and washed
separately. Some of the units have elastic head straps; these should also be removed and
washed separately.
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2.10.2 Cleaning
Date: 12/19 Revision EFR-7
Page 18 of32
Mill staff will decontaminate and disinfect respirators and associated equipment in
accordance with the manufacturer's instructions, paying particular attention to the
cleaning or sanitizing agents used and to the maximum temperature of the water used for
cleaning, to avoid degradation of the respirator. Chemical residues should not be
hazardous or irritating to the user. Radiological limits for re-use of respirators after they
have been cleaned and sanitized have been established at the Mill and are set out in
Section 2.10.3.1 below.
For full face respirators, P APRs and SCBAs, the respirators will be cleaned and rinsed in
as specified by the manufacture. The radiation and safety staff will perform cleaning and
washing of respirators. The respirators will be washed and then dried by either air or
with the use of a commercial dryer.
2.10.3 Inspection and Testing of Respirators
Inspections of all respiratory devices will be conducted as set out below. Under no
circumstances will a device that is known to be defective be used.
2.10.3.1 General
Respirator face pieces that are routinely available for issue will be visually inspected at
least every month or in accordance with manufacturer's instructions. If such devices are
stored in clear plastic bags, they should be handled and examined, but need not be
removed from the bags for the inspection as long as the inspector can determine that the
device is ready for issue.
Equipment used in conjunction with face piece respirators (e.g., belt-or face piece-
mounted air regulators, air-supply hoses, portable distribution manifolds) will be
inventoried and functionally tested periodically or prior to use.
Repair and replacement parts for respiratory protection devices will be inventoried and
inspected periodically. The goal is to ensure that there are sufficient functional parts
available to support the respiratory protection program when it is operating at full
capacity.
Devices in storage will be inspected quarterly and before they are made available for
issue. Equipment stored for periods of a year of more will be re-cleaned annually to
ensure that they are in good condition in case they are needed unexpectedly.
Each reassembled respirator must be inspected for radiation contamination before it is
used. An instrument survey or a swipe test may be conducted to determine if any item is
contaminated. The equipment check must indicate levels of less than 100 dpm/100 cm2
of alpha radiation or 1,000 dpm/100 cm2 of beta-gamma radiation to be serviceable. If
repeated washings do not decrease contamination to acceptable levels, that item must be
disposed of.
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Page 19 of 32
Freshly cleaned and inspected respirators will be placed in plastic bags and sealed (see
Section 2.10.3.1). The individual who serviced the respirator shall write the date on each
bag and initial it to indicate the work has been done properly.
The following conditions should be checked during any type of inspection:
2.10.3.2 Air Purifying Respirators
Routinely used air purifying respirators (full face respirators and PAPRs) should be
checked as follows before and after each use.
a) Examine the face piece for:
(i) Excessive dirt;
(ii) Cracks, tears, holes, or distortion from improper storage;
(iii) Inflexibility (stretch and massage to restore flexibility);
(iv) Cracked or badly scratched lenses in full face pieces;
(v) Incorrectly mounted full-face piece lens or broken, or missing mounting
clips; and
(vi) Cracked or broken air purifying element holder(s), badly worked threads,
or missing gasket(s), if required;
b) Examine the head straps or head harness for:
(i) Breaks;
(ii) Loss of elasticity;
(iii) Broken or malfunctioning buckles and attachments; and
(iv) Full face pieces only -excessively worn serrations on the head harness
which might permit slippage;
c) Examine the exhalation valve for the following after removing its cover:
(i) Foreign material such as detergent residue, dust particles, or human hair
under the valve seat;
(ii) Cracks, tears, or distortion in the valve material;
(iii) Improper insertion of the valve body in the face piece;
(iv) Cracks, breaks, or chips in the valve body, particularly in the sealing
surface;
(v) Missing or defective valve cover; and
(vi) Improper installation of the valve in the valve body;
d) Examine the air purifying elements for:
(i) Incorrect installation, loose connections, missing or warn gaskets, or
cross-threading in holder; and
(ii) Cracks or dents in outside case of filter, cartridge, or canister;
e) If the device has a corrugated breathing tube, examine it for:
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RPP-1 Book 14
(i) Broken or missing end connectors;
(ii) Missing or loose hose clamps; and
Date: 12/19 Revision EFR-7
Page 20 of32
(iii) Deterioration (determined by stretching the tube and looking for cracks);
t) Examine the harness of a front or back mounted gas mask for:
(i) Damage or wear to the canister holder which may prevent its being held
secure I y in place; and
(ii) Broken harness straps or fastenings; and
g) Blower mechanism on the PAPR units only:
(i)
(ii)
2.10.3.3
Damage to the outer casing of the blower unit will result in the
replacement of the blower; and
Missing or broken pins that connect the blower to the battery pack will
result in replacing of damaged pieces.
Supplied Air Respirators
The following shall be checked:
a) If the device has a tight-fitting face piece, use the procedures outlined above for
air purifying respirators; and
b) Examine the air supply for:
(i) Integrity and good condition of air supply lines and hoses including
attachments and end fittings; and
(ii) Correct operation and condition of all regulators, valves, or other air flow
regulators.
A visual inspection of the SCBAs shall be performed monthly, and a thorough
examination shall be performed two or three times per year. See Section 2.10.3.5 below.
Breathing air cylinders, including SCBA cylinders, must be tested as prescribed in the
Shipping Container Specification Regulations of the Department of Transportation ( 49
CFR 173 and 178). Each breathing air cylinder will be permanently and legibly marked
"Breathing Air" or "Compressed Air".
2.10.3.4 Re-use of Respirator Filters
Respirator filters can be re-used by the same person on the same day without being re-
tested, as long as contamination control is adequate, and the filters do not appear to be
damaged. Filters to be re-used during the same day should not have any apparent damage
and should meet the Mill's criteria for residual contamination, set out in Section 2.10.3.1.
Filters will be discarded after each day's use.
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2.10.3.5 Respirators Used for Emergency Use
Date: 12/19 Revision EFR-7
Page 21 of 32
Respirators specifically designated for emergency use are visually inspected once per
month and removed from any protective container and thoroughly examined periodically
(e.g., 2 to 3 times per year). Such monthly and periodic inspections will be recorded.
2.10.4 Quality Assurance
To prevent the use of faulty or defective respiratory equipment, the following steps will
be taken:
2.10.4.1 New Equipment
All new equipment will be thoroughly inspected before it is put into service (see Section
2.10.3 above). Only MSHA/NIOSH approved equipment will be used (see Section 1.5
above). Parts used for repairs will be purchased only from the manufacturer of the unit
being repaired or their agents (see Section 2.10.1 above).
2.10.4.2 Cleaning and Repairs
All respiratory devices will be inspected before and after cleaning and before and after
repairs are made. The inspection procedures that are to be used are listed above under
Section 2.10.3.
Any replacement items that will be used for repairs will be inspected prior to assembly.
2.10.4.3 Periodic Checks of Items in Storage
At least once during each quarter, all of the respirators that are in storage will be checked
for serviceability and to make sure that they will be ready for immediate use. See Section
2.10.3.1.
2.10.5 Service Life Limitations
If the respirator equipment manufacturer specifies a shelf life or service life limit on one
or more components of a respiratory protection system the Mill will comply with the
recommendations of the manufacturer. This will ensure that the device continues to
operate properly and that the "like-new condition" is maintained (see Section 1.5 above).
2.11 Recordkeeping
Records of all required activities in this program will be kept in a manner that shows
compliance with the requirements of the applicable regulations. Specifically, the
following records will be kept:
a) A log sheet for issuance and return of respirators;
b) A removable alpha survey sheet for respiratory devices; and
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c) Freshly cleaned and inspected respirators will be placed in plastic bags and
sealed (see Section 2.10.3.1 above). The individual who cleaned and inspected
the respirator will write the date on each bag and initial it to indicate the work
has been done properly.
2.12 Limitations on Periods of Respirator Use and Relief from Respirator Use
As noted above under Section 1.1, the NRC has noted that the use of respiratory
protection devices in the workplace can impose physiological and psychological stresses
on workers, obstruct their vision, hinder their movements, and make effective
communications difficult. In consideration of this, a respirator wearer will be permitted
to leave the work area for any respirator-related cause. Reasons which may cause a
respirator wearer to leave a work area, include, but are not limited to, the following:
a) Failure of the respirator to provide adequate protection;
b) Malfunction of the respirator;
c) Detection of leakage of air contaminant into the respirator;
d) Increased resistance to breathing;
e) Severe discomfort in wearing the respirator;
f) Illness of the wearer including: sensation of dizziness, nausea, weakness,
fatigue, breathing difficulty, coughing, sneezing, vomiting, fever, or chills; and
g) Claustrophobia, anxiety, or other psychological factors that may affect the
wearer.
2.13 Monitoring, Including Air Sampling and Bioassays
2.13.1 Evaluation of Respiratory Hazards
Before a respiratory protective device is used, the work area must be evaluated as to the
type of hazards that may be encountered. The type of respiratory protection may be
selected only after the hazard has been classified.
Most areas of the Mill have been evaluated for hazards during routine work assignments.
Signs will be posted in the different areas that will indicate the type of respiratory device
to be used under normal conditions.
Equipment needed:
a) Oxygen and Combustible Gas Detector;
b) MSA Orion or equivalent;
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c) MSA Samplair Pump Kit (or similar) with the following detector tubes:
(i) Carbon Dioxide;
(ii) Carbon Monoxide;
(iii) Sulfur Dioxide;
(iv) Ammonia;
(v) Hydrogen Sulfide;
(vi) Nitrous Oxide;
(vii) Halogen Gases (Chlorine);
(viii) Acid fumes and mists; and
(ix) Organic vapors; and
d) Detector tubes for HF and any other potential gas, as determined by the RSO.
Many environmental designs were incorporated into the Mill's construction to keep
exposures to most hazards at a minimum. This environmental equipment is checked
frequently to ensure that it is functioning properly.
To ensure the reliability of these controls, monthly gross alpha and radon daughters
samples will be collected at numerous locations throughout the Mill. Routine samples
will also be collected in the vanadium precipitation and packaging areas and analyzed for
airborne vanadium.
The routine samples have already identified some areas that require respirator use at all
times during normal working conditions. These areas are inside the yellowcake dryer and
packaging enclosures and the vanadium dryer area and the packaging area. Other areas
that may require respirator use may include, but would not be limited to, the sample
bucking room, and the SAG mill.
Respirators need not be worn routinely during normal working conditions in other areas
of the Mill. At these locations, usage will be determined by the hazard level or at the
worker's request. Occasionally, a condition may exist that the environmental controls
cannot handle. At that time, the appropriate respirator must be used until the workplace
atmosphere is returned to normal.
Infrequently, maintenance work will have to be performed in areas that are not normally
sampled or areas that may have questionable air quality. Prior to anyone entering one of
these areas, the environment must be evaluated to determine what hazards exist.
A Safe Work Permit is issued for all work tasks that are anticipated to present
unidentified or unusual hazardous environmental conditions. A Radiation Work Permit
(RWP) is issued for work in unassessed areas or for nonrecurring tasks for which
engineering controls are not in place or practical. The Radiation Safety Department will
be responsible for the evaluation of the areas before work begins.
Oxygen concentration is checked by a portable detector to determine the exact oxygen-air
mixture. NIOSH defines that air which contains less than 19.5% 02 as an oxygen-
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
Date: 12/19 Revision EFR-7
Page 24 of32
deficient atmosphere and attempting to breathe such air is considered to present a hazard
that would be immediately dangerous to life and health. Any area having less than 19.5%
02 will not be entered until or unless the 02 concentration returns to and is maintained at
a level above 19.5%. If an area is identified as having an oxygen-deficient atmosphere,
the oxygen levels must be remedied by engineering controls prior to entry by personnel.
The use of a SCBA is allowed only for emergency escape or emergency response
purposes.
Other atmospheric hazards will be identified and quantified by using air sampling
equipment, such as the MSA Samplair Pump (or similar device) with detector tubes for
the specific contaminant in question. The instructions must be carefully read for every
test, as each type of detector tube is handled differently.
After exposure to the atmosphere, the tubes will indicate the presence and concentration
of the chemical for which that tube is designed. Chemical cartridges are good only in
atmospheres in which the chemical concentration is less than the limit set by the
manufacturer and the oxygen concentration is equal to or greater than 19.5%. As noted
above, the Mill's policy is for workers not to enter an area in which the 02 level is below
19.5%, but to enter such areas only in emergency situations, such as to retrieve an injured
worker, and then with the use of a SCBA.
There are many other hazards that are very obvious but are often overlooked. The
following are examples:
• dust concentrations have an adverse effect on breathing and/or the comfort of the
individual; and
• some substances may cause irritation to the eyes, nose, throat, etc., but may not be
chemically toxic.
These and other such conditions should always be considered in evaluating respiratory
hazards. If there is any doubt about the conditions within the work area, a respiratory
device should be used. Always be conservative.
2.13.2 Breathing Zone Air Samples
Breathing zone samples are collected to determine the air contamination concentration an
individual may be exposed to during the execution of his job. The respiratory protection
factor is used to calculate the individual's exposure during the work task duration. The
application of a respiratory protection factor assigned to the particular respiratory device
is used to reduce an individual's exposure to an air contaminant concentration as
determined by breathing zone sampling. Routine breathing zone samples are collected by
the use of a small belt-mounted pump attached to a hose that is, in turn, attached to the
person's clothing close to the head (or breathing zone). The sample is collected for a
period of time that would be representative of one eight-hour workday. They are
collected in such a manner that the material collected will be representative of that being
inhaled by the individual wearing the sampler. See Section 1.1.2 of the Mill's Radiation
Protection Manual for the detailed procedures to be followed for breathing zone samples.
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RPP-1 Book 14
2.13.3 BioassayProgram
Date: 12/19 Revision EFR-7
Page 25 of 32
Evaluation of the effectiveness of the respiratory protection program will be
accomplished by air sampling (described above in 2.13.2) and by the Mill Bioassay
Program.
Those workers who are working in areas that require the use of respirators will submit a
urine specimen for analysis on a biweekly basis. Workers who use respirators during
maintenance may also be required to submit specimens after maintenance ceases. The
samples will be collected from individuals who have performed maintenance tasks in
atmospheres that are significantly elevated in contaminant concentration or they are
working in such an area for an extended period of time.
The specimens will be analyzed for uranium content.
See Section 1.4 of the Mill's Radiation Protection Manual for the detailed procedures to
be followed for bioassays.
2.14 Communication
Respiratory protection devices limit the wearer's ability to communicate. However, all
respirator users must be able to communicate well enough to be able to work safely and
to keep radiation doses ALARA. The RSO will use his judgment in determining how
these goals can best be satisfied. In many situations, adequate communication can be
maintained by training the respirator wearers to speak slowly and distinctly. In other
situations, especially where ambient noise levels are high or where respirator wearers
must communicate across long distances, voice-amplification devices or other types of
systems might have to be employed.
If voice-amplification devices are attached to the respirator or require a modification of
the respirator, they must be listed on the manufacturer's schedule of approved
subassemblies. This ensures that the NIOSH approval for the device remains in force
with the addition of the communications equipment.
After-market communications devices supplied by a company other than the respirator
manufacturer may be used as long as they do not alter the form, fit, or function of the
respirator. Any such after-market device that attaches to or requires penetration of the
respiratory inlet covering is likely to void the NIOSH approval for the device.
2.15 Vision
Some types of respirators prevent the wearer from using standard spectacles or from
using them properly. The earpieces of standard spectacles pass through the seal area of
full-facepiece respirators and are therefore not allowed. However, respirator users must
be able to see well enough to be able to work safely and to keep radiation doses ALARA.
The RSO will use his judgment in determining how these goals can best be met.
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
Date: 12/19 Revision EFR-7
Page 26 of32
Most manufacturers of full-facepiece respirators offer a spectacle adapter kit. Non-
manufacturer-supplied adapters may be acceptable if they do not interfere with the
facepiece seal and if they do not cause any distortion of vision, damage the lens of the
face-piece, or cause any harm to the wearer during use. Home-made adapters are not
acceptable, not is it acceptable to simply tape the spectacles inside the facepiece.
2.16 Use of Respirators in Low Temperatures
The RSO should recognize the potential problems associated with respirator use in
subfreezing environments, discussed below, and take special care when respirators are
used in subfreezing temperatures.
2.16.1 Lens Fogging
Fogging of the inside of the respirator lens is commonly experienced in full facepiece
respirators. The fogging is caused by the condensation of the moisture in exhaled breath
that comes in direct contact with the inside of the lens. Most full facepiece respirators
have air inlet ducts positioned to direct the inhaled air across the inside of the lens as it
enters the facepiece. This clears off the accumulated condensation, but the lens fogs
again during exhalation. The cooler the ambient air temperature, the less effective the
lens clearing provided during inhalation. At temperatures below freezing, lens frosting
can occur that will not be removed during inhalation and may eventually seriously
obscure the wearer's vision. Lens fogging and frosting, therefore, can present a
significant safety hazard by restricting the wearer's ability to see clearly in the workplace.
Some possible solutions to the fogging and frosting problem, that can be employed by the
RSO in his discretion, are:
a) Nose Cup.
Most full-facepiece manufacturers provide an optional component called a nose cup. It is
attached to the inside of the facepiece in such a way that it directs the stream of exhaled
air directly into the exhalation valve, minimizing the amount of moist air contacting the
interior of the lens.
b) Anti-Fog Applications.
Most full-facepiece manufacturers provide an anti-fog material that limits fogging when
applied to the interior of the respirator lens.
c) Plastic Inserts.
Thin plastic inserts that are applied to the inside of the facepiece lens to form a double-
pane insulating barrier may effectively reduce fogging.
Before using commercial anti-fogging products (that are not supplied by the respirator
manufacturer), the RSO should check with the respirator manufacturer regarding the
compatibility of these products with their facepieces.
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Date: 12/19 Revision EFR-7
Page 27 of32
NIOSH requires that facepieces used with SCBA be designed to prevent lens fogging.
This means that, in order to maintain the NIOSH certification of the device, a nose cup or
some other method must be used when fogging might be a problem.
2.5.2 Exhalation Valve Freezing
Another potential problem when using any type of face-sealing respirator in subfreezing
temperatures is the possibility that the exhalation valve could freeze. If the valve freezes
shut, exhaled air will be exhausted through the face-to-facepiece seal area and the
respirator wearer will be aware of the malfunction. In this case, the respirator will
probably provide adequate protection as the wearer exits the work area.
If the valve freezes in the open position, or if ice forms on a portion of the exhalation
valve seat, a path is created for contaminated ambient air to enter the respiratory inlet
covering. If the device in use were a PAPR or a continuous-flow supplied-air respirator,
it is likely that the respirator wearer would not be aware of the malfunction, although the
internal dose consequences of this type of failure would probably be limited.
If the device in use were a pressure-demand supplied-air device (e.g., air line-supplied or
SCBA), it is likely that the respirator wearer would recognize that a malfunction had
occurred since air would leak out of the facepiece through the exhalation valve. Even
though the wearer would continue to be adequately protected, he or she should exit the
work area immediately since a respirator malfunction has occurred. If the device in use is
a SCBA, the duration of the air supply will be reduced because of the loss of breathing
gas from the supply cylinder.
If the device in use is operated in the negative pressure mode, it is unlikely that the
respirator wearer would be aware of the malfunction. The air breathed by the wearer
would, at least in part, be unfiltered ambient air entering the respiratory inlet covering
through the open exhalation valve during the negative-pressure (inhalation) portion of the
breathing cycle.
3. PROCEDURES FOR MEDICAL EVALUATIONS AND AUDITS
3.1 Performing and Documenting the Required Medical Evaluation
Medical qualification will be required of each worker that might be using a respirator in
his or her normal work duties. This is necessary to evaluate the individual's limitations
to wearing respirator devices.
3.1.1 The Mill's Physician
The medical evaluation will be performed by a licensed physician, selected by the RSO,
to determine that the individual user is medically fit to use the respiratory protection
equipment. The RSO will choose a physician with an appropriate specialty (e.g., internal
medicine, industrial medicine, family practice), and the physician will be licensed to
practice medicine in the United States.
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RPP-1 Book 14
3.1.2 Establishing and Performing the Evaluation
Date: 12/19 Revision EFR-7
Page 28 of32
The medical screening process and tests and acceptance criteria will be determined by the
physician and will include a medical history and will be sufficient (in the opinion of the
physician) to identify any person who should not use respiratory devices for medical
reasons, or who should be limited to the use of specific types of respirators. The
physician will report any medical restrictions the worker has that would limit the
individual's ability to use a respirator. Based on the physician's recommendations, any
worker may be subject to additional or more frequent medical evaluation as deemed
necessary by the physician.
ANSI Z88.6-1984, "Respirator Use -Physical Qualifications for Personnel," provides
guidance that is acceptable to the NRC staff for the physician to use in determining
medical fitness. The screening method may include a medical history questionnaire and
spirometry testing. The physician, however, establishes the precise screening method.
The medical evaluation program should be carried out by the physician, or by a certified,
medically trained individual such as a registered nurse (RN), licensed practical nurse
(LPN), emergency medical technician (EMT), or someone who, in the judgment of the
physician, has adequate experience education, training, and judgment to administer the
screening program.
Medical evaluations performed by a physician other than the Mill's designated physician
may be acceptable as long as comparable screening tests and acceptance criteria are used
for screening individuals.
3 .1. 3 Timing of Medical Evaluations
The initial medical evaluation to determine a worker's fitness to use respirators must be
accomplished prior to respirator fit-testing.
The worker must be re-evaluated medically every 12 months thereafter or at some other
frequency established by the Mill's physician. The Mill's physician has established the
following frequency for re-evaluation:
• Every five years for workers under the age of 45; and
• Every year for workers 45 years or older.
3.1.4 Failure to Meet the Acceptance Criteria
Individuals whose screening results fall outside the range of the criteria established by the
Mill's physician may have their cases evaluated by the physician. This evaluation might
consist only of a review of the written record, or it might involve a hands-on
examination. In these situations, the physician might permit the individual to use one or
more types of respirators judged to impose less stress and prohibit the use of other more
stressful devices. The Mill's physician may confirm the outcome of the screening by
prohibiting the individual from using any respirator.
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
3.1.5 Privacy of Medical Records
Date: 12/19 Revision EFR-7
Page 29 of 32
Medical records and the results of medical screening tests will be kept private to the
extent possible. The only information that will be transmitted from the RSO and any
other respiratory program supervisory personnel to the non-supervisory personnel in the
respirator department is whether or not an individual may use respirators, or which
devices may be used, and which may not be.
3.2 Maintaining TEDE ALARA and Performing ALARA Evaluations of
Respiratory Protection
3.2.1 ALARA Evaluations
As stated in the Policy Statement in 1.0, the Mill will use, to the extent practical,
procedures and engineering controls based on sound protection principles to achieve
exposures to radiation ALARA and shall limit intakes by means of engineering controls
or procedures, along with the use of respirators, consistent with maintaining the TEDE
ALARA.
The Mill will endeavor to limit the use of respirators to situations in which respirator use
has been shown to keep TEDE ALARA. Other methods of protection against airborne
radioactive material, such as the use of process or other engineering controls, limitation
of exposure times, decontamination and so on, will be considered before the use of
respirators.
Mill staff will perform an ALARA evaluation of the types of situations that will require
the use of respirators and, if necessary, for unusual or non-recurring circumstances. As
mentioned above, there are undesirable effects from the use of respiratory protection.
The use of respiratory protection devices in the workplace can impose physiological and
psychological stresses on workers, obstruct their vision, hinder their movements, and
make effective communications difficult. These factors increase the risk of physical
injury to respiratory wearers that, in many cases, far exceed any potential risk associated
with the inhalation of a small quantity of airborne radioactive material. Therefore, when
performing an ALARA analysis for the use of respiratory protection in any
circumstances, and the results do not show a clear, obvious indication (to use or not use
respirators), the RSO will use professional judgment as to whether or not to assign
respirators in the circumstances.
When a specific ALARA evaluation is performed to justify the use or nonuse of
respirators, the evaluation will consider the following elements:
a) The use of process and engineering controls, filtered ventilation systems, and
decontamination before the use of respiratory protection devices;
b) Control of access, limitation of exposure time, and the use of other types of
exposure controls before the use of respiratory protection devices, and
c) The estimated benefit.
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RPP-1 Book 14
Date: 12/19 Revision EFR-7
Page 30 of32
In performing an ALARA evaluation, when deciding which respirator is to be considered
for assignment during a specific task, the RSO will divide the average ambient
concentration of radioactive material in workplace air (or the estimated average) by the
appropriate DAC value for the contaminants present. The number obtained may be
considered initially as an ideal minimum APF for the selected device. If the ALARA
evaluation determines that use of a respiratory protection device might be justified, the
RSO should consider a device with this APF or greater. If selection of a respirator with
this APF is inconsistent with ALARA, however, the RSO may select a device with a
lower APF. Worker safety factors other than radiological factors, such as heat stress or
impaired vision, should be taken into account when performing such an ALARA
evaluation. Consideration should also be given to the possibility that the planned work
will cause re-suspension of radioactive material, thus increasing the average
concentration during the task.
The extent and level of detail addressed in TEDE ALARA evaluations should be
commensurate with the potential radiological and physical risks involved in the activity.
The RSO should consider the following factors in an evaluation of whether respirator use
isALARA:
• Environmental conditions;
• Protective equipment and clothing, including the respirator, that would be
required for the activity being evaluated and their effects on worker efficiency;
• Comfort level of the workers regarding the use of respirators;
• Experience and skill level of the individual with respect to the task;
• Process and engineering controls to be used;
• Specific details of the tasks to be performed (e.g .. dose rates, estimated average
airborne concentrations); and
• Potential post-activity negative impacts (e.g., personnel decontamination and skin
dose assessments, portal monitor alarms).
Such evaluations may either be job-specific or be performed for general job types.
ALARA evaluations performed for general job types will be reviewed periodically, as
necessary, to ensure that none of the assumptions or parameters upon which the
evaluation is based has changed.
The RSO should be able to support the decision to use or not to use respirators in each
circumstance. Supporting information could include the results of surveys,
measurements and calculations, previous history with this or similar jobs, or other
pertinent data. The judgment of individuals, such as the RSO, with extensive knowledge
and experience in the field may also be sufficient in circumstances that are not amenable
to quantitative analysis.
For ALARA evaluations, a respirator-induced worker inefficiency factor of up to 15%
may be used without further justification. Larger worker efficiency factors may be used,
but the RSO should have test data to support them.
White Mesa Mill -Standard Operating Procedures
RPP-1 Book 14
3.2.2 Estimated ALARA Benefit
Date: 12/19 Revision EFR-7
Page 31 of 32
The evaluation should demonstrate whether or not the TEDE for the job will be ALARA;
that is, whether the internal dose avoided by using the respiratory protection equipment is
likely to be greater than or less than any additional external dose that may result from the
use of these devices from respirator-induced and other factors. Non-radiological factors
should be included.
3.2.3 ALARA Evaluation -Records
The Mill has established 0.50 mrem/hr. for prospective external deep dose equivalent
from a task or job below which a record of an ALARA evaluation for the use of
respirators is not needed. A Radiation Work Permit (RWP) may serve as the record of an
ALARA evaluation for the use of respirators for a specific task or job.
Regardless of the magnitude of the projected external and internal dose, the RSO does
not need to perform or record ALARA evaluations before requiring the use of respiratory
protection equipment as a precautionary measure when there is a large uncertainty about
the magnitude of the projected concentrations of airborne radioactive material to which
the workers will be exposed (e.g., a new job with significant airborne contamination
potential, but with no history of previous similar jobs).
3.2.4 Exceptions to ALARA Requirements for Respirators
The RSO may require the use of respirators in any situation where, in his judgment,
respiratory protection would be appropriate, even though a dose assessment would
indicate that respiratory protection is not required.
However, when the use or non-use of respirators has no clear impact on TEDE, the RSO
should opt to not use respirators in most circumstances.
A reduction in TEDE for a worker would not be reasonable if an attendant increase in the
worker's industrial health and safety risk (e.g., from a vision limitation or other
respirator-related problem) would exceed the benefit to be obtained by reducing the risk
associated with the reduction in TEDE.
4. PROCEDURES FOR RESPIRATOR APPLICATIONS
4.1 Routine Respirator Use
Donning a respirator must be performed in accordance with the training provided.
Procedures for routine respirator use are set out in detail in the foregoing Sections of this
Program.
4.2 Non-routine Respirator Use
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Date: 12/19 Revision EFR-7
Page 32 of 32
Non-routine Respirator Use shall be defined as use of respirators in un~assessed areas or
for nonrecurring tasks for which engineering controls are not in place or practical. The
same procedures apply to non-routine respirator use as apply to routine respirator use, as
detailed in this Program.
4.3 Emergency Respirator Use
Emergency Respirator Use shall be for recovery of an injured person from an area where
air concentrations of radioactive material may be high, the breathing quality of the
ambient air has not been assessed, or the area may become immediately dangerous to life
or health because of the presence of non-radiological hazards.
Respirators designed for emergency use will be stored in areas that are readily accessible
to all workers. Emergency cabinets are located on the north side of the Mill building
outside of the SAG Mill doors, outside the SX on the north wall, on the south end of SX
on the fire cabinet, and at the fire hose station at the front gate.
The equipment preferred for emergency entry into an unassessed environment, or into an
area with high concentrations of a chemical hazard, is the SCBA operated in the pressure-
demand mode, with a minimum rated service life of 30 minutes. For other emergency
use against airborne radioactive material, the full-face air purifying respirators normally
used at the facility will be adequate.
The use of demand SCBA in emergency firefighting situations is not permitted, because
such respirators do not meet National Fire Protection Association standards.
4.4 Safety
4.4.1 General
Procedures intended to ensure the safety of the worker are set out m detail m the
foregoing Sections of this Program
4.4.2 Unassessed Environments
For entry into areas where the level of hazard has not been assessed because of the
existence of unusual conditions, or in response to unanticipated releases of radioactive
material, workers must use only SCBA operated in pressure-demand mode. However,
the use of SCBA to circumvent the pre-exposure sampling requirement (R313-15-703 10
CFR 20.1703(c)(l)) is not permitted for non-emergency activities.
4.4.3 Emergency Escape
For emergency escape from normally safe environments, where a respiratory hazard
might develop suddenly, any of the full face, PAPR or SCBA devices used at the Mill
may be used so long as it provides adequate short-term protection against the type of
hazard that might be encountered.
EMERGENCY RESPONSE PLAN
REVISION 6.0
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Blanding, Utah
Revised
May 21, 2019
Book #16 Energy Fuels Resources (USA) Inc .
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 51
Date: May 2019 Tit)e: White Mesa Mill Emergency Response Plan
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................... 3
1.1 MILL OVERVIEW ...................................................................................................... 4
1.2 PLAN OBJECTIVES .................................................................................................... 4
2.0 FACILITY DES CR IPTI ON ........................................................................................................ 4
2.1 Description of Licensed Activity .............................................................................. 4
2.2 Description of Facility and Site ............................................................................... 5
2.3 Description of Area Near the Site ......................................................................... 13
3.0 TYPES OF ACCIDENTS ........................................................................................................ 14
3.1 Description of Postulated Accidents ..................................................................... 14
3. 2 Detection of Accidents .......................................................................................... 26
4.0 CLASSIFICATION AND NOTIFICATION OF ACCIDENTS ....................................................... 27
4.1 Classification System ............................................................................................. 27
4. 2 Notification and Coordination .............................................................................. 30
4.3 Information to be Communicated ........................................................................ 31
5.0 RESPONSIBILITIES .............................................................................................................. 32
5 .1 Normal Facility Organization ................................................................................ 32
5.2 Onsite Emergency Response Organization ........................................................... 32
5.3 Local Offsite Assistance to Facility ........................................................................ 37
5.4 Coordination with Participating Government Agencies ....................................... 38
6.0 EM ERG EN CY RESPONSE MEASURES ................................................................................. 39
6.1 Activation of Emergency Response Organization ................................................. 39
6. 2 Assessment Actions .............................................................................................. 39
6.3 Mitigating Actions ................................................................................................. 40
6.4 Protective Actions ................................................................................................. 40
6.5 Exposure Control in Radiological Emergencies ..................................................... 42
6. 6 Med ica I Transportation ........................................................................................ 44
6. 7 Medical Treatment ............................................................................................... 44
7.0 EMERGENCY RESPONSE EQUIPMENT AND FACILITIES ..................................................... 45
7 .1 Command Center .................................................................................................. 45
7.2 Communications Equipment ................................................................................ 45
7.3 Onsite Medical Facilities ....................................................................................... 46
7.4 Emergency Monitoring Equipment.. ..................................................................... 46
8.0 MAINTAINING EMERGENCY PREPAREDNESS CAPABILITY ................................................ 47
8.1 Written Emergency Plan Procedures .................................................................... 47
8.2 Training ................................................................................................................. 4 7
8. 3 Drills and Exercises ................................................................................................ 4 7
8.4 Critiques ................................................................................................................ 48
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
8.5 Independent Audit ................................................................................................ 48
8.6 Maintenance and Inventory of Emergency Equipment, Instrumentation and
Supplies ............................................................................................................................. 49
8. 7 Letters of Agreement ............................................................................................ 49
9.0 RECORDS AND REPORTS ................................................................................................... 49
9.1 Records of Incidents .............................................................................................. 49
9.2 Records of Preparedness Assurance ..................................................................... 50
10.0 RECOVERY AND PLANT RESTORATION ............................................................................. 50
11.0 COMPLIANCE WITH COMMUNITY RIGHT-TO-KNOW ACT AND CLEAN AIR ACT .............. 50
11.1 Community Right to Know Act .............................................................................. 50
11.2 Clean Air Act .......................................................................................................... 51
List of Figures
Figure 1 White Mesa Mil Location Map
Figure 2 Mill Site Layout
Figure 3 Fire System Schematic
Figure 4 Drainage Map ofthe Vicinity of the White Mesa Mill
Figure 5 Population Centers Map
Figure 6 Organization Chart
List of Exhibits
Exhibit 1 Main Shut Off Valves
Exhibit 2
Exhibit 3
Internal Notifications
Emergency Notifications List
List of Appendices
Appendix A Emergency Response Procedure for a Release of Anhydrous Ammonia
Appendix B Emergency Response Procedure for an Ammonia Explosion in a Building
Appendix C Emergency Response Procedure for a Release of Propane or Liquefied Natural
Gas (LNG) Methane
Appendix D Emergency Response Procedure for a Leach Tank Failure or Sulfuric Acid Tank
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Appendix J
Appendix K
Appendix L
Failure
Emergency Response Procedure for a Fire in the Solvent Extraction Building
Emergency Response Procedure for a Fire
Emergency Response Procedure for a Tornado or Major Earthquake
Emergency Response Procedure for Tailings Accidents
Emergency Response Procedure for a Terrorist/Bomb Threat
Emergency Evacuation and Shut Down Procedure
Clean Air Act Section 112r -Risk Management Program
Transportation Accident Plan
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
1.0 INTRODUCTION
The purpose of this Emergency Response Plan (this "Plan") is to reduce the risk to our
employees and to the community from potential health, safety and environmental emergencies
that could arise at the Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Uranium Mill
(the "Mill").
This plan includes the following:
• evaluation of the potential risks for accidents, including fire, explosions, gas releases,
chemical spills and floods (including tailings dam failure), that could occur at the Mill;
• specific emergency programs for each potential event;
• administrative response actions; and,
• emergency response contacts -both internal and external.
The Mill operates under the jurisdiction of the following regulatory agencies:
• Utah State Department of Environmental Quality, Division of Radiation Control;
• Mine Safety and Health Administration;
• Environmental Protection Agency;
• Utah State Department of Environmental Quality, Division of Air Quality; and,
• Utah State Division of Natural Resources Bureau of Dam Safety.
This Plan follows the standard format and content for emergency plans for fuel cycle and
materials facilities set out in U.S. Nuclear Regulatory Commission ("NRC") Regulatory Guide
3.67 (January 1992) ("Reg. Guide 3.67"), to the extent applicable to the Mill. Section 3 of Reg.
Guide 3.67 states that "in its emergency response plan and in coordination meetings with offsite
authorities, the licensee should convey the concept that fuel cycle and materials facilities do not
present the same degree of hazard (by orders of magnitude) as are presented by nuclear power
plants. Thus the classification scheme for these facilities is different." Reg. Guide 3.67 also
refers to NRC' s NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel
Cycle and Other Radioactive Material Licensees", S.A. McGuire, January 1988, for a description
of past incidents involving radioactive materials.
NUREG-1140 analyzed potential accidents for 15 types of fuel cycle and other radioactive
material licensees, including uranium mills, for their potential for offsite releases of radioactive
materials. NUREG-1140 concludes that for most of these licensees, for example uranium mills,
the degree of hazard is small and that "the low potential off site doses ... the small areas where
actions would be warranted, the small number of people involved, and the fact that the local
police and fire departments would be doing essentially the same things they normally do, are all
factors that tend to make a simple plan adequate." NUREG-1140 concludes that "an appropriate
plan would (1) identify accidents for which protective actions should be taken by people offsite.
(2) List the licensee's responsibilities for each type of accident, including notification of local
authorities (fire and police generally), and (3) give sample messages for local authorities
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
including protective action recommendations. This approach more closely follows the approach
used for research reactors than for power reactors."
As a result, this Plan incorporates the most appropriate responses for the Mill, in accordance with
the requirements of Reg. Guide 3.67 and the conclusions set out in NUREG-1140.
1.1 MILL OVERVIEW
Master files containing Safety Data Sheets ("SDSs") for all materials in use at the Mill are
maintained at the Safety Office, Mill Maintenance Office, Mill Laboratory and Mill Central
Control Room. Copies are also on file at the Blanding Clinic, Doctor's Offices, Blanding Fire
House and Office of the San Juan County Emergency Medical Coordinator.
1.2 PLAN OBJECTIVES
The primary objectives of this plan are:
• To save lives, prevent injuries, prevent panic, and minimize property/environmental
damage to the lowest possible level;
• To evacuate and account for all people in the area including visitors, truck drivers,
contractors, etc.;
• To provide assembly areas that are as safe as possible and which can be reached without
traveling through a hazardous area. Assembly areas will be properly manned to deal with
sick or injured persons, and provisions will be made to evacuate those persons to proper
shelter; and
• To make adequately trained personnel available to cope with rescue and recovery
operations as directed by the Incident Commander.
2.0 FACILITY DESCRIPTION
2.1 DESCRIPTION OF LICENSED ACTIVITY
The Mill is located approximately 6 miles south of Blanding, Utah. See the White Mesa Mill
Location Map included as Figure 1. The Mill processes conventional uranium or
uranium/vanadium ores to recover uranium and vanadium. In addition to the processing of
conventional ores, the Mill also processes alternate feed materials using similar process steps and
chemicals. The conventional ore is stored on the Ore Pad (shown on the Site Layout Map
included as Figure 2). Alternate feed materials are also stored on the Ore Pad and may be stored
in bulk form, lined burrito style bags, liners or drums. In certain circumstances, containerized
alternate feed materials may be stored in locations off of the ore pad.
All of the ores and feeds processed at the Mill contain natural uranium and its daughter products.
Uranium is in equilibrium with its daughters for conventional ores and is generally in various
degrees of disequilibrium with its daughters for alternate feed materials, depending on the
specific feed material. The descriptions of each alternate feed material are maintained by the
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Mill's Radiation Safety Officer ("RSO"). However, the Mill does not receive, process or
produce enriched uranium of any sort, therefore there is no risk of a criticality accident at the
Mill. The products produced at the Mill include ammonium metavanadate (AMY), vanadium
pregnant liquor (VPL), vanadium pentoxide (V 20s), and yellowcake, or uranium concentrate
(U30s). The U30s product is packaged in steel drums for shipment. The V20s product is
packaged in steel drums or super-saks for shipment. The AMY is packaged in either steel drums
or super-saks while the VPL is sold in liquid form in bulk.
Drums containing U30s and vanadium product are stored from time to time in a fenced, locked,
paved area in the Mill's restricted area, pending shipment offsite.
The Mill utilizes a semi-autogenous grind circuit (SAG mill) followed by a hot sulfuric acid
leach and a solvent extraction process to extract uranium and vanadium from ores, using large
amounts of sulfuric acid, sodium chlorate, kerosene, amines, ammonia and caustic soda in the
process. The reagent storage tank locations are described in further detail in Section 2.2.9 below.
At any one time, there may by 1.4 million gallons of sulfuric acid, 63,000 gallons of anhydrous
ammonia, 220,000 gallons of kerosene (which includes the kerosene in the Mill processes),
20,000 gallons of caustic soda and 30,000 gallons of propane and various quantities of other
reagents stored or located on site. See Sections 2.26, 2.27 and 2.29 for a more detailed
discussion of the chemicals and reagents used and stored at the site.
Tailings and wastes generated from processing conventional ores and alternate feed materials are
disposed of permanently in the Mill's lined tailings impoundments. The Mill's tailings system is
comprised of five engineered cells, Cells 1, 2, 3, 4A and 4B. Cell 4A receives the Mill's tailings
sands. Cell 2 is closed. Cell 3 is nearly filled and no longer receives tailings sands or solutions.
Cells 1 and 4B receive solutions only, and are in operation as evaporative ponds. The liquid in
the tailings cells is very acidic. Solutions in the tailings cells should not be used to fight fires in
the Mill facility.
2.2 DESCRIPTION OF FACILITY AND SITE
2.2.1 Site Drawing
The Mill facilities are shown on the White Mesa Mil Location Map included as Figure 1 and on
the Site Layout Map included as Figure 2 ..
2.2.2 Communication and Assessment Centers
The Mill does not have a specific communication or assessment center. Key personnel are
equipped with handheld VHF transceivers, which will serve as the primary means of
communication while personnel are assembling to the designated relocation areas and as needed
thereafter to deal with the emergency. The relocation area will serve as the initial assessment
center. Other communications and assessment centers will be set up in the Mill's Office
building, Scalehouse, Warehouse or other areas of the Mill that have communication capability,
as needed depending on the nature and location of the emergency.
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2.2.3 Assembly and Relocation Areas
When the evacuation alarm sounds or when personnel are verbally notified by radio or other
means, all personnel will assemble at:
• The parking lot south of the office;
• The Scalehouse;
• East side of Tailings Cell 1; or
• North of the Mill.
The assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions,
etc. The RSO or Safety Coordinator/Fire Chief or Shift Foreman will specify the appropriate
assembly site.
2.2.4 Fire Water Supply and Alarm Systems
a) Fire Water Supply
The fire water supply facilities include:
• 400,000 gallon Storage Tank of which 250,000 gallons are reserved for
fireemergencies; and
• Centrifugal diesel driven pump rated at 2,000 gpm at 100 psi. This pump starts
automatically when the pressure in the fire main drops below 100 psi (See Figure 3,
Fire System Schematic).
When more water is needed for an emergency an additional source is the Recapture Reservoir
supply pipeline, which can be utilized in emergencies at a rate of about 1,200 gpm.
b) Alarm System
The alarm systems include the following:
• hand held radios; and
• siren.
2.2.5 Office Building and Laboratory
a) Office Building
The office building (approximately 10,000 square feet) contains the administration offices,
radiation health and safety offices and the Mill laboratory. The central file vault and the main
computer system are also in this building.
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b) Laboratory
The laboratory facilities contain the following:
• three flammable, one solid acid and one poison cabinets (keys required);
• chemical storage room south of main lab;
• seven fume hoods -hoods 1, 2, 3 and 4 are in the chemical laboratory and hoods 5, 6
and 7 are in the metallurgical laboratory. Only hoods 1 and 2 may be used for
perchloric acid;
• area fume hoods in both laboratories
• outside laboratory chemical storage north of office building (key required);
• flammable/combustible material product storage container (keys required); and
• perchloric acid storage vault located underground west of office building (key
required).
A wide variety of chemicals in small quantities are located in the Mill laboratory. These
chemicals range from acids to bases along with flammable metal compounds and peroxide
forming compounds. Oxidizers and organic chemicals are stored in a storage room in the
laboratory, which have a strong potential of producing harmful vapors if the containers are
damaged to the point that the chemicals are exposed. There are no acids stored in this storage
room. The acids (including but not limited to sulfuric, nitric, acetic, perchloric, phosphoric and
hydrochloric acids) are stored in the main laboratory area in 2.5 liter or 500-ml bottles. SDS
books for all chemicals in the laboratory are located in the Laboratory and Safety Department.
c) Electrical
Electrical transformers and electrical switches are located in the laboratory at the east end of the
chemical storage room.
d) Fire Protection System
The fire protection systems in the office building and laboratory include:
• a fire hose station located on the east end of the office building. The station includes
two sets of turnout gear, two SCBA units and Incident Commander materials;
• automatic "wet" sprinkler system which is actuated at 212° F; and
• portable dry chemical extinguishers strategically located throughout the building.
2.2.6 Solvent Extraction Building
The solvent extraction (SX) building (approximately 21,000 square feet) houses the uranium and
vanadium solvent extraction circuits and the ELUEX circuit. The SX circuits may contain up to
200,000 gallons of kerosene (757,000 liters) which has a flash point of 185° F.
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Chemicals which may be encountered in the SX building include:
• Kerosene;
• Caustic Soda;
• Anhydrous Ammonia;
• Sulfuric Acid;
• Salt (Brine);
• Soda Ash;
• Ammonium Sulfate;
• Amines;
• Alcohol;
• Sodium Chlorate;
• Sodium Vanadate; and
• Propane .
The VPL product is stored in the SX building.
This area may contain other chemicals specific to individual projects. SDS's are available for all
chemicals that may be present at any given time.
a) Electrical
All electrical switches are located outside in the Motor Control Center (MCC) room north of the
SX building. The main control panel for all of the equipment is located in the Central Control
Room in the main Mill building.
b) Fire Protection System
The SX building fire protection systems include:
• a "wet" AFFF foam sprinkler system with heat actuated sprinkler heads that release at
212°F; and
• portable dry chemical extinguishers strategically located throughout the building.
For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic
included as Figure 3 in this Plan.
2.2. 7 Mill Building
The mill building (approximately 22,000 square feet) contains process equipment related to
grind, leach, counter current decantation, precipitation, and drying and packaging of uranium and
vanadium products.
Chemicals which may be encountered in the mill building include:
• Caustic Soda;
• Anhydrous Ammonia;
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• Sulfuric Acid;
• Soda Ash;
• Ammonium Sulfate;
• Sodium Chlorate;
• Sodium Vanadate; and
• Propane .
This area may contain other chemicals specific to individual projects. SDS's are available for all
chemicals that may be present at any given time.
The finished products which are contained in the mill building include AMV, V20s and U30s (or
yellowcake).
a) Electrical
The main electrical switch gear is located west of the SAG mill on the ground floor in the north
west corner of the mill building. Circuit control panels are located in the SAG mill MCC, the
central control room, the vanadium roaster control room and the AMV area.
b) Fire Protection System
The main mill building fire protection systems include:
• portable dry chemical extinguishers strategically located throughout the building; and
• water hoses throughout the building.
For fire hydrant and hose cabinet locations in the mill building refer to the Fire System
Schematic included as Figure 3 of this Plan.
2.2.8 Maintenance Shop/Warehouse/Change Room Building
This building (approximately 20,000 square feet) contains the main maintenance shop area
(located on the north end of the building), the main warehouse (located in the center of the
building) and the personnel change rooms and lunch/training room (located on the south end of
the building on the ground and second floors).
Within the maintenance shop area are the following work area and specialty shops:
• the main maintenance shop area contains welding and cutting equipment, lathes,
presses, and drill presses;
• fiberglass work is also done within this shop area and it is located at the northwest
end of the maintenance shop area;
• an electrical shop which is located south of the carpenter shop;
• a heavy equipment maintenance shop area is located at the north end of the
maintenance shop in the center of the building;
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• a rubber room for rubber lining of equipment is located east of the equipment shop
area; and
• the maintenance shop office, instrument shop and tool room are located at the south
end of the maintenance shop area.
The warehouse area contains primarily dry good storage for repair parts and consumables for the
operation of the Mill. There is an electrical water heater for the change room which is located in
the warehouse area at the south end.
Within the warehouse and maintenance shops there are some oils and chemicals stored in the
following locations:
• small quantities of flammable material such as starting fluid and spray paint are kept
in the warehouse;
• drums of new oil and anti-freeze are stored along the east wall of the equipment
maintenance area and on the east side of the warehouse on oil storage racks;
• used oil is stored in a tank located northeast of the equipment shop. The tank has a
capacity of approximately 6,000 gallons;
• in the main maintenance shop area and the rubber room there are flammable storage
cabinets; and
• compressed gas cylinder storage, both empty and full is located outside, east of the
warehouse.
a) Electrical
The main electrical circuit breaker for the maintenance shop and warehouse building is located
on the east wall inside the Maintenance shop. Auxiliary electrical panels for the change room
and warehouse are located in the southwest corner of the warehouse area.
b) Fire Protection System
The fire protection system within the maintenance shop/warehouse/change room building
includes:
• "wet" automatic sprinkler system that releases at 212° F; and
• portable dry chemical extinguishers strategically located throughout the maintenance
area, warehouse area and the change room and lunch room.
For fire hydrant and hose cabinet locations refer to the Fire System Schematic (Figure 3).
2.2.9 Reagent and Fuel Storage
The following lists the reagents and fuel stored at the Mill site:
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• a sulfuric acid tank located northwest of the mill building which has a capacity of
approximately 1.4 million gallons and a day sulfuric acid tank located on the north
side of the SX building with a capacity of approximately 9,000 gallons;
• a storage tank for propane is located on the north edge of the Mill site, northwest of
the mill building. It has a storage capacity of 30,000 gallons;
• the liquefied natural gas (LNG) tank is located due east of the propane tank. It has a
storage capacity of 20,000 gallons;
• three sodium chlorate tanks located east of the SX building (directly north of the
office building). The two tanks east of the SX building are for sodium chlorate
storage and the other tank is for dilution of the sodium chlorate;
• two anhydrous ammonia tanks located east of the SX building, with capacity of
31,409 gallons each;
• three kerosene tanks located east of the SX building, with a capacity of 10,152
gallons each;
• one caustic soda tank north of the SX building, with a capacity of 19,904 gallons; and
• three soda ash tanks which are located east of the SX building. One tank is the dry
soda ash tank with a capacity of 70,256 gallons. Two of the tanks are soda ash
dilution tanks with capacities of 16,921 gallons each.
• diesel fuel and gasoline are stored in tanks located on the eastern side of the ore pad.
The gasoline storage capacity is 6,000 gallons, while diesel storage capacity is 6,000
gallons. In addition, there is a 2,000 gallon mobile diesel storage tank mounted on a
truck which moves about the Mill facility.
Other reagents are stored in steel barrels, supersacs, or plastic totes in a reagent yard located west
of the office building. Typical reagents which are stored in this yard include:
• polymers and flocculants;
• hydrogen peroxide in plastic totes
• boiler feed water chemicals;
• methanol;
• tributyl phosphate;
• "dirty" soda ash and ammonium sulfate;
• "clean" soda ash and ammonium sulfate
• SX amines and emulsion breakers;
• decyl alcohol;
• minimal amounts of acid in barrels;
• sodium chlorate;
• salt; and
• used oil in drums and overpacks .
2.2.10 Boiler Facilities
The main building (approximately 12,400 square feet) is located on the west side of the Mill site
and contains air compressors and water treatment facilities. To the north of the main building is
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a building which houses two LNG-fired boilers. The vanadium oxidation tank, oxidation
thickener, and pH adjustment tank are located south of the boiler house facilities.
a) Electrical
The main electrical panel for the boiler facilities is located outside of the building, on the
south wall.
b) Fire Protection System
The fire protection system for the boiler facilities is comprised of strategically located
portable dry chemical extinguishers.
2.2.11 Sample Plant
The sample plant building (approximately 8,000 square feet) is located on the ore pad, east of the
maintenance shop/warehouse building. The sampling plant equipment has been removed from
the building and it is currently used as a storage area for maintenance.
a) Electrical
The electrical panel for the sample plant building is located on the east wall upstairs.
b) Fire Protection System
The fire protection system for the boiler facilities is comprised of strategically located portable
dry chemical extinguishers.
2.2.12 Tailings Cells
Tailings and wastes generated from processing conventional ores and alternate feed materials are
disposed of permanently in the Mill's lined tailings impoundments. The Mill's tailings system is
comprised of five engineered cells, Cells 1, 2, 3, 4A and 4B. Cell 4A receives the Mill's tailings
sands. Cell 2 is closed. Cell 3 is nearly filled and no longer receives tailings sands or solutions.
Cells 1 and 4B receive solutions only, and are in operation as evaporative ponds. The liquid in
the tailings cells is very acidic. It also contains virtually all of the radionuclides contained in the
ores and alternate feed materials that are processed at the Mill, other than uranium, which is
included in the tailings at approximately 5% of its concentration in the ores and alternate feed
materials.
Solutions in the tailings cells should not be used to fight fires in the Mill facility.
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2.2.13 Stack Heights, Diameters and Typical Flow Rates
Emissions from the Mill process are in the form of air emissions from exhaust stacks and
solid/liquid tailings which are stored in the Mill's tailings cells located west/southwest of the
main Mill building. The major exhaust stack parameters are shown in the following table.
Height
(meters from Diameter Estimated Flow Rate
Description surface) (inches) (cfm)
Leach Exhaust -100 36 13,700
North Yellow Cake -25.3 18 4,000
Dryer Stack
South Yellowcake -25.3 12.75 4,000
Dryer Stack
Yellowcake -25.3 16 4,000
Packaging Stack
Vanadium Scrubber -28 36.5 4100
Vanadium Packaging 18.8 30 4100
There are also smaller exhaust stacks associated with the Laboratory in the Mill Office building
and the boiler exhaust stack.
2.2.14 Main Shut-Off Valves
The main shut-off valves and their locations are indicated on Exhibit 1.
2.3 DESCRIPTION OF AREA NEAR THE SITE
The site and surrounding area are indicated on the White Mesa Mill Location Map included as
Figure 1.
The Mill lies within a region designated as the Canyon Lands section of the Colorado Plateau
physiographic province. Elevations in the region range from approximately 3,000 feet in the
bottom of canyons to over 11,000 feet among the peaks of the Henry, Abajo and La Sal
Mountains. The average elevation for the area, excluding deeper canyons and isolated mountain
peaks is about 5,000 feet. The average elevation at the Mill site is approximately 5,600 feet
above mean sea level.
Although varying somewhat with elevation and terrain, the climate in the vicinity of the Mill can
be considered as semi-arid with normal annual precipitation of about 13.4 inches. Primary land
uses in the region include livestock grazing, wildlife range, recreation, and exploration of
minerals, oil and gas. The area within 5 miles of the Mill site is predominantly range land owned
by residents of Blanding or of the White Mesa Ute community of the Ute Mountain Ute Tribe.
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There are no perennial surface waters on or in the vicinity of the Mill site. Corral Creek, located
east of the site is an intermittent tributary to Recapture Creek. Westwater Creek is an
intermittent tributary of Cottonwood Wash, with its confluence with Cottonwood Wash located
1.5 miles west of the Mill site. Both Recapture Creek and Cottonwood wash are similarly
intermittent. They both drain to the south and are tributaries to the San Juan River
approximately 18 miles south of the Mill Site. The drainage in the vicinity of the Mill is shown
on Figure 4.
The Mill site is near Utah State Highway 191 and can be accessed by a paved access road from
the highway to the Mill facilities. This would be the primary route for access of emergency
equipment and evacuation. A municipal airport is also located approximately 3 miles north of
the Mill site. There are no significant potential impediments to traffic flow in the area, such as
rivers, drawbridges, railroad grade crossings, etc.
The nearest residence to the Mill is approximately 1.2 miles to the north of the Mill, the next is a
residence approximately two miles north of the Mill, followed by the community of White Mesa,
about 3.5 miles to the south. The City of Blanding is located approximately 6 miles to the
northeast. Figure 5 shows these population centers.
The local fire station and police station are located in Blanding, Utah. Blanding also has a
hospital, Blue Mountain Hospital, and medical clinic. St. Mary's hospital in Grand Junction,
Colorado, approximately 3 hours drive by highway, is the nearest trauma center. Specialized
medical attention for radioactive contamination or chemical exposure would be located either in
Salt Lake City at the University of Utah Medical Center (approximately 5 hours drive by
highway), or in Denver, Colorado (approximately 7 hours drive by highway).
There are no facilities close to the Mill site that could present potential protective action
problems. All schools, arenas, stadiums, prisons, nursing homes and hospitals are located in
Blanding, approximately 6 miles north of the Mill site.
There are no sites of potential emergency significance such as liquefied petroleum gas (LPG)
terminals, chemical plants, pipelines, electrical transformers and underground cables in the
vicinity of the Mill, other than Mill site facilities described in detail in Section 2.2 above.
3.0 TYPES OF ACCIDENTS
3.1 DESCRIPTION OF POSTULATED ACCIDENTS
The following is a description of each type of radioactive material accidents or other accident
that could potentially occur at the Mill site that could require an emergency response.
3.1.1 Unloading, Storage of Ammonia
A release of anhydrous ammonia could occur through tank failure, overfilling, and failures of
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piping, loading hoses, hose couplings, and emergency relief valves.
No radiological impacts are foreseen from a release of anhydrous ammonia. However, in the
event of an ammonia tank spill, the material would be expected to evaporate quickly. Release of
the entire contents of one or both of the onsite ammonia tanks during a short period of time could
result in a significant release to the environment (the atmosphere) of a hazardous material that
could require a response by an offsite organization to protect persons offsite. Such a release is
addressed in the Mill's Risk Management Plan, required under Section 112r of the Clean Air
Act, a copy of which plan is attached hereto as Appendix K. The Risk Management Plan
contemplates a worst case scenario of the release of the entire 140,000 pound contents of one of
the anhydrous ammonia tanks over a 10 minute period, which could result in a dangerous cloud
of anhydrous ammonia that could extend 12 miles from the point of origin at the Mill. An
alternate scenario of a release of 500 pounds of ammonia over a one minute period could result
in a dangerous cloud of anhydrous ammonia that extends 0.8 miles from the point of origin.
Therefore, an uncontrolled release of ammonia that could result in the release of 100 or more
pounds of ammonia is classified as a Site Area Emergency. Any other uncontrolled release of
ammonia, other than a minor release, is classified as an Alert. A minor release of ammonia is
classified as an On-Site Emergency. See Section 4 below for a discussion of the significance of
these classifications.
A minor release of ammonia would be any release that is expected to be of a small amount (less
than 7 gallons (36 pounds)) that is not expected to be uncontrolled. Minor releases of ammonia
are not subject to the notification requirements of this Plan; however they are subject to the
procedures for response to an ammonia release outlined in Appendix A.
In addition to the procedures in Appendix A, an uncontrolled release of 100 lbs or more of
anhydrous ammonia would also require that notice be given to the Community Emergency
Coordinator for the local Emergency Planning Committee under the Emergency Response and
Community Right to Know Act (see Section 10 below). The procedures for giving such
notifications are also set out in Appendix A to this Plan.
3.1.2 Ammonia Explosion in a Building
An ammonia-air explosive mixture could be formed inside the Mill and SX buildings if a line
ruptured. Existing controls include emergency powered vent fans, operator presence at all times
for surveillance, and one-half inch piping that minimizes potential release amounts.
Radiological impacts from the explosion would be minimal and most likely contained within the
restricted area, unless the explosion resulted in a fire (see Sections 2.1.6 and 2.1.7 below for the
emergency response procedures to follow in the event of a fire). An ammonia explosion would
be classified as a Site Area Emergency if it involved the uncontrolled release of greater than 100
lbs of anhydrous ammonia, and as an Alert if it involved an uncontrolled release of 36 lbs (7
gallons) to 100 lbs of anhydrous ammonia. Releases of less than 7 gallons are classified as On-
Site Emergencies (see Section 4 for significance of this classification). Any contamination
would be recycled or disposed of, as appropriate.
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The procedure for response to an ammonia explosion is set out in Appendix B.
3.1.3 Unloading/Storage of Propane/Propane Fire or Explosion
A release of propane could occur through tank failure, overfilling, and failures of piping, loading
hoses, hose couplings, and emergency relief valves.
Daily inspections of the propane tank for leaks and integrity are conducted to minimize potential
hazards associated with propane leaks.
No radiological impacts are predicted for a release of propane, unless the release is associated
with a fire. Inhalation of propane is also less a hazard than inhalation of ammonia, and would
not be expected to be a significant threat to the public, although it could pose hazards to workers
in the immediate vicinity of the release. Vapors can cause dizziness or asphyxiation without
wammg.
However, there is a significant risk of fire or explosion in the event that the release was
uncontrolled and the propane was ignited. The potential worst case scenario would involve the
release of 110,000 pounds of propane, resulting in a vapor cloud explosion extending 0.40 miles
from the point of origin. An alternate scenario of a release of 500 pounds of propane could result
in a vapor cloud explosion extending 0.06 miles from the point of origin. These distances were
developed using guidance in EPA 550-8-99-009, EPA Risk Management Program Guidance for
Offsite Consequence Analysis, which is not strictly applicable to the Mill but which provides
reasonable methods for estimating release distances. The propane tank is located approximately
0.5 miles from Highway 191 and the nearest Mill property boundary, so a propane explosion is
unlikely to have direct offsite impacts. However, as a matter of caution, notice is provided to
offsite authorities.
An uncontrolled release of propane that could result in the possibility of an explosion is
classified as an Alert. A minor release of propane (see below) is classified as an On-Site
Emergency. See Section 4 below for a discussion of the significance of these classifications.
A minor release of propane would be any release that is expected to be of a small amount and
that is not expected to be uncontrolled or pose a risk of explosion. Minor releases of propane are
not subject to the notification requirements of this plan; however, they are subject to the
procedures set out in Appendix C.
The procedures for response to a propane release are outlined as Appendix C.
3.1.4 Unloading/Storage of LNG/LNG Fire or Explosion
A release of LNG could occur through tank failure, overfilling, and failures of piping, loading
hoses, hose couplings, and emergency relief valves.
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Daily inspections of the LNG tank for leaks and integrity are conducted to minimize potential
hazards associated with LNG leaks. The LNG storage area is surrounded by a concrete
containment dike.
No radiological impacts are predicted for a release of LNG, unless the release is associated with
a fire. Inhalation of LNG is also less a hazard than inhalation of ammonia, and would not be
expected to be a significant threat to the public, although it will pose hazards to workers in the
immediate vicinity of the release. LNG may cause burns, frostbite and asphyxiation. Vapors can
cause dizziness or asphyxiation without warning.
However, there is a significant risk of fire or explosion in the event of an uncontrolled release
that is ignited. The potential worst case scenario of the release of the tank's full capacity of
20,000 gallons (70,000 pounds) of LNG, resulting in a vapor cloud explosion extending 0.40
miles1 from the point of origin. These distances were developed using methods in EPA 550-8-
99-009. An alternate scenario of a release of 500 pounds of LNG could result in a vapor cloud
explosion extending 0.07 miles from the point of origin. The LNG tank is located approximately
0.5 miles from Highway 191 and the nearest Mill property boundary, so a LNG explosion is
unlikely to have direct offsite impacts. However, as a matter of caution, notice is provided to
offsite authorities.
An uncontrolled release of LNG that could result in the possibility of an explosion is classified as
an Alert. A minor release of LNG (see below) is classified as an On-Site Emergency. See
Section 4 below for a discussion of the significance of these classifications.
Per the guidance in EPA 550-8-99-001, Risk Management Program Guidance for Propane/LNG
Storage Facilities (40 CFR Part 68), which is not strictly applicable to the Mill but which
provides methods for evaluating releases from multiple co-located storage tanks, the LNG and
propane tanks could theoretically considered co-located since the tanks each contain greater than
10,000 and are separated by approximately 100 feet. A combined worst case scenario could
involve releases from both the LNG and propane tanks of 70,000 and 110,000 pounds
respectively. This could theoretically produce a vapor cloud explosion extending to 0.46 miles
which, like the individual tank release and explosion scenarios, is also unlikely to have any direct
offsite impacts. The combined effect of the propane and LNG tanks were calculated using the
Equation C-2 and C-3 in EPA 550-B-99-000
A minor release of LNG would be any release that is expected to be of a small amount including
leaks and spills and that is not expected to be uncontrolled or pose a risk of explosion. Minor
releases of LNG are not subject to the notification requirements of this plan; however, they are
subject to the procedures set out in Appendix C.
The procedures for response to a LNG release are outlined as Appendix C.
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3.1.5 Leach Tank Failure
The rubber lined leach tanks contain the nearly boiling ore/sulfuric acid slurry. Tank failure due
to corrosion and break-out is a possibility. Procedures and practices are in place and functioning
to minimize this possibility. Failure due to loss of structural integrity is also possible. The tanks
are evaluated periodically to determine structural stability and the potential need for replacement.
Radiological impacts are minimal from an occurrence of this type. Any release of material
would be contained in the leach area or would flow to via an above ground path to tailings Cell
1.
Accidents of this type are classified as On-Site Emergencies. See Section 4 for the significance
of this classification.
The procedures for response to a leach tank failure are outlined in Appendix D.
3.1.6 Sulfuric Acid Storage Tank Failure
The Mill's sulfuric acid storage tanks consist of one large above ground tank and one smaller
tank outside the north end of the SX. The tanks can hold up to 1,400,000 and 9,000 gallons
respectively. Tank failure due to corrosion and break out is possible. Failure due to loss of
structural integrity, as well as failures of piping, loading hoses, hose couplings, and emergency
relief valves.
The main sulfuric acid tank spill would flow via an above ground path to tailings Cell 1. The
smaller tank is contained within a concrete impoundment that is directed to the SX sump.
There would be no radiological impacts associated with an accident of this type. Nor would
there be any significant hazards to the environment from off gases from any such release.
However, there would be potential hazards to workers in the close vicinity from contact with
sulfuric acid or inhalation of sulfuric acid vapors, and a release to the surface soils.
The both tanks are equipped with a high level audible alarm which sounds prior to tank
overflows.
Accidents of this type are classified as On-Site Emergencies, because they will not lead to a
significant release to the environment of radioactive or other hazardous material. See Section 3
below for the significance of this classification.
The procedures for response to a sulfuric acid tank failure are outlined in Appendix D.
3.1.7 SX Fire
The possibility of a major fire in the solvent extraction building is remote, as very strict safety
precautions are adhered to. This part of the process is kept isolated and in separate buildings due
to the large quantities of kerosene present. These facilities are equipped with an independent fire
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detection and protection system. In the event of a fire in the solvent extraction building, the fire
suppression system delivers foam to the affected area. The foam is designed to spray for 25
minutes, followed by water at 100 psig and up to 2,000 gpm.
In spite of the safety precautions, a major fire in the solvent extraction building could occur.
NRC staff concluded in NUREG-1140 that a fire in the solvent extraction circuit is the accident
of greatest significance for emergency preparedness for a uranium mill, from the point of view of
potential radiological impacts offsite. However, NRC staff concluded that the calculated dose
from this type of accident is small (0.1 rem or less) because of the very low specific activity of
the uranium and the low volatility of the uranium compounds, which causes a low release
fraction. NRC staff noted that these low release fractions are the reason why no offsite ground
contamination was ever detected due to the historic fires that have occurred at other uranium
mills. In the 1980s, two solvent extraction fires occurred at other uranium Mills. Neither fire
resulted in appreciable release of uranium to the unrestricted environment, and essentially
complete recovery of the uranium was obtained.
As a result, NRC staff concluded in NUREG-1140 that no credible accident would justify
emergency protective actions because radiation doses to the public offsite from an accident
would be below the EPA' s protective action guides. Also, the quantity of uranium inhaled is
below the quantity where chemical toxicity effects are observed. Thus, neither radiation doses
nor chemical toxicity from licensed materials is a concern with respect to the need for prompt
protective actions.
If a major fire were to occur, the radiological environmental effects would be confined within a
few hundred feet of the buildings. Recovery of uranium that would be scattered by the burning
solvent would be accomplished. Uranium-contaminated soil would be processed in the Mill
circuit or disposed of in the Mill's tailings cells, as appropriate. The Mill would be required by
existing regulations to take certain actions. Among these, the Mill would be required by R313-
15-302 to conduct surveys (offsite if appropriate) to determine whether the dose limits for
individual members of the public in R313-15-301 or NRC' s limits on radioactivity in effluents to
unrestricted areas in Appendix B of 10 CFR 20 were exceeded. A major fire would also require
immediate notification of the Director of the U tab Division of Waste Management and Radiation
Control by telephone (R313-15-1202).
Consequently, the impact from such an event at the Mill would be limited to (1) cleanup of
contaminated material, (2) replacement of destroyed Mill components, and (3) a short duration
release of combustion products to the atmosphere.
A major SX fire is classified as an Alert. See Section 4 for the significance of this classification.
The procedures for response to an SX fire are outlined in Appendix E.
3.1.8 Other Fire
A fire could start anywhere in or around Mill facilities as a result of a number of causes, such as
lightning strikes, electrical malfunction, human error etc. However, at the Mill there is an
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increased risk of fire and of severe onsite or offsite consequences in the following areas, due to
the nature of the chemicals stored or used at those areas:
• SX Building (see Section 3.1.6 above);
• Propane Tanks (see Section 3.1.3 above);
• LNG Tank (see Section 3.1.4; and
• Lab or Lab Storage Area.
Fires could start in these areas due to equipment malfunction or human error and the intensity
and consequences of the fire could be severe, although direct radiological hazard from any such
fires would be expected to be relatively low (see Section 3.1.6 for a discussion of the radiological
impacts of an SX fire, which is the type of accident considered to have the highest risk of
radiological impacts at a uranium mill). To the extent that facilities are damaged as a result of
any such fire, there could be secondary radiological hazards, such as fire damage in the
yellowcake product drying, packaging and storage areas that would have to be evaluated.
As discussed in Section 3.1.6 above, an uncontrolled fire in the SX building is classified as an
Alert. All other uncontrolled fires in Mill buildings are classified as On-Site Emergencies. See
Section 3 for a discussion of the significance of these classifications.
Should a fire (other than an SX fire) occur, the procedure outlined in Appendix F for reporting
and responding to fires will be followed (the procedure to be followed for an SX fire is outlined
in Appendix E).
3.1.9 Tornado
Although this is highly unlikely, a tornado could occur at the Mill. A severe tornado could cause
buildings and other structures to collapse, chemical or gas releases, major fires as well as general
panic. The environmental impacts from a tornado could be the transport of tailings solids and
liquids, ores or product from the Mill area into the environment. This dispersed material would
contain some uranium, radium, and thorium. An increase in background radiation could result,
and, if sufficient quantities are detected and isolated, they would be cleaned up. However, NRC
staff has concluded in NUREG-1140 that while tornadoes could release a large amount of
radioactive material, they spread the material so greatly that resulting doses are very small. As a
result, tornadoes are not discussed further in NUREG-1140 and are not considered to be a
significant radiological risk at uranium mills.
However, to the extent that a tornado has caused or is likely to result in an ammonia leak or
propane release, an SX building fire or a breach of the Mill's tailings cells, it would be classified
as a Site Area Emergency or Alert depending on which one of these other accidents resulted
from the tornado. All other tornadoes would be classified as On-Site Emergencies. See Section
3 below for the significance of these classifications.
In the event of a major tornado, the procedures outlined in Appendix G will be followed.
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3.1.10 Major Earthquake
Although this is highly unlikely, an earthquake could occur at the Mill. A severe earthquake
could cause buildings and other structures to collapse, chemical and/or gas releases, major fires
as well as general panic. NRC staff concluded in NUREG-1140 that earthquakes were not
identified as leading to significant releases of radionuclides unless they were followed by a fire.
To the extent that an earthquake has caused or is likely to result in an ammonia leak, LNG or
propane release, an SX building fire or a breach of the Mill's tailings cells, it would be classified
as a Site Area Emergency or Alert, depending on which one of these accidents resulted from the
earthquake. All other major earthquakes would be classified as On-Site Emergencies. See
Section 3 for the significance of these classifications.
In the event of a major earthquake the procedures outlined in Appendix G will be followed.
3.1.11 Tailings Accidents
3.1.11.1 Flood Water Breaching of Retention System
In general, flood water breaching of tailings embankments presents one of the greatest dangers
for the sudden release of tailings solids and impounded water. The tailings cells are designed
with sufficient freeboard (at least three feet) to withstand back-to-back 100-year storm events or
40% of the probable maximum flood (PMF) followed by the 100-year storm event. The flood
design is equivalent to 15 inches of rainfall. In addition, the tailings dikes were designed in
accordance with NRC regulations and allow a sufficient margin of safety even in the event of an
earthquake.
The possibility of floods in Westwater Creek, Corral Creek, or Cottonwood Wash causing
damage to the tailings retention facility is extremely remote. This is due to the approximately
200 foot elevation difference between the streambeds of the creeks and the toe of the tailings
dikes.
Flood water breaching a tailings embankment is classified as an On-Site Emergency, because it
is unlikely that any releases to the environment will leave the Mill property, and in the event that
any contamination were to leave the property, it is unlikely that the release is expected to require
a response by an offsite response organization to protect persons offsite. See Section 4 below for
the significance of this classification.
In the event of a Flood Water Breach of the tailings retention system, to procedures in Appendix
H will be followed.
3.1.11.2 Structural Failure of Tailings Dikes
All tailings dikes have been designed with an ample margin of safety as per NRC regulations.
This has included design calculations showing dike stability even when the dike is saturated with
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moisture during a seismic event, the most severe failure mode. In addition, the tailings discharge
system is checked at least once per shift during operation, or once per day during Mill standby.
NRC staff concluded in NUREG-1140 that tailings pond failures also release a large quantity of
material. However, NRC staff concluded that rapid emergency response is not needed to avoid
doses exceeding protection action guides because dose rates at a spill site are very low. NRC
staff concluded that an appropriate response is to monitor drinking water, especially for radium-
226, to be sure that drinking water standards are met. Gamma ray monitoring of the ground is
also appropriate to determine where the tailings have been deposited. However, NRC staff
concluded that ground contamination presents little immediate hazard to the public because the
gamma dose rates are low. Gamma dose rates in contact with tailings should be less than 0.1
mR/hr. A clean-up of the spilled tailings would be expected, but this could be done effectively
without pre-existing emergency preparedness.
Although the discharge from a dike failure would soon cross the restricted area boundary, the
flow path is over three miles in length before leaving the Mill property. In the event of a dam
failure, large operating equipment will be mobilized to construct temporary earthen dikes or
berms downgradient to the failed dike. In addition, the State of Utah, Division of Waste
Management and Radiation Control Director (the "Director"), MSHA, and State of Utah,
Department of Natural Resources, Division of Dam Safety will be notified. The contamination
from such an event would be cleaned up and returned to the tailings area.
A tailings dam failure is classified as an On-Site Emergency, because it is unlikely that any
releases to the environment will leave the Mill property, and in the event that any contamination
were to leave the property, it is unlikely that the release is expected to require a response by an
offsite response organization to protect persons offsite. See Section 4 for the significance of this
classification.
In the event of a tailings dam failure the procedures outlined in Appendix H will be followed.
3.1.11.3 Seismic Damage to Transport System
In the event of a seismic rupture of a tailings slurry pipeline, the released slurry will be contained
in the tailings cells regardless of the quantity released. The tailings retention system pipe is in
the same drainage basin as the retention system. Any tailings slurry released by a pipe rupture,
no matter what the cause, would flow downhill where it would be impounded inside a tailings
cell.
If a break occurred, the pumping system would be shut off, personnel removed from the
immediate area, and the Executive Secretary notified. The break would be repaired and the
affected area cleaned up in the safest and most expeditious manner. The advice and direction of
the Executive Secretary would be sought and heeded throughout the episode.
A seismic rupture in the tailings slurry pipeline would be classified as an On-Site Emergency.
See Section 3 for the significance of this classification.
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In the event of a rupture in the tailings slurry pipeline the procedures outlined in Appendix H
will be followed.
3.1.12 Terrorist/Bomb Threat
In the event that any person should receive a threat of a bomb, the procedure set out in Appendix
I should be followed.
Because of the unknown nature of the risk, a terrorist/bomb threat is classified as an Alert. See
Section 4 for the significance of this classification.
In the event of a terrorist/bomb threat, the procedures in Appendix I will be followed.
3.1.13 Chemical or Reagent Spills
Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow and dikes and/or curbs are constructed around process and
storage tanks ( excluding the water tank) to confine the material in the event of a tank spill.
However, as an operating facility, it is possible for spills of chemicals or reagents to occur from
time to time. Unless such a spill qualifies as an ammonia release (see Section 3.1.1 above), a
propane release (see Section 3.1.3 above), LNG release (see Section 3.1.4) or a sulfuric acid
release (see Section 3.1.5 above), the spill will be considered a minor spill and will be addressed
and cleaned up in accordance with the Mill's Spill Prevention, Control, and Countermeasures
Plan.
It is unlikely that any such minor spills will impact the environment if cleaned up in accordance
with the Mill's Spill Prevention, Control, and Countermeasures Plan. The entire Mill facility is
graded such that run-off will drain into the Mill's tailings cells.
Any such minor spills are classified as Non-Subject Incidents. See Section 4 for the significance
of this classification.
3.1.14 Transportation Accident on the Mill Property Involving a Spill of
Yellowcake
In the event of a transportation-related accident on the Mill property involving a spill of
yellowcake, immediate containment of the product will be achieved by covering the spill area
with a plastic sheeting or equivalent material to prevent wind and water erosion. If sheeting is
not available, and depending on where the spill occurs, soil from the surrounding area may be
used. Perimeter ditching will be used to contain the spill if it should occur in an area where
runoff could result from precipitation.
All human and vehicular traffic through the spill area will be restricted. The area would be
cordoned off if possible. All persons not participating in the accident response will be restricted
to 50 feet from the accident site. Local law enforcement officers will be notified and may be
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asked to assist in controlling traffic and keeping unauthorized persons out of the spill area.
Covered containers and removal equipment, i.e., large plastic sheeting, radioactive signs, ropes,
hoses, shovels, vacuums, axes, stakes, heavy equipment (front-end loaders, graders, etc.), will be
available to clean up the yellowcake. A Radioactive Material Spill Kit is available and under the
control of the Radiation Department. If conditions warrant, water will be applied to the spilled
yellowcake in a fine spray to assist in dust abatement.
Gloves, protective clothing and any personal clothing contaminated during cleanup operations
will be encased in plastic bags and kept in the plant area for decontamination or disposal.
Any fire at the site will be controlled by local experienced fire fighting personnel wearing
appropriate respiratory protective equipment.
Response team members will have a thorough knowledge in basic first aid and of the physical
hazards in inhalation, ingestion, or absorption of radionuclides. Team members will adequately
protect themselves.
As per R313-15 requirements, the Director will be notified promptly of any accident of this type.
Any minor spills are classified as Non-Subject Incidents. See Section 4 for the significance of
this classification.
3.1.15 Of/site Transportation Accidents
3.1.15.1 Concentrate Sh.ipments
Concentrates will be shipped in sealed 55-gallon drums built to withstand normal handling and
minor accidents. Each drum will contain approximately 900 pounds of yellowcake. A
maximum of 45 drums will be shipped in each closed van. The drums will be sealed and marked
appropriately according to current Department of Transportation regulations, and the trucks will
be properly marked. Because most of the radioactive daughter products of uranium are removed
in the extraction process and radioactive buildup of daughter products is slow, yellowcake has a
very low level of radioactivity and is therefore classified by the Department of Transportation as
a low specific activity material.
The environmental impact of a transportation accident involving release of the product would be
minimal. Yellowcake, having a high density, even in a severe accident in which multiple drums
are breached, would not easily disperse. More than likely, the drums and any released material
would remain within the damaged vehicle or in an area of close proximity of the accident site.
Driver or carrier instructions are given to each driver of each transport leaving the plant site with
a load of yellowcake. These instructions will consist of an explanation of the product,
preliminary precautions at the accident site, whom to notify and what to do in case of fire. A
copy of these instructions is included in the Mill's Transportation Accidents Plan, a copy of
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which is attached as Appendix L to this Plan.
Mill personnel would respond if requested for the initial spill response to handle any yellowcake
transport accident. A procedure for this likelihood is included in the Mill's Transportation
Accidents Plan. EFRI may contract with a carrier or firm properly trained to handle any
yellowcake transport accident.
Offsite accidents involving the transportation of product concentrates are classified as Non-
Subject Incidents. See Section 4 for the significance of this classification.
In the event of an offsite accident involving a spill of yellowcake, the procedures outlined in the
Mill's Transportation Accidents Plan, attached as Appendix L hereto, will be followed.
3.1.15.2 Ore or Alternate Feed MateriaJ Shipments
Ore is shipped in 20 to 25 ton shipments in highway trailers that are covered by tarpaulins. The
truck trailers are labeled according to current Department of Transportation regulations. Because
the ore is typically in the form of large particles and is typically wet (2% to 5% moisture), the
potential for a significant release from an accident involving an ore shipment truck is quite small.
Alternate feed materials can be transported to the Mill in a number of conveyances. Most
typically, alternate feed materials are either shipped in bulk in intermodal containers (either with
or without a secondary containment such as a supersac), or in steel drums (possibly in plastic
overpacs) in the back of a van trailer. Bulk shipments in intermodal containers are labeled
according to current Department of Transportation regulations. For bulk materials, the potential
release from an accident is similar to potential releases from an accident involving conventional
ores, but this may vary depending on the feed material and the manner of conveyance. The
potential release from alternate feed materials that are transported in drums will vary, depending
on the particular alternate feed material, and in some cases could be equal to or exceed the risks
associated with transportation of yellowcake.
In the event of an accident, the transportation company will respond to clean up any spilled
material and ensure that the area is clean. Mill personnel will support the transportation
contractor in cleaning up the affected area and radiological scanning of the impacted area.
Offsite accidents involving the transportation of ores and alternate feed materials are classified as
Non-Subject Incidents. See Section 4 below for the significance of this classification.
3.1.15.3 Reagent Shipments
Reagents are shipped in properly marked trailers and the drivers are trained in hazardous
materials transportation and accident procedures. In the event of an accident, all of the reagent
suppliers' transportation contractors are required to have emergency response contractors to
respond to an accident and a potential spill. Many of the reagents that are used at the Mill are
shipped on a daily basis to other industrial facilities throughout the United States. The potential
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for an accident is minimized due to quick response of the transportation contractor's emergency
response team and the training of many of the country's emergency response services.
Off site accidents involving the transportation of reagents are classified as Non-Subject Incidents.
See Section 3 below for the significance of this classification. However, the State of Utah
Division of Waste Management and Radiation Control (801-536-4250) should be notified within
24 hours of the incident.
3.2 DETECTION OF ACCIDENTS
Mill personnel perform a number of daily and weekly inspections of the Mill facilities. These
are:
• The Mill's Operating Foremen conduct inspections of all facility areas each operating
shift;
• The Mill's Safety Coordinator or designee performs a daily inspection of all facility
areas;
• Mill personnel perform daily, weekly, monthly and quarterly inspection of the Mill's
tailings cells; and
• The RSO or designee performs weekly inspections of all areas of the Mill.
These inspections, particularly the shift and daily inspections provide a means for Mill personnel
to detect and alert the Mill's operating staff of any abnormal operating condition or of any other
danger to safe operations. These inspections, along with the observations of operating personnel
in any impacted area, are the primary means of detecting the accident and alerting the operating
staff for chemical or gas leaks, any fires in areas that do not have fire detection equipment, or
any impairment to the tailings cells.
For areas of the Mill with fire detection equipment, such as the SX Building, the office building
and the Maintenance/Warehouse Building, in addition to the foregoing inspections, the fire
detection equipment would be expected to also provide an early warning of a fire.
Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow.
For terrorist or bomb threats, the threat itself would provide the means of detection of the
incident. Where no threats are given, suspicious activity would be observed during the shift and
daily inspections. In addition, the Mill employs surveillance cameras in a limited number of
areas, which are intended to allow Mill personnel to monitor product storage areas and certain
access points to the facility.
The required responses to any detected accidents are set out m Section 3.1 above and m
Appendices A through I for the various types of accidents.
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4.0 CLASSIFICATION AND NOTIFICATION OF ACCIDENTS
In this Emergency Response Plan, accidents have been classified into four categories as
described below. It should be noted that Reg. Guide 3.67 concludes that fuel cycle and material
facilities, such as the Mill, do not present the same degree of hazard (by orders of magnitude) as
are presented by nuclear power plants. Thus the classification scheme for the Mill, which has
four classes of accidents (Alerts, Site Area Emergencies, On-Site Emergencies and Non-Subject
Incidents), is different from the classification scheme for other nuclear facilities, which have two
classes of accidents (Site Area Emergencies and Alerts).
Reg. Guide 3.67 provides that "[t]he NRC intends that licensees be allowed to have a single
emergency plan that can apply to all licensee needs and regulatory requirements. To this end it
should be understood that a licensee may wish to include in the emergency plan some incidents
that do not fall within the jurisdiction of the NRC. For example, the licensee may wish to
include industrial accidents or fires unrelated to the licensee's work with nuclear materials. The
licensee may include such incidents in the emergency plan."
As a result, this Plan includes On-Site Emergencies, most of which do not involve risks of off site
releases of radiation and are therefore not specifically required by Reg. Guide 3.67 to be
included in an emergency response plan for the Mill, and Non-Subject Incidents, which are
incidents that are addressed by other plans (such as the Mill's Spill Prevention, Control, and
Countermeasures Plan and Transportation Accidents Plan) and that either involve incidents that
could occur on site but that would not involve risks of offsite releases of radionuclides or that
involve offsite accidents, and for these reasons are not required by Reg. Guide 3.67 to be
included in this Plan. These On-Site Emergencies and Non-Subject Incidents are included in this
Plan in order to compile all potential emergencies into one Plan. Although in some cases this
merely involves referencing the type of accident or incident and then referring the reader to
another plan, the purpose is to allow Mill personnel to have a reference source that will allow
them to be able to respond quickly to each type of incident.
4.1 CLASSIFICATION SYSTEM
At the Mill, there are four classes of accidents, Alerts, Site Area Emergencies, On-Site
Emergencies and Non-Subject Incidents, described as follows:
a) Alert
An Alert is defined as an incident that has led or could lead to a release to the environment of
radioactive or other hazardous material, but the release is not expected to require a response by
an offsite response organization to protect persons offsite. An Alert reflects mobilization of the
Mill's emergency response organization, either in a standby mode that will activate some
portions of the Mill's organization or full mobilization, but does not indicate an expectation of
offsite consequences. However, an Alert may require offsite response organizations to respond
to onsite condition such as a fire.
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The following potential accidents are classified as Alerts:
• An uncontrolled release of 36 pounds (7 gallons) or more but less than 100 pounds of
anhydrous ammonia (see Section 3.1.1);
• An ammonia explosion that involves a release of 36 pounds (7 gallons) or more but less
than 100 pounds of anhydrous ammonia (see Section 3.1.2);
• An uncontrolled release of propane that could result in an explosion (see Section 3.1.3);
• An uncontrolled release of LNG methane that could result in an explosion (see Section
3.1.4)
• An uncontrolled combined release of propane and LNG Methane that could result in an
explosion ( see Section 3 .1.4)
• A major fire in the SX building (see Section 3.1.6); and
• A terrorist/bomb threat ( see Section 3 .1.11)
b) Site Area Emergency
A Site Area Emergency is defined as an incident that has led or could lead to a significant release
to the environment of radioactive or other hazardous material and that could require a response
by an offsite organization to protect persons offsite. A Site Area Emergency reflects full
mobilization of the Mill's emergency response organization and may result in requests for off site
organizations to respond to the site.
Although it is unlikely that a Site Area Emergency requiring offsite actions will occur at a fuel
cycle or materials facility such as the Mill, the Mill must nevertheless be able to recognize
potential offsite hazards and make the required notifications in such a manner that offsite
response organizations can take appropriate actions, such as sheltering or evacuating persons in
the affected area.
Accordingly, the following potential accidents have been classified as Site Area Emergencies,
because they could require a response by an off site organization to protect persons offsite:
• An uncontrolled release of 100 lbs or more of anhydrous ammonia (see Section 3.1.1);
and
• An ammonia explosion that involves a release of 100 lbs or more of anhydrous ammonia
(see Section 3.1.2).
c) On-Site Emergency
An On-Site Emergency is defined as an incident that is of a nature that has not led or could not
lead to a significant release to the environment of radioactive or other hazardous material, and
hence does not qualify as an Alert or a Site Area Emergency, but that nevertheless could pose
significant and unusual safety hazards to workers at the site, and is therefore subject to the
procedures under this Plan.
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The following potential accidents are or could be classified as On-Site Emergencies:
• A minor release (less than 36 lbs (7 gallons)) of anhydrous ammonia that is not
uncontrolled (see Section 3.1.1);
• An ammonia explosion in a building, unless this results in a fire in the SX building, an
uncontrolled release of 36 pounds (7 gallons) or more of anhydrous ammonia or an
uncontrolled release of propane that could result in an explosion, in which case the
classifications applicable to those other incidents would apply (see Section 3.1.2);
• A minor release of propane that is not uncontrolled and could not lead to an explosion
(see Section 3.1.3);
• A minor release of LNG methane that is not uncontrolled and could not lead to an
explosion ( see Section 3 .1.4)
• A leach tank failure (see Section 3.1.4);
• A sulfuric acid storage tank failure (see Section 3.1.5);
• A fire (other than a major fire in the SX building) (see Section 3.1.7);
• A tornado, unless this results in a fire in the SX building, an uncontrolled release of
anhydrous ammonia or propane, in which case the classifications applicable to those
other incidents would apply (see Section 3.1.8);
• A major earthquake, unless this results in a fire in the SX building, an uncontrolled
release of anhydrous ammonia or propane, in which case the classifications applicable to
those other incidents would apply (see Section 3.1.9); and
• Tailings Accidents
o A flood water breaching of the tailings retention system ( see Section 3 .1.10.1)
o Structural failure of a tailings dike (see Section 3.1.10.2); and
o Seismic damage to the tailings transportation system (see Section 3.1.10.3).
d) Non-Subject Incidents
A Non-Subject Incident is defined as an incident that involves an accident of a specific nature
that is covered under a different plan and is not subject to this Plan but is listed in this Plan for
informational purposes only.
The following potential incidents are or could be classified as Non-Subject Incidents:
• A chemical or reagent spill ( other than a release of anhydrous ammonia, propane, LNG
methane, or a sulfuric acid leak or spill). These types of spills are covered by the Mill's
Spill Prevention, Control, and Countermeasures Plan;
• A transportation accident on the Mill property involving a spill of yellowcake. These
accidents are covered by the Mill's Spill Prevention, Control, and Countermeasures Plan
(see Section 3.1.13); and
• An offsite transportation accident
o Concentrate shipments. These types of accidents are covered by the Mill's
Transportation Accidents Plan (see Section 3.1.14.1 );
o Ore or alternate feed material shipments (see Section 3.1.14.2); and
o Reagent Shipments (see Section 3.1.14.3).
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4.2 NOTIFICATION AND COORDINATION
4.2.1 Alert
The purpose of declaring an Alert is to ensure that emergency personnel are alerted and at their
emergency duty stations to mitigate the consequences of the accident, that the emergency is
properly assessed, that offsite officials are notified, and that steps can be taken to escalate the
response quickly if necessary.
An Alert, like a Site Area Emergency, differs from an On-Site Emergency or a Non-Subject
Incident in that offsite response authorities are notified, as well as the State of Utah Division of
Waste Management and Radiation Control. This is because there is a potential for off site
consequences.
The actions to be taken in the event of an Alert vary somewhat depending on the incident. The
actions to be taken for each incident described in Section 3.1 above that is classified as an Alert
are set out in the various subsections in Section 3.1 and corresponding Appendices A through I
to this Plan that relate to the specific incidents. The actions set out in the Appendices describe,
to the extent appropriate for each incident, how and by whom the following actions will be taken
with respect to each specific incident:
• Decision to declare an Alert (this has been predetermined by incident);
• Activation of onsite emergency response organization;
• Prompt notification of offsite response authorities that an Alert has been declared
(normally within 15 minutes of declaring an Alert);
• Notification to the State of Utah Division of Waste Management and Radiation Control
immediately after notification of offsite authorities, and in any event within one hour of
the declaration of an Alert;
• Decision to initiate any onsite protective actions;
• Decision to escalate to a Site Area Emergency, if appropriate;
• Decision to request support from offsite organizations; and
• Decision to terminate the emergency or enter recovery mode.
4.2.2 Site Area Emergency
The purpose of declaring a Site Area Emergency is to ensure that offsite officials are informed of
potential or actual offsite consequences, that offsite officials are provided with recommended
actions to protect persons offsite, and that the Mill's response organization is augmented by
additional personnel and equipment.
A Site Area Emergency, like an Alert, differs from an On-Site Emergency or a Non-Subject
Incident in that offsite response authorities are notified, as well as the State of Utah Division of
Waste Management and Radiation Control. This is because there is a potential for offsite
consequences. Unlike an Alert, a Site Area Emergency assumes that offsite emergency response
assistance will be required.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
The Mill has identified only two incidents that should be classified as Site Area Emergencies -
an uncontrolled release of greater than 100 pounds of anhydrous ammonia; and an ammonia
explosion that involves the release of greater than 100 pounds of anhydrous ammonia. The
actions to be taken in the event of such Site Area Emergencies are set out in Section 3 .1.1 above
and in Appendices A and B to this Plan, and describe, to the extent appropriate, how and by
whom the following actions will be taken:
• Decision to declare a Site Area Emergency (this has been predetermined by incident);
• Activation of onsite emergency response organization;
• Prompt notification of offsite response authorities that a Site Area Emergency has been
declared, including recommendation for offsite protective actions (normally within 15
minutes of declaring a Site Area Emergency);
• Notification to the State of Utah Division of Waste Management and Radiation Control
immediately after notification of offsite authorities, not later than one hour after the Mill
has declared a Site Area Emergency;
• Decision on what onsite protective actions to initiate;
• Decision on what offsite protective actions to recommend;
• Decision to request support from offsite organizations; and
• Decision to terminate the emergency or enter recovery mode.
4.3 INFORMATION TO BE COMMUNICATED
Mill personnel will do their best to provide clear, concise information to offsite response
organizations. The communication should avoid technical terms and jargon and should be
stated to prevent an under-or over-evaluation of the seriousness of the incident.
The procedures set out in the Section 3.1 and Appendices A through I describe the key types
of information that will be communicated with respect to facility status, releases of
radioactive or other hazardous materials and recommendations for protective actions to be
implemented by offsite response organizations, where applicable. Such Appendices also
contain the preplanned protective action recommendations the Mill will make to each
appropriate offsite organization for each incident that is classified as an Alert or Site Area
Emergency, including the size of the area where the actions are to be taken. The Appendices
also contain a standard reporting checklist to facilitate timely notifications.
Mill personnel meet annually with the various offsite emergency response providers to
ensure that:
• This Plan contains the most practical and efficient protective actions for each
postulated accident and that such providers understand and agree with the
recommended courses of action; and
• The notifications set out in this Plan are appropriate and the contact information is
current.
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 32 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
5.0 RESPONSIBILITIES
5.1 NORMAL FACILITY ORGANIZATION
The Mill Manager is ultimately responsible for the Mill site. The Mill Manager reports to the
Chief Operating Officer of EFRI. The Chief Operating Officer of EFRI reports to the President
and Chief Executive Officer of EFRI.
The Mill Superintendent, Maintenance Superintendent, Mill Operational Superintendent, Utility
Crew, Administrative Staff and Chief Metallurgist report directly to the Mill Manager.
One or more Mill Foremen report to the Mill Superintendent. The number of Mill Foremen will
depend on Mill activities. In full operations, there are two Mill Foremen. The Shift Foremen
report to the Mill Foremen.
The Radiation Technicians report to the RSO. The Safety Coordinator and his staff report to the
RSO. The RSO reports to the Mill Manager.
The Maintenance Foreman and Electrical Foreman report to the Maintenance Superintendent.
These relationships are indicated on the organization chart included as Figure 6.
The procedures to be followed for the types of possible emergencies that have been identified for
the Mill are set out in Section 3.1 above and more specifically in Appendices A through I. The
individuals who have the authority and responsibility to declare the various types of emergencies
are detailed in Section 3.1 and those Appendices.
5.2 0NSITE EMERGENCY RESPONSE ORGANIZATION
The response crew for each operating shift will normally consist of the following operators under
the direction of the shift foreman. This organization may be changed for individual shifts subject
to the approval of the Safety Coordinator/Fire Chief.
5.2.1 Direction and Coordination
The Incident Commander will be the Mill Manager, or in his absence, the Mill Superintendent,
or in the absence of the Mill Manager and the Mill Superintendent, the Safety Coordinator.
The Incident Commander has the overall responsibility for implementing and directing the
emergency response. The Incident Commander has the following duties and authorities:
• Control of the situation;
• directing activities during the emergency;
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• coordination of staff and off site personnel who may augment the staff;
• communication with parties requesting information about the event;
• reporting to local, State and Federal authorities;
• authority to request support from offsite agencies;
• termination of the emergency; and
• authority to delegate any of the foregoing responsibilities to:
o the Mill Superintendent;
o the Safety Coordinator; or
o such other individual or individuals that the Incident Commander deems
appropriate in the circumstances.
The Incident Commander will stop routine radio usage upon learning of an emergency and set up
the base station in a safe location for directing activities. Radio usage will be limited to the
emergency. The Incident Commander has the responsibility to contact or direct others to contact
EFRI personnel as delineated in Exhibit 2 and outside services as delineated in Exhibit 3.
The Incident Commander has the ultimate responsibility to account for all employees at the Mill,
using the assistance of supervisors and/or any EFRI personnel. The Incident Commander should
not interact with the news media. All contact with news media shall be coordinated through
either the Executive Vice President or President of EFRI.
Shift Foremen are in charge until the Incident Commander arrives and are responsible for all
functions listed above. Shift Foremen have the responsibility to account for all of their people in
addition to any visitors, contractors, etc., in their areas and report to the Incident Commander; or,
in the absence of the Incident Commander, to administer all of the above duties.
5.2.2 Onsite Staff Emergency Assignments
The following individuals, organizational group or groups are assigned to the functional areas of
emergency activity listed below.
During normal working hours while the Mill is in full operation, all of the individuals or their
alternates should be available on site to fulfill their emergency assignments. During evening or
night shifts, or during other times when the Mill is not in full operation, not all of the individuals
listed below will be on site. However, there will always be a Shift Foreman on site.
Blanding is a small town, and most of the individuals listed below live within a short distance of
the Mill. In the event of an emergency during a non-working period, afternoon or night shift,
during a period of limited Mill operations or other situation where there is a reduced staff at the
Mill, the Shift Forman or his supervisors, if on site, will initiate procedures to effect any
necessary evacuations of the site and will contact the required personnel from the list of
assignments below to assemble the team required in order to fill all of the necessary assignments.
Two of the first persons contacted will be the Mill Manager and the Safety Coordinator, who will
ensure that the remainder of the team is assembled in order to carry out the emergency
procedures set out in this Plan for the emergency.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
a) Facility System Operations
The Mill Superintendent, or in his absence a Mill Foreman or the Mill Manager, is responsible
for all operational activities on the property. In this capacity, the Mill Superintendent, Mill
Foreman or Mill Manager can shut down any affected areas within the process and render aid to
the other departments.
The Maintenance Superintendent, or in his absence the Maintenance Foreman or the Mill
Manager, is responsible for all mechanical and instrumentation on the site and has the ability to
gather resources during any declared emergency.
Shift Foremen are in charge until the foregoing personnel arrive and are responsible for all of the
foregoing functions until relieved by one or more of the foregoing individuals.
b) Fire Control
As Fire Chief, the Safety Coordinator has the responsibility to maintain trained fire crews and
operable equipment, mobilize and direct the fire crews and equipment in a fire emergency or one
containing the threat of fire, and to assist in evacuation and rescue or recovery operations. The
Safety Coordinator/Fire Chief makes sure that the team or crew has been established, equipped
and properly trained every six months. The Safety Coordinator/Fire Chief works with the Safety
Department under 30 CFR 56.4330 Firefighting, evacuation, and rescue procedures.
In the absence of the Safety Coordinator, RSO will assume these duties. If the RSO is not
present, those responsibilities fall to the next senior member of the Safety Department.
Scheduled time off at the Mill is worked around the RSO's and Safety Coordinator's time off.
Both individuals will not be given time off work at the same time, thereby ensuring supervised
coverage in the event of an emergency.
During an emergency situation, the RSO will also be present and receive direction from the
Safety Coordinator/Fire Chief as to how to proceed. If the Safety Coordinator is present during
the emergency, the next senior member of the Safety Department will act as the Assistant Fire
Chief to free up the RSO' s time to deal with radiation decontamination or other issues that may
anse.
c) Personnel Evacuation and Accountability
The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with
the emergency, including isolation of utilities and providing technical advice as needed. The
Maintenance Supervisor will be assisted by the Mill Safety Coordinator.
The Laboratory Supervisor has the responsibility to direct and account for all office personnel
(including EFRI personnel and office visitors) in evacuation and in activities to cope with the
emergency. In case of a mill tour, the Supervisor accompanying the tour will be responsible for
evacuation of visitors.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
The Scale house person on shift will be responsible to account for ore truck drivers and reagent
truck drivers.
The Mill's Emergency Evacuation and Shut-Down Procedure are outlined in Appendix J to this
Plan.
d) Search and Rescue Operations
The Safety Coordinator will direct rescue operations and provide the necessary emergency
medical personnel and facilities to cope with the emergency.
e) First Aid
First aid will initially be the responsibility of the Safety Coordinator or a Safety Technician. If
the need for first aid is minimal, there may not be a need to require offsite assistance. However,
if there are any significant injuries, or there is a risk of any significant injuries, the Safety
Coordinator or a Safety Technician will have the responsibility of contacting offsite medical and
ambulance services for assistance.
f) Communications
The Incident Commander will stop routine radio usage upon learning of an emergency and set up
the base station in a safe location for directing activities. Radio usage will be limited to the
emergency. The Incident Commander has the responsibility to contact all outside services.
g) Radiological Survey and Assessment (Onsite and Offsite)
On-site and offsite radiological surveys and assessments will be performed by one or more
Radiation Technician(s) under the direction of the RSO. The RSO may assist in performing any
such surveys.
The surveys and assessments that will be required will depend on the incident. In most cases,
radiological contamination resulting from the Mill would be expected to be limited and restricted
to the Mill site. In some cases, however, radiological contamination could be dispersed offsite.
The RSO will determine what surveys and assessments are required in order to: a) determine to
what extent if any, radiological contamination has or could be dispersed offsite as a result of the
incident; and b) determine what surveys are necessary in the circumstances to assess any onsite
or offsite radiological contamination that may have resulted from the incident. In the absence of
the RSO, the Lead Radiation Technician will make these determinations.
The Mill has established an emergency call sheet that will be used in the event of an emergency
to alert all members of the department, whether on-site and on-duty or not. When an emergency
occurs, the RSO is notified first. If the RSO is not available, the Safety Coordinator is notified.
The on-shift Radiation Technicians notify the off-shift Radiation Technicians. All Radiation
Book #16 Energy Fuels Resources (USA) Inc.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Technicians are required to report to the site to assist in the emergency, unless advised otherwise
by the RSO. This ensures that there will be adequate Radiation Safety Staff available for any
emergency that may arise.
h) Personnel Decontamination
Personnel decontamination will be performed by Mill Radiation Technicians under the direction
of the RSO, or in the absence of the RSO, under the direction of a Radiation Technician, as
needed.
i) Facility Decontamination
Facility decontamination will be performed by Mill operations personnel, maintenance personnel
and/or utility crew personnel under the direction of the Mill Manager, Mill Superintendent or
Maintenance Superintendent, to decontamination standards set by the RSO and monitored by
Radiation Safety Staff.
j) Facility Security and Access Control
The Mill Superintendent, or in his absence a Mill Foreman, has the responsibility of directing
outside emergency personnel and has the responsibility for plant security and will report directly
to the Incident Commander.
k) Request Support from Offsite Agencfes
During an emergency, the Incident Commander and/or the Safety Coordinator/Fire Chief will
coordinate that the crew or team has the available members needed to respond to the emergency.
After the team or crew has responded and is in the process of handling the situation, the Incident
Commander and/or Safety Coordinator/Fire Chief will then coordinate with the Radiation/Safety
Departments to maintain scene safety. Scene safety includes, but is not limited to, crowd
control, outside emergency assistance requests and any decontamination.
l) Post-Event Assessment
A post-event assessment of facility conditions for future operations will be performed by the Mill
Manager, Mill Superintendent and/or Maintenance Superintendent. A post-event assessment of
facilities for occupational safety will be performed by the Safety Coordinator. A post-event
assessment of any on-site or offsite radiological contamination resulting from the incident will be
performed by the Radiation Safety Staff under the direction of the RSO.
m) Recordkeeping
The Safety Coordinator will coordinate all record keeping relating to the incident and will be
responsible for the preparation of an incident report.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
n) Media Contact
The Incident Commander, President and Chief Executive Officer or Executive Vice President of
EFRI shall be the sole media contact in the event of an emergency at the Mill.
5.3 LOCAL 0FFSITE ASSISTANCE TO FACILITY
Under a Letter of Agreement with the San Juan County Emergency Management Office, EFRI
will be assisted in the event of an emergency with all needed equipment and services at the
disposal of San Juan County. Local agencies have also volunteered services in the event of an
emergency. These local agencies are (see Section 5.4 below and Exhibit 1 for contact
information):
a) First Aid and Initial Medical Services
• Blue Mountain Hospital -This facility is located approximately 8 miles north of the
Mill in Blanding, Utah; and
• Blanding Clinic -This facility is located approximately 8 miles north of the Mill in
Blanding, Utah (contained within the hospital grounds).
b) Ambulance and Paramedic Services
• San Juan County Ambulance Service -This facility is located approximately 11 miles
north of the Mill in Blanding, Utah.
c) Fire Department
• Blanding City Fire Department -This agency is located approximately 9 miles north
of the Mill in Blanding, Utah. This agency is a volunteer fire department.
d) Law Enforcement
• Blanding City Police Department -This agency is located approximately 11 miles
north of the Mill in Blanding, Utah; and
• San Juan County Sheriff -This agency is located approximately 30 miles north of the
Mill in Monticello, Utah.
e) Highway Patrol
• Utah Highway Patrol -This agency is located approximately 30 miles north of
Blanding in Monticello, Utah.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
f) Hospitals
• San Juan County Hospital -This facility is located in Monticello, Utah,
approximately 33 miles north of the facility; and
• Blue Mountain Hospital -This facility is located approximately 8 miles north of the
facility in Blanding, Utah.
The Mill has provided all of the foregoing facilities and agencies with Safety Data Sheets
(SDS's) for any potential incident at the Mill. These are updated periodically by the Mill. Also,
each facility has an understanding with EFRI, that EFRI will perform all radiological
assessments and decontaminate any area or equipment that has been contaminated during
emergency activities.
Annual visits with each agency or facility are conducted to update and refresh the various
departments about potential emergencies that may be encountered. These visits are documented
and housed in the Safety Office at the Mill.
Given that Mill personnel will be in attendance at any emergency situation, there is no need to
make any provisions to suspend security or safeguard measures for site access during an
emergency in order to accommodate any of the agencies referred to above.
5.4 COORDINATION WITH PARTICIPATING GOVERNMENT AGENCIES
Below are listed the principal State agency and other government (local, county, State, and
Federal) agencies or organizations having responsibilities for radiological or other hazardous
material emergencies at the Mill:
• State of Utah, DWMRC ................................................... 801-536-4250
• NRC .............................................................. 301-951-0550
• MSHA Field Office--801-524-3450 District Office ........ 303-231-5465
• MSHA, Arlington ............................................................ 800-746-1553
• State Emergency Response Comm .................................. 801-538-3400
• State of Utah, Natural Resources, Dam Safety ................ 801-538-7200
• National Response Center. ............................................... 800-424-8802
• Utah Poison Control Center ............................................. 800-456-7707
• Blanding City Fire Department. ............................. Dial 911 or 678-2313
• Blanding City Police Department ........................ Dial 911 or 678-2916 or 678-2334
• San Juan County Sheriff, Monticello, Utah ................. Dial 911 or 587-2237
• Utah Highway Patrol, Monticello, Utah .................... Dial 911 or 587-2000
Mill personnel meet annually with San Juan County Office of Emergency Management and Fire
Control and City of Blanding Fire Department to review items of mutual interest, including
relevant changes in this Plan. During those meetings Mill personnel discuss the Plan,
notification procedures, and overall response coordination, as necessary.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
6.0 EMERGENCY RESPONSE MEASURES
Reg. Guide 3.67 suggests that specific response measures should be identified for each class of
emergency and related to action levels or criteria that specify when the measures are to be
affected. However, rather than describe specific responses applicable to classes of emergencies,
this Plan describes the specific response measures for each type of accident. Since the number of
different types of accidents that have been postulated for the Mill is relatively small, it was
concluded that this more direct approach is most appropriate for a facility such as the Mill.
There is no need to describe the specific actions and responses for each class of emergency when
the actual specific response measures can be described more directly for each accident.
Section 3.1 and Appendices A through I set out the specific response measures for each
postulated accident.
6.1 ACTIVATION OF EMERGENCY RESPONSE ORGANIZATION
Activation of the Emergency Response Organization for each type of accident is set out in
Section 3.1 and the applicable Appendix A through I.
A contact list is maintained through the Mill Safety Department. All supervisors and key
personnel onsite have a copy of this contact list. The individuals listed are available at all times.
Blanding is a small town, and most of the individuals listed live within a short distance of the
Mill. In the event of an emergency during a non-working period, afternoon or night shift, or
during a period of limited Mill operations or other situation where there is a reduced staff at the
Mill, the Shift Forman or his supervisors, if on site, will initiate procedures. In addition, the
Radiation Safety Department has established an emergency call sheet that will require
notification throughout the department. When an emergency occurs, the Safety Coordinator/Fire
Chief is notified and then the Shift Radiation Technicians notify RSO and off shift Radiation
Technicians. The shift Radiation Technicians will maintain scene security until directed by the
RSO to do otherwise. When the off duty Radiation Technicians arrives, they will report
immediately to the RSO and receive their instructions.
6.2 ASSESSMENT ACTIONS
For each type of emergency, the actions to be taken to determine the extent of the problem and to
decide what corrective actions may be required are set out in Section 3 .1 and the applicable
Appendix A through I. Where appropriate, Section 3.1 and the applicable Appendix describe the
types and methods of onsite and offsite sampling and monitoring that will be done in case of
release of radioactive or other hazardous material. To the extent not specifically addressed in
Section 3.1 or in Appendices A through I, Mill personnel will use procedures contained in
existing Mill Standard Operating Procedures.
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6.3 MITIGATINGACTIONS
The means and equipment provided for mitigating the consequences of each type of accident are
specified in Section 3.1 and Appendices A through I. To the extent applicable, these include the
mitigation of consequences to workers onsite as well as to the public offsite, as well as the
criteria that will be used to decide whether a single process or the entire facility will be shut
down.
The Mill's Emergency Evacuation and Shut Down Procedure is set out in Appendix J.
6.4 PROTECTIVE ACTIONS
The nature of onsite and offsite protective actions, the criteria for implementing those actions,
the areas involved, and the procedures for notification to affected persons are described in
Section 3.1 and Appendices A through I for each type of accident. In order to prevent or
minimize exposure to radiation, radioactive materials, and other hazardous materials, the
procedures specified in Section 3.1 and those Appendices provide for timely relocation of onsite
persons, timely recommendation of offsite actions, effective use of protective equipment and
supplies, and use of appropriate contamination control measures, appropriate for each specified
type of accident. To the extent that any actions and equipment are described generally in Section
3.1 and those Appendices, Mill personnel will take actions and use equipment in accordance with
Mill Standard Operating Procedures.
6.4.1 Onsite Protective Actions
6.4.1.1 Personnel Evacuation and Accountability
For each type of accident, Section 3.1 and Appendices A through I include:
• Criteria for ordering an evacuation;
• The means and time required to notify persons involved;
• Evacuation routes, transportation of personnel;
• Locations of onsite and offsite assembly areas;
• Search and rescue;
• Monitoring of evacuees for contamination and control measures if contamination is
found;
• Criteria for command center and assembly area evacuation and reestablishment at
alternate location;
• Procedures for evacuating and treating injured personnel, including contaminated
personnel; and
• Provisions for determining and maintaining the accountability of assembled and
evacuated personnel.
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6.4.1.2 Use of Protective Equipment and Supplies
Section 3.1 and Appendices A through I specify the required protective equipment and supplies,
to the extent not already covered by Mill Standard Operating Procedures. To the extent that
Section 3.1 and Appendices A through I do not specify protective equipment and supplies, then
protective equipment and supplies normally required or available under existing Mill Standard
Operating Procedures for the required procedure or activity will apply.
In addition to normal supplies of equipment at the Mill, such as respirators, protective clothing
etc., the Mill maintains supplies of specialized equipment in certain locations for use in
emergency situations as follows:
a) Fire Hose
Fire hose cabinets are located at the following sites with a minimum of 300 feet of 2-1/2" hose,
two spanner wrenches, spray nozzles and one hydrant wrench:
• South of SX;
• West of CCD;
• North of mill building;
• East of pulp storage tanks;
• Northwest of Maintenance Shop;
• West of Warehouse; and
• East of office building.
b) Self Contained Breathing Apparatus
Two Self-Contained Breathing Apparatus (SCBA) units are located at each of the following
locations:
• Hose station east of office building;
• Hose Station South of SX;
• North End SX Outside Wall; and
• North end of mill building, outside wall.
c) Spill Clean-up Equipment
Barrels of soda ash are located throughout the Mill to be used in case of a chemical spill. Soda
ash is also stored in bulk if needed. There are also a few drums of absorbent stored near the
laboratory. The laboratory also contains acid spill kits and absorbent materials to be used in case
of a spill.
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d) Fire Fighting PPE
Two complete sets of turnout gear for firefighting and/or emergency extrication are located in the
Fire Hose Station located on the east side of the office building.
e) Maintenance of Emergency Equipment
Fire extinguishers are inspected on an annual basis, as well as the fire pump system. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to
ensure that all of the equipment is in place. (Extinguishers are serviced on an annual basis and
then checked monthly to make sure units are still charged. The SCBA units are also checked
monthly and then pressure tested every five years.)
6.4.1.3 Contamination Control Measures
Because of the nature of potential accidents that can occur at uranium mills, it is unlikely that an
accident would result in a significant risk of overexposure to any workers or members of the
public (see the conclusions of NRC staff in NUREG-1140 discussed in section 3.1.7 above).
Therefore the Mill's existing Standard Operating Procedures are considered adequate for
preventing further spread of radioactive materials and for minimizing radiation exposures from
radioactive materials that could be unshielded or released by abnormal conditions. Section 3.1
and Appendices A through I describe isolation, area access control, and application of criteria for
permitting return to normal use to the extent necessary and not otherwise covered by existing
Standard Operating Procedures for the types of accidents that could occur at the Mill.
6.4.2 Of/site Protective Actions
Section 3.1 and Appendices A through I describe the conditions that would require protective
actions offsite for the various types of accidents, and describe the protective action
recommendations that would be made to offsite authorities, when each recommendation would
be made, and what area offsite would be affected.
6.5 EXPOSURE CONTROL IN RADIOLOGICAL EMERGENCIES
Given the radioactive materials found at the Mill and the types of postulated accidents, it is not
likely that Mill personnel or offsite workers would be exposed to levels of radiation that cannot
be adequately addressed under existing Mill Standard Operating Procedures.
6.5.1 Emergency Radiation Exposure Control Program
6.5.1.1 Radiation Protection Program
During the emergency situation, the Radiation Protection Manual, SOP Book 9, will be the guide
for all decontamination and exposure monitoring.
Book #16 Energy Fuels Resources (USA) Inc.
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Date: May 2019 Title: White Mesa Mill Emergency Response Plan
The RSO will be responsible for the determination of exposures to be allowed during the event
of an emergency situation. This includes the unlikely event of authorizing workers to receive
emergency doses and for permitting onsite volunteers to receive radiation doses in the course of
carrying out lifesaving and other emergency activities.
6.5.1.2 Exposure Guidelines
The onsite exposure guidelines to be used for all postulated accidents, including actions to
control fires, stop releases or protect facilities will be those set out in UAC R313-15 and the
Mill's Radiation Protection Manual. These exposure guidelines will also apply to
• Removing injured persons;
• Undertaking mitigating actions;
• Providing onsite first aid;
• Performing personnel decontamination;
• Providing ambulance service; and
• Providing offsite medical treatment.
6.5.1.3 Monitoring
EFRI will provide all needed instrumentation for determining doses received by individuals
during all emergency situations. EFRI will also provide OSL badge monitoring to those
emergency response individuals during situations that may require extended periods of exposure
to high radiation areas.
In the event of an accident, such as an accident that involved the dispersion of yellowcake, or a
fire in the SX building or elsewhere on the facility that could involve the dispersion of
radioactive materials, breathing zone samples will be taken if practicable in the circumstances.
Emergency personnel who must wear respiratory devices, must have their own devices. EFRI
will not furnish these devices.
Radiation safety personnel will also monitor various areas of the facility occupied by emergency
personnel, to the extent practicable.
Records of dose and dose commitments will be maintained for Mill personnel and off site support
organization's emergency workers involved in the accident.
6.5.1.4 Decontamination of Personnel
Any emergency response equipment that enters the Mill's Restricted Area in response to an
incident will be scanned and decontaminated prior to leaving the site according to the
requirements found in Table 1 of the NRC's Policy and Guidance Directive FC-85-23,
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 44 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted
Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May
1987.
Any personnel leaving the Mill's restricted area, or otherwise exposed to radiation from the
incident, will be scanned and decontaminated in accordance with the procedures set out in the
Mill's Radiation Protection Manual for personnel leaving the Mill's restricted area.
Injured personnel will be evaluated for radiation contamination at the earliest convenience, if
there is a potential for contamination. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
cannot be decontaminated, the clinic/hospital personnel will be notified in advance. Mill
radiation safety personnel will be available to provide health physics support clinic/hospital
personnel.
6.6 MEDICAL TRANSPORTATION
San Juan County Ambulance Service will be used as needed in emergency situations for the
transportation of personnel for off-site medical attention.
Other motor pool vehicles on the property will be utilized as needed in emergency situations
with support as needed from the local Emergency Medical Services.
All transportation vehicles will be surveyed and decontaminated by the Radiation Department at
the Mill. Any emergency response equipment or personnel that enters the Restricted Area in
response to an incident will be scanned and decontaminated prior to leaving the site according to
the requirements found in Table 1 of the NRC's Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted
Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May
1987. If any injured personnel who may also be radiologically contaminated, will be transported
to medical treatment facilities, the inside of the transport vehicle will also be scanned and
decontaminated in accordance with the foregoing Guidance.
Injured personnel will be evaluated for radiation contamination, if there was a potential for
contamination, at the earliest convenience. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
cannot be decontaminated, clinic/hospital personnel will be notified in advance.
6.7 MEDICAL TREATMENT
All medical facilities will be made aware of potential radiological and chemical hazards
associated with the postulated accidents described in Section 3 .1. St. Mary's hospital in Grand
Junction, Colorado, approximately 3 hours drive by highway, is the nearest trauma center.
Specialized medical attention for radioactive contamination or chemical exposure would be
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 45 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
located either in Salt Lake City at the University of Utah Medical Center (approximately 5 hours
drive by highway), or in Denver, Colorado (approximately 7 hours drive by highway).
All facilities are aware that EFRI will take responsibility for the monitoring and potential
decontamination of all facilities contaminated during these emergencies. The Mill will provide
ambulance and hospital personnel with health physics support if needed.
7.0 EMERGENCY RESPONSE EQUIPMENT AND FACILITIES
7.1 COMMAND CENTER
When the evacuation alarm sounds or when personnel are verbally notified by radio or other
means, all personnel will assemble at:
• The parking lot south of the office;
• The Scalehouse;
• East side of Cell 1 ; or
• North of the Mill.
The assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions,
etc. The Incident Commander, Safety Coordinator/Fire Chief or Shift Foreman will specify the
appropriate assembly site.
The Mill does not have a specific communication or assessment center. Key personnel are
equipped with handheld VHF transceivers, which will serve as the primary means of
communication while personnel are assembling to the designated relocation areas and as needed
thereafter to deal with the emergency. The relocation area will serve as the initial assessment
center. Other communications and assessment centers will be set up in the Mill's office
building, Scalehouse, Warehouse or other areas of the Mill that have communication capability,
as needed depending on the nature and location of the emergency.
7.2 COMMUNICATIONS EQUIPMENT
7.2.1 Onsite Communications
Employees will be notified to evacuate the area by activating the evacuation system by breaking
the protective glass over the alarm buttons. The evacuation siren (continuous frequency) will
automatically sound for approximately forty-five seconds, and then automatically shut off,
allowing communications by radio from that point. (See Exhibit 1)
The primary onsite communications will be by radio throughout the course of the emergency and
the subsequent recovery. Onsite communication by radio is the typical day-to-day manner of
communication within the Mill facility, and is performed by individual hand held VHF
transceivers. There is no central relay or similar system that could be disabled in the event of an
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 46 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
emergency. As a result, there is no need to provide for an alternative onsite communication
system or perform operational tests of that communications system.
7.2.2 Offsite Communications
EFRI may communicate with emergency response services using commercial telephone or
cellular telephone services as needed and as appropriate.
7.3 ONSITE MEDICAL FACILITIES
The Mill maintains medical supplies at the site for typical occupational injuries as required by
MSHA.
San Juan County Ambulance Service will be used as needed in emergency situations for the
transportation of personnel for off-site medical attention.
Other motor pool vehicles on the property will be utilized as needed in emergency situations
with support as needed from the local Emergency Medical Services.
Given the types of accidents identified, it is unlikely that any personnel would require
contamination control over and above the controls set out in the Mill's Radiation Protection
Manual, which would be applied to injured personnel. If it is not possible or there is not
sufficient time to decontaminate individuals, then advance notice will be applied to offsite
medical personnel and facilities. In addition, Mill personnel will be available to provide health
physics assistance to such medical personnel if necessary.
7.4 EMERGENCY MONITORING EQUIPMENT
The monitoring equipment used on a day-to-day basis by the Radiation Safety Department will
be available to monitor personnel and perform area monitoring, as well as to assess the release of
radioactive materials to the environment. As discussed in Section 3.1.6 above, none of the
postulated accidents described in Section 3.1 above is expected to release significant quantities
of radionuclides into the environment. The greatest risk of that would be a fire in the solvent
extraction building, but, as NRC concluded in NUREG-1140 the potential for overexposures
offsite would not be significant. Mill personnel will monitor to assess the magnitude and
dispersion of any releases after the fact by use of hand held gamma meters in the areas offsite
that could have been impacted. The existing high volume particulate stations will also provide
some information on the magnitude and dispersion of any such releases.
Onsite area monitoring and personnel scanning will be performed by use of existing monitoring
equipment, which is located in the Radiation Safety Department. This is considered to be as
"non-hazardous" a location as possible at the site, because it is not located particularly close to
any locations that could involve one of the postulated accidents.
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 47 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Mill Safety Staff will use atmosphere testing tubes primarily to detect dangerous levels of
anhydrous ammonia and propane and other chemically toxic materials. If necessary, monitoring
personnel will be equipped with SCBA respiratory protection while performing such monitoring.
8.0 MAINTAINING EMERGENCY PREPAREDNESS CAPABILITY
8.1 WRITTEN EMERGENCY PLAN PROCEDURES
This Plan will be reviewed annually by the RSO and, if required, updated by the ALARA
Committee. The SERP Committee will then validate all substantive changes that are being
requested before such changes will be implemented into a new revision of this Plan.
After final SERP approval, changes will be updated to the Document Control System. The
Document Control supervisor will update this Plan and then amend all current copies of the Plan
to the recipients listed on the Distribution List at the beginning of this document.
8.2 TRAINING
Semi-annual training for the emergency response teams will be conducted. This training will
include, but not be limited to, fire suppression, emergency medical services, evacuation under
hazardous atmosphere conditions, search and rescue, proper PPE usage during each potential
emergency situation and radiological contamination surveying onsite and offsite.
Each member of the emergency response team will be assigned his or her tasks and trained in
detail about those tasks. The Radiation Staff will be trained in the proper decontamination of
personnel, PPE and potentially offsite medical facilities.
All employees onsite will be trained in the use of respiratory protection and on radiological
hazards during their normal monthly safety meetings and as needed during special radiation
training sessions as processes change at the facility.
Even with appropriately trained Mill personnel who will be in attendance at the Mill to
accompany any offsite emergency response personnel, there are periodic orientation tours of the
facility to such personnel.
8.3 DRILLS AND EXERCISES
Quarterly drills, as required by MSHA, and are conducted by the Safety Department to monitor
performance of personnel responding to emergency situations. Each drill is enacted upon one or
more of the potential emergencies contemplated by this Plan. The drill and evacuation activities
are documented by the Mill's Safety Coordinator and maintained within plant files.
Management reviews all drills at quarterly ALARA Committee Meetings.
Because the impacts associated with most types of emergencies that could occur at the Mill are
limited to the Mill site itself, and the risks to the public are very low, off site agencies are not
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 48 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
typically invited to participate in any drills or exercises at the Mill.
8.3.1 Biennial Exercises
Training exercises will be held every two years with the potential offsite emergency responders.
These exercises consist of training and information pertaining to the operational activities at the
time.
8.3.2 Quarterly Communications Checks
Quarterly communication checks with all potential offsite emergency responders will be
performed. The communication checks will be documented and housed in the Safety
Department records. These checks will update any changes to contact information for needed
parties.
Emergency response groups that are required to be contacted are:
• Blanding Police Department;
• Blanding City Fire Department;
• San Juan County Sheriff;
• San Juan County EMS;
• All local medical clinics and or hospitals; and
• Utah Highway Patrol
8.4 CRITIQUES
This Plan is subject to audit by the ALARA audit team (see Section 8.5 below), and the periodic
drills and exercises referred to in Section 8.3 above are subject to review periodically by the
Mill's ALARA Committee. Given the nature of the potential incidents that could occur at the
Mill and the low risk to the public relative to incidents that could occur at other types of
facilities, such as nuclear power reactors, the Mill does not require that a critique be prepared for
each drill and exercise by one or more of the nonparticipating observers, other than the audits
and reviews conducted by the ALARA Audit Committee and the ALARA Committee.
8.5 INDEPENDENT AUDIT
This Plan, including all procedures, trammg act1v1ties, emergency facilities, equipment, and
supplies, and records associated with offsite support agency interface, described therein, is
subject to annual review by the Mill's ALARA audit team. The Mill's ALARA audit team is
comprised of EFRI corporate environmental and safety personnel who do not have direct
responsibilities for implementing the emergency response program, as well as an independent
outside consultant with expertise in environmental and radiation safety matters.
Any recommendations or deficiencies observed by the ALARA audit team will be presented to
the ALARA Committee for consideration typically within approximately 60 days after the audit
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 49 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
has been completed. Decisions by the Mill's ALARA Committee to make any substantive
changes to this Plan will be submitted to the Mill's SERP for implementation. Any changes in
plant layout, process or facilities are included in the types of changes that will be reviewed and
could warrant revision to this Plan.
8.6 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT, INSTRUMENTATION AND
SUPPLIES
Fire extinguishers, as well as the fire pump system, are inspected on an annual basis. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to
ensure that all of the equipment is in place. Extinguishers are serviced on an annual basis and
then checked monthly to make sure units are still charged. The SCBA units are also checked
monthly and then pressure tested every five years.
8.7 LETTERS OF AGREEMENT
Any changes to this Plan that would impact the actions of any offsite response organizations will
be communicated to such organizations. The Mill will review all letters of agreement with
offsite agencies periodically to ensure that they are kept up to date and in force.
9.0 RECORDS AND REPORTS
9.1 RECORDS OF INCIDENTS
A written report will be prepared for all incidents of abnormal operation, equipment failure and
accidents that led to a plant emergency that is classified as an Alert or Site Area Emergency.
The report will include the cause of the incident, personnel and equipment involved, extent of
injury and damage (onsite and offsite) resulting from the incident, all locations of contamination
with the final decontamination survey results, corrective actions taken to terminate the
emergency, and the action taken or planned to prevent a recurrence of the incident. The report
will also include the onsite and offsite support assistance requested and received, as well as any
program changes resulting from the lessons learned from any critique of emergency response
activities.
All such reports unique to a radiological emergency, not covered by existing regulations or
License conditions will be retained until the License is terminated.
The foregoing reports will be prepared under the direction of the Safety Coordinator and/or RSO,
and will be maintained in the Mill's files for inspection.
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 50 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
9.2 RECORDS OF PREPAREDNESS ASSURANCE
Records will be maintained in accordance with all MSHA, State of Utah and ALARA criteria.
These documents will be available on site and housed in the Safety Department for review.
10.0 RECOVERY AND PLANT RESTORATION
The Incident Commander will make the determination as to when the facility has been restored
to safe status. In making this determination, the Incident Commander will:
i) Assess the damage to and the status of the facility's capabilities to control radioactive
materials and hazardous materials. Specifically, the Incident Commander must be
satisfied that all safety-related equipment required for safe occupation and use of the
facility, in those areas to be occupied and used (e.g., radiation monitoring
instruments, respiratory protection equipment, fire-suppression and fire-fighting
equipment, containments, and air filters) have been checked and restored to normal
operations. The Incident Commander will be assisted by the RSO, the Safety
Coordinator and the Maintenance Supervisor or Maintenance Forman in making these
determinations; and
ii) Determine the actions necessary to reduce any ongoing releases of radioactive or
other hazardous material and to prevent further incidents. The Incident Commander
will be assisted by the RSO, the Safety Coordinator and the Maintenance Supervisor
or Maintenance Forman in making these determinations.
The Incident Commander will direct the resources and personnel required in order to accomplish
the tasks to meet any required restoration action. During any planned restoration operations,
personnel exposures to radiation will be maintained within UAC R313-15 limits and as low as is
reasonably achievable.
11.0 COMPLIANCE WITH COMMUNITY RIGHT-TO-KNOW ACT
AND CLEAN AIR ACT
11.1 COMMUNITY RIGHT TO KNOW ACT
Section 11002 and 11004 of the Emergency Response and Community Right to Know Act
("EPCRA") of 1986; 42 U.S.C. 11001 et seq., requires that notice be given to the community
emergency response coordinator for the local emergency planning committee in the event of a
release of an extremely hazardous substance offsite. This requirement does not apply to any
release which results in exposure to persons solely within the sites or sites within which the
facility is located.
The Mill maintains inventories of three extremely hazardous substances: anhydrous ammonia
propane, and methane liquefied natural gas. Mill personnel are required to provide notice to the
community response coordinator for the local emergency planning committee in the event of an
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 51 of 51
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
offsite release of either of those two substances. See Sections 3.1.1, 3.1.2 and 3.1.3 above and
Appendices A, B, Cl and C2.
11.2 CLEAN AIR ACT
When Congress passed the Clean Air Act Amendments of 1990, Section 112r required EPA to
publish regulations and guidance for chemical accident prevention at facilities using substances
that posed the greatest risk of harm from accidental releases. These regulations require facilities
such as the Mill that use, store or otherwise handle a threshold quantity of certain listed regulated
flammable and toxic substances to develop a Risk Management Program.
The Mill uses, stores and handles threshold quantities of three substances listed under the
regulations promulgated under Section 112r of the Clean Air Act: anhydrous ammonia,
propane, and methane liquefied natural gas, and has submitted to EPA a Risk Management
Program for those three substances. A copy of that Risk Management Program is attached as
Appendix K to this Plan.
FIGURES
WYOMING
UTAH
White Mesa Mill
NEW MEXICO
Legend
* Public Land Ownership
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REVISIONS Project: WHITE MESA MILL
Date: By: County: San Juan State: Utah
Location Portions ofT37S R22E S28
Author: areither
FIGURE 1
WHITE MESA MILL
LOCATION MAP
Dale 5/20/2014 Drafted By: areither
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Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
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Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
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REVISIONS Project: WHITE MESA MILL
Dale: By: Coonly: San Juan Sia.le: Utah
Localion: •
Figure S
POPULATION IN THE
PROJECT VICINITY -2010 CENSUS
Author: mheninglon Dale: 9/3/2014 Drafted By: mhenlnglon
FIGURE 6
Mark Chalmers
President,
Chief Executive
Officer
I
Paul Gorason
Chief Operating
Officer
. • -
Terry Slade Logan Shumway
RSO Mill Manager
·-. -· . . . ... --. .
. Leron Atcitty Launa Armstrong . .
Steve Snyder Wade Hancock Environmental Radiation Wayne Palmer
Shawn Begaye Quality Control Warehouse Purchasing Agent Office Mill Engineer Technicians Technicians Safety Supervisor Maintenance Thayne Holt Metallurgical Foreman Administrator Timo Groves Superintendent
Process Engineer Technicians Analytical Lab Mill Foreman Supervisor -I -. ..
Ryan Young I _.
Billy Mendoza
Electrical Foreman Ore Receiving Maintenance rrvrone Blackhorse Foreman Utility Crew Lead Operators Process Operators Analytical
Technicians Supervisor I
Instrument I """ Technicians
Maintenance
Mechanics Equipment
Operators
-Electricians
EXHIBITS
EXHIBIT 1
Main Shut Off Valves
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 4
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
EXHIBIT 1
EXHIBIT 1
MAIN SHUT-OFF VALVES
During an emergency this list should be used along with Site Layout Map (Figure 2) to locate tanks
and valves associated with these tanks.
REAGENT SHUT-OFF VALVE LOCATIONS
Sulfuric Acid
4" Main located south side of acid tank
East acid pump discharge valve
West acid pump discharge valve
3" Main (leach area) located 25 feet west of Derrick screens next to walkway
1-1/2" Main (SX area) located south of Central Control room
On/Off switch on east side of north SX man-door (small acid dry tank north side of SX)
Ammonia
4" Main ( east tank) located on end at bottom
4" Main (west tank) located on end at bottom
2" Valve located on top of tank (east tank)
2" Valve located on top of tank (west tank)
Kerosene
2" Main valve located at bottom of tank (east tank)
2" Main valve located at bottom of tank (north tank)
2" Main valve located at bottom of tank (south tank)
Pump discharge 2" valve
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
EXHIBIT 1
Soda Ash
Salt
Main valve located at bottom of tank ( dry storage)
411 Main valve located at bottom of tank on 30% dilution tank
411 Main valve locate at bottom of tank on dilution tank
3 11 Main valve located at bottom of tank
Caustic Soda
3 11 Main valve located at bottom of tank east and west between supports
Sodium Chlorate
311 Main valve located at bottom of tank (east tank)
3 11 Main valve located at bottom of tank (north tank)
311 Main valve located at bottom of tank (south tank)
Propane
4" Main located 15 feet east of tank
3 11 Main located on pipe off top of tank
3" Main located at bottom of tank (also fill pipe)
LNG
Emergency "Stop" button located on the control cabinet
PLANT UTILITY SHUT-OFF VALVE LOCATIONS
Process Water
Main valve located on west side of water storage tank
Discharge valve off service water pump east
Page 2 of 4
Book#16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 ST AND ARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
EXHIBIT 1
Discharge valve off service water pump west
Mill process water main located east wall by SAG mill
Fire Water
Main valve located west side of water storage tank
Emergency fire pump discharge valve to fire system
Emergency fire pump discharge valve to header west side of pump house
8" Main valve located south of Central Control room for SX and boilers
Potable Water
2" Main (suction) from potable water storage tank
2" Main (discharge) from potable water storage tank
4" Main located at east wall by SAG mill
Page 3 of 4
4" Main located south of Central Control room for SX, Maintenance shop, and offices
Steam
Main discharge valve for Superior boiler located at top of boiler
Main steam valve located south side of boiler house
Plant Air
Main valve located at receiver tank in compressor room at boiler house
Main valve to mill building located south of Central Control room
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 ST AND ARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
EXHIBIT 1
PROCESS SHUT-OFF VALVE LOCATIONS
Pulp Storage
No. 1 valve located on west side of tank
No. 3 valve located on west side of tank
Pre-leach ( old No. 2 pulp storage) valve located on west side of tank
Pre-leach Thickener
Main valve located underneath at center cone
Clarifier
Main valve located underneath at center cone
Main valve located underneath at center cone
CCD Thickeners
Main valve located underneath at center cone of each thickener
Page 4 of 4
EXHIBIT 2
Internal Notifications
Book #16
Rev. No.: R-6.0
Date: May 2019
Energy Fuels Resources (USA) Inc.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
EXHIBIT2
EXHIBIT 2
INTERNAL NOTIFICATIONS
Page 1 of 2
Internal reporting requirements for Incidents, Spills and Significant Events are as follows: (see
Section 3.1 of the Plan and Appendices A through I for more specific internal notification
requirements that may apply to each type of emergency situation):
Report Immediately:
Event Criteria:
Release of toxic or hazardous substances.
Fire, explosions or other accidents.
Government investigations information, requests or enforcement actions.
Private actions or claims (corporations or employees).
Deviations from Corporate policies or government requirements by Management.
Other significant events, which have resulted or could result in:
Death, serious injury or adverse health effect (employees or public).
Property damage exceeding $1,000,000.
Government investigation or enforcement action -limiting operation or penalties
of $100,000 or more.
Significant criminal actions.
Substantial media coverage.
Unscheduled down time of more than 24 hours.
Report at the Beginning of the Next Business Day:
Incident Criteria:
Was reported to a government agency as required by law.
Worker (EFRI or contractor) recordable injury or illness associated with a release.
Community impact -reported or awareness.
Publicity resulted or is anticipated.
Release of 5,000 pounds or more of process material, waste or product.
The local manager in charge is to call Paul Goranson, Mark Chalmers or David Frydenlund.
Paul Goranson (C00) ................................................ 303-389-4168 (office)
307-287--0126 (cell)
Mark Chalmers (President/CEO) ............................... 303-389-4155 (office)
.................................................................................... 303-801-7026 ( cell)
Book#l6 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 ST AND ARD OPERA TING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
EXHIBIT 2
David Frydenlund (Sr. Vice President) ...................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 2 of 2
EXHIBIT 3
Emergency Notification List
Book #16
Rev. No.: R-6.0
Date: May 2019
Energy Fuels Resources (USA) Inc.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
EXHIBIT 3
EXHIBIT3
EMERGENCY NOTIFICATION LIST
Page 1 of 2
ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR:
Give artificial respiration if necessary.
Control bleeding.
Treat for shock.
Immobilize fractures and stabilize for transportation.
Scan the injured person for excessive alpha prior to transporting if time allows.
(If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office).
Perform other first aid as more specifically described in Section 3.1 or Appendices A
through I for the specific types of accidents and resulting injuries
THE INCIDENT COMMANDER OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING
AS NEEDED:
Blanding Clinic ............................ 678-2254 or 678-3434 (930 N. 400 W.)
Blue Mountain Hospital, Blanding ... 678-3993 (802 S. 200 W.)
San Juan Hospital, Monticello ..... 678-2830 or 587-2116 (364 W. 1st N.)
FIRST AID TRAINED -The following personnel should be contacted, if they are on-site, in
the event of an emergency to aid in the event of any injuries to personnel.
Safety Coordinator
AMBULANCE SERVICE
Blanding ....................................... Dial 911
If the Company Ambulance is used, an attendant must ride with the injured in addition to the
driver, except where the injured could normally be transported in a car or pickup.
OTHER EMERGENCY NUMBERS
Fire Department ........................... Dial 911 or 678-2313
County Sheriff .............................. Dial 911 or 587-2237
Highway Patrol ............................ Dial 911 or 587-2000
Blanding Police ............................ Dial 911, 678-2916 or 678-2334
MANAGERS
The Supervisor will notify one of the following of all incidents:
L. Shumway ................................ .435-459-9878
T. Slade ....................................... .435-678-4128 or 435-459-3545
Book #16 Energy Fuels Resources (USA) Inc.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
EXHIBIT 3
G. Palmer ............................. 435-678-4114 or 435-459-9463
W. Palmer ........................... .435-678-2146 or 435-485-0584
A MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING
AGENCIES AS REQUIRED FOR EACH INCIDENT (SEE SECTION 3.1 AND
APPENDICES A THROUGH I):
State of Utah, Division of Radiation Control.. ................. 801-536-4250
MSHA Field Office ........................................... 801-524-3450
MSHA District Office ...................................................... 303-23 l-5465
MSHA, Arlington ............................................................ 800-746-1553
State Emergency Response Comm .................................. 801-538-3400
State of Utah, Natural Resources, Dam Safety ................ 801-538-7200
National Response Center ................................................ 800-424-8802
Utah Poison Control Center ............................................. 800-456-7707
Notification of surrounding communities and or residences will be handled by the appropriate
agencies as required by EPCRA (Emergency Planning and Community Right to Know Act). See
Section 3.1 and Appendices A through I.
APPENDICES
APPENDIX A
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix A
APPENDIX A
EMERGENCY RESPONSE PROCEDURE FOR A RELEASE OF ANHYDROUS
AMMONIA
(See also Section 3.1.1 of' the Emergency Response Plau)
The following steps will be followed for an uncontrolled release of anhydrous ammonia. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which
case some of the steps can be taken simultaneously by different crews. The Incident Commander
has the authority to vary from the steps set out below if he deems it necessary in the circumstances
to protect public health, safety or the environment.
CAUTION: INHALATION OF ANYDROUS AMMONIA CAN CAUSE
INCAPACITATION, SERIOUS INJURY AND DEATH.
1. A release of anhydrous ammonia would most likely occur suddenly. The person who would
first witness the release should immediately contact his or her supervisor who would activate
the evacuation alarm by pressing one of the evacuation buttons.
2. Evacuate all personnel from the Mill site to a location upwind of the spill, and account for all
personnel, including all contractors and visitors at the Mill and all ore, product and reagent
truck drivers, in accordance with the Emergency Evacuation and Shutdown Procedure
described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 5.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety
Administration 2012 Emergency Response Guidebook (the "DOT Guidebook") for
appropriate protective clothing. In that Guidebook, Anhydrous ammonia has an ID No. of
1005 and is covered by Guide No. 125. A copy of Guide 125 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
7. Attend to any injured persons:
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix A
• First Aid trained personnel should be contacted, if they are on-site to aid in the event
of any injuries to personnel.
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance;
give artificial respiration with the aid of a pocket mask equipped with a one-way
valve or other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water
• In case of contact with substance, immediately flush skin or eyes with running water
for at least 20 minutes;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet.
• Keep victim under observation. Effects of contact or inhalation may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• Ensure that medical personnel are aware of the materials involved and take precautions
to protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured person in addition
to the driver, except where the injured person could normally be transported in a car or
pickup.
8. Initiate necessary steps to contain and/or neutralize the release, such as spraying with water
fog, turning off valves, etc.
• See Safety Data Sheet attached to this Appendix; and
• See Exhibit I for a list and locations of main shut-off valves.
9. Guard against possible fires by shutting off electrical circuits, isolating gas lines and
eliminating ignition sources from affected areas.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix A
10. If the incident involves an uncontrolled release of greater than 100 lbs (19 gallons) of
anhydrous ammonia, the incident is classified as a Site Area -Emergency and could pose a
hazard to the public. If the incident involves an uncontrolled release of between 36 lbs (7
gallons) and 100 lbs of anhydrous ammonia, it is classified as an Alert. In either case, notify
the community emergency response coordinator for the local emergency planning committee
as soon as possible (within 15 minutes after declaration of the emergency, if possible) as
follows:
• San Juan County EMS Supervisor 587-3225 (work)
After hours call 911
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of anhydrous ammonia released and provide the Mill's
initial recommendation for offsite protective actions, which are that the offsite response
authorities should follow the recommendations for releases of anhydrous ammonia contained
in the DOT Guidebook. In the DOT Guidebook, Anhydrous ammonia has an ID No. of 1005
and is covered by Guide No. 125. Initial isolation and protective action distances are set out
in Table 1 to the DOT Guidebook. Copies of the relevant portions of the Guidebook are
attached to this Appendix. An uncontrolled release of the contents of one of the anhydrous
ammonia tanks at the Mill would be similar to an uncontrolled release from a rail car or tanker
truck and would be considered to be a "large spill" under Table 1 of the DOT Guidebook. The
foregoing offsite officials should also be advised of the conclusions of the Mill's Risk
Management Plan, attached hereto as Appendix K, as it relates to anhydrous ammonia.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix A
11. If the incident involves an uncontrolled release of greater than 36 lbs (7 gallons) of anhydrous
ammonia, report the release to the State of Utah Division of Waste Management and Radiation
Control (DWMRC) (801-536-4250) immediately after notification of off site authorities, and
in any event within one hour after declaration of the emergency, if possible. This immediate
notification is required because an uncontrolled release of anhydrous ammonia of greater than
36 lbs (7 gallons) and 100 pounds is classified as an Alert and a release of greater than 100
pounds is classified as a Site Area Emergency.
12. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-459-3545
435-459-9463
435-678-2146
13. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediate I y.
Paul Goranson (COO) ...................................... 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303-389-4155 (office)
303.801.7026 (cell)
David Frydenlund (Sr. Vice President) ................... 303-303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
14. Inspect facility for residual concentrations of anhydrous ammonia, paying particular attention
to low points. The Safety Coordinator or their designee will make a determination if it is safe
for personnel to re-enter the facility or any portion of the facility or whether or not any portion
of the facility must remain shut down.
15. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERA TING PROCEDURES Page 5 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix A
16. Notification of Regulatory Agencies:
A member of MiJl management or Corporate management will notify the following regulating
agencies as indicated below:
• Report to MSHA
Any release of anhydrous ammonia at the Mill facility must be reported within 15
minutes to the MSHA-1-800-746-1553.
17. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files, containing the
information set out in Section 9.1 of the Plan.
FIRE OR EXPLOSIO~
• EXTREMELY FLAMMABLE.
• Will be easily ignited by heat, sparks or flames.
• Will form explosive mixtures with air.
• Vapors from liquefied gas are initially heavier than air and spread along ground.
CAUTION: Hydrogen (UN1049), Deuterium (UN1957), Hydrogen, refrigerated liquid (UN1966) and
Methane (UN1971) are lighter than air and will rise. Hydrogen and Deuterium fires are difficult
to detect since they burn with an invisible flame. Use an alternate method of detection (thermal
camera, broom handle, etc.)
• Vapors may travel to source of ignition and flash back.
• Cylinders exposed to fire may vent and release flammable gas through pressure relief devices.
• Containers may explode when heated.
• Ruptured cyllnders may rocket.
CALL EMERGENCY RESPONSE Telephone Number on Shipping Paper first. If Shipping Paper not
available or no answer, refer to appropriate telephone number listed on the inside back cover.
• As an immediate precautionary measure, isolate spill or leak area tor at least 100 meters (330 feet) in all
directions.
• Keep unauthorized personnel away.
Stay upwind.
Many gases are heavier than air and will spread along ground and collect in low or confined areas
(sewers, basements, tanks).
• Keep out of low areas.
• Wear positive pressure self-contained breathing apparatus (SCBA).
• Structural firefighters' protective clothing will only provide limited protection.
• Always wear thermal protective clothing when handling refrigerated/cryogenic liquids.
E ION
Large Spill
• Consider initial downwind evacuation tor at least 800 meters (1/2 mile).
Fire
• It tank, rail car or tank truck is involved in a fire, ISOLATE tor 1600 meters (1 mile) in all directions; also,
consider initial evacuation tor 1600 meters (1 mile) in all directions.
E E
• DO NOT EXTINGUISH A LEAKING GAS FIRE UNLESS LEAK CAN BE STOPPED.
CAUTION: Hydrogen (UN1049), Deuterium (UN1957) and Hydrogen, refrigerated liquid (UN1966)
burn with an invisible flame. Hydrogen and Methane mixture, compressed (UN2034) may burn
with an invisible flame.
Small Fire
• Dry chemical or CO,.
Large Fire
• Water spray or fog.
• Move containers from fire area if you can do it without risk.
Fire involving Tanks
• Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.
• Cool containers with flooding quantities of water until well after fire is out.
• Do not direct water at source of leak or safety devices; icing may occur.
• Withdraw immediately in case of rising sound from venting safety devices or discoloration of tank.
• ALWAYS stay away from tanks engulfed in fire .
• For massive fire, use unmanned hose holders or monitor nozzles; if this is impossible, withdraw from
area and let fire burn.
SPILL • R LEAK
• ELIMINATE all ignition sources (no smoking, flares, sparks or flames in immediate area).
All equipment used when handling the product must be grounded.
• Do not touch or walk through spilled material.
• Stop leak if you can do it without risk.
If possible, turn leaking containers so that gas escapes rather than liquid.
Use water spray to reduce vapors or divert vapor cloud drift. Avoid allowing water runoff to contact spille
material.
• Do not direct water at spill or source of leak.
• Prevent spreading of vapors through sewers, ventilation systems and confined areas.
• Isolate area until gas has dispersed.
CAUTION: When in contact with refrigerated/cryogenic liquids, many materials become brittle and
are likely to break without warning.
FIRSl AID
Move victim to fresh air.
Call 911 or emergency medical service.
Give artificial respiration if victim is not breathing.
• Administer oxygen if breathing is difficult.
• Remove and isolate contaminated clothing and shoes.
Clothing frozen to the skin should be thawed before being removed.
In case of contact with liquefied gas, thaw frosted parts with lukewarm water.
In case of burns, immediately cool affected skin for as long as possible with cold water. Do not remove
clothing if adhering to skin.
• Keep victim warm and quiet.
• Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
• TOXIC; may be fatal if inhaled, ingested or absorbed through skin.
• Vapors are extremely irritating and corrosive.
• Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite.
• Fire will produce irritating, corrosive and/or toxic gases.
• Runoff from fire control may cause pollution.
• Some may burn but none ignite readily.
Vapors from liquefied gas are initially heavier than air and spread along ground.
Some of these materials may react violently with water.
• Cylinders exposed to fire may vent and release toxic and/or corrosive gas through pressure relief
devices.
• Containers may explode when heated.
Ru lured c linders ma rocket.
• CALL EMERGENCY RESPONSE Telephone Number on Shipping Paper llrst.11 Shipping Paper not
available or no answer, refer to appropriate telephone number listed on the inside back cover.
• As an immediate precautionary measure, isolate spill or leak area for at least 100 meters (330 feet) in all
directions.
Keep unauthorized personnel away.
• Slay upwind.
• Many gases are heavier than air and will spread along ground and collect in low or confined areas
(sewers, basements, tanks).
• Keep out of low areas.
• Ventilate closed spaces before entering.
em -~vie CU>l"tUNG
• Wear positive pressure self-contained breathing apparatus (SCBA).
Wear chemical protective clothing that is specifically recommended by the manufacturer. It may provide
little or no thermal protection.
• Structural firefighters' protective clothing provides limited protection in fire situations ONLY; it is not
effective in spill situations where direct contact with the substance is possible.
j"
Splll
• See Table 1 -Initial Isolation and Protective Action Distances for highlighted materials. For non-
highlighted materials, Increase, in the downwind direction, as necessary, the isolation distance shown
under 'PUBLIC SAFETY'.
Fire
• If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all directions; also,
consider initial evacuation for 1600 meters (1 mile) in all directions.
Small Fire
• Dry chemical or CO2•
Large Fire
• Water spray, fog or regular foam.
• Move containers from fire area if you can do it without risk.
• Do not get water inside containers.
• Damaged cylinders should be handled only by specialists.
Fire involving Tanks
• Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.
• Cool containers with flooding quantities of water until well after fire is out.
• Do not direct water at source of leak or safety devices; icing may occur.
• Withdraw immediately in case of rising sound from venting safety devices or discoloration of tank.
• ALWAYS stay away from tanks engulfed in fire.
Fully encapsulating, vapor protective clothing should be worn for spills and leaks with no fire.
Do not touch or walk through spilled material.
Stop leak if you can do ii without risk.
• If possible, turn leaking containers so that gas escapes rather than liquid.
• Prevent entry into waterways, sewers, basements or confined areas.
Do not direct water at spill or source of leak.
• Use water spray to reduce vapors or divert vapor cloud drift. Avoid allowing water runoff to contact spilled
material.
Isolate area until gas has dispersed.
IR
Move victim to fresh air.
• Call 911 or emergency medical service.
• Give artificial respiration if victim is not breathing.
Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give artificial
respiration with the aid of a pocket mask equipped with a one-way valve or other proper
respiratory medical device.
• Administer oxygen if breathing is difficult.
Remove and isolate contaminated clothing and shoes.
In case of contact with liquefied gas, thaw frosted parts with lukewarm water.
In case of contact with substance, immediately flush skin or eyes with running water for at least 20
minutes.
In case of contact with Hydrogen fluoride, anhydrous (UN1052), flush skin and eyes with water for 5
minutes; then, for skin exposures rub on a calcium/gel combination; for eyes flush with a water/calcium
solution for 15 minutes.
• Keep victim warm and quiet.
Keep victim under observation.
Effects of contact or inhalation may be delayed.
• Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
APPENDIXB
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix B
APPENDIXB
EMERGENCY RESPONSE PROCEDURE FOR AN AMMONIA EXPLOSION IN A
BUILDING
(See also Section 3.1.2 of the Emergency Response Plan)
The following steps will be followed in the event of an ammonia explosion in a building. The
steps should be followed in the order set out below, unless more than one crew is mobilized, in
which case some of the steps can be taken simultaneously by different crews. The Incident
Commander has the authority to vary from the steps set out below if he deems it necessary in the
circumstances to protect public health, safety or the environment.
CAUTION: INHALATION OF ANYDROUS AMMONIA CAN CAUSE
INCAPACITATION, SERIOUS INJURY AND DEATH.
1. An ammonia explosion would most likely occur suddenly. The person who would first witness
the explosion should immediately contact his or her supervisor who would activate the
evacuation alarm by pressing one of the evacuation buttons.
2. Evacuate all personnel from the Mill site to a location upwind of the impacted area, and account
for all personnel, including all contractors and visitors at the Mill and all ore, product and
reagent truck drivers, in accordance with the Emergency Evacuation and Shutdown Procedure
described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 5.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety
Administration 2012 Emergency Response Guidebook (the "DOT Guidebook") for
appropriate protective clothing. In that Guidebook, anhydrous ammonia has an ID No. of 1005
and is covered by Guide No. 125. A copy of Guide 125 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped as a result of the explosion; do
this only with properly trained and equipped personnel.
Book#l6 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix B
7. Guard against possible fires by shutting off electrical circuits, isolating gas lines and
eliminating ignition sources from affected areas.
8. In the event of fire, follow procedures set out on Guide No. 125. If the fire is in the SX
Building, follow the procedures in Appendix E in addition to the procedures in this Appendix.
9. Isolate utility lines affected by the fire.
10. Extinguish the fire and post a fire watch for flare-ups.
11 . In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and EFRI
management.
12. Attend to any injured persons:
• First Aid trained personnel should be contacted, if they are on-site to aid in the event
of any injuries to personnel.
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance;
give artificial respiration with the aid of a pocket mask equipped with a one-way
valve or other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water;
• In case of contact with substance, immediately flush skin or eyes with running water
for at least 20 minutes;
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhering to skin;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet;
• Keep victim under observation. Effects of contact or inhalation may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix B
o Ambulance Service, Blanding Dial 911
• Ensure that medical personnel are aware of the materials involved and take precautions
to protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured person in addition
to the driver, except where the injured person could normally be transported in a car or
pickup.
13. Initiate necessary steps to contain and/or neutralize the release of ammonia that caused the
explosion, such as spraying with water fog, turning off valves, etc.
• See Safety Data Sheet attached to this Appendix; and
• See Exhibit 1 for a list and locations of the main shut-off valves.
14. If the incident involves an uncontrolled release of greater than 100 lbs (19 gallons) of
anhydrous ammonia, the incident is classified as a Site Area Emergency and could pose a
hazard to the public. If the incident involves an uncontrolled release of between 36 lbs (7
gallons) and 100 lbs of anhydrous ammonia, it is classified as an Alert. In either case, notify
the community emergency response coordinator for the local emergency planning committee
as soon as possible (within 15 minutes of declaration of the emergency, if possible) as follows:
• San Juan County EMS Supervisor 587-3225 (work)
After hours call 911
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of anhydrous ammonia released and provide the Mill's
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix B
initial recommendation for offsite protective actions, which are that the offsite response
authorities should follow the recommendations for releases of anhydrous ammonia contained
in the DOT Guidebook. In the DOT Guidebook, Anhydrous ammonia has an ID No. of 1005
and is covered by Guide No. 125. Initial isolation and protective action distances are set out
in Table 1 to the DOT Guidebook. Copies of the relevant portions of the Guidebook are
attached to this Appendix. An uncontrolled release of the contents of one of the anhydrous
ammonia tanks at the Mill would be similar to an uncontrolled release from a rail car or tanker
truck and would be considered to be a "large spill" under Table 1 of the DOT Guidebook. The
foregoing off site officials should also be advised of the conclusions of the Mill's Risk
Management Plan, attached hereto as Appendix K, as it relates to anhydrous ammonia.
15. If the incident involves an uncontrolled release of greater than 36 lbs (7 gallons) of anhydrous
ammonia, report the release to the State of Utah Division of Waste Management and Radiation
Control (DWMRC) (801-536-4250) immediately after notification of offsite authorities, and
in any event within one hour after declaration of the emergency, if possible. This immediate
notification is required because an uncontrolled release of anhydrous ammonia of greater than
36 lbs (7 gallons) and 100 pounds is classified as an Alert and a release of greater than 100
pounds is classified as a Site Area Emergency.
16. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146
17. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediately.
Paul Goranson (COO) ....................................... 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303-389-4155 (office)
303.801.7026 (cell)
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix B
18. Inspect facility for residual concentrations of anhydrous ammonia, paying particular attention
to low points. The Safety Coordinator or their designee will make a determination if it is safe
for personnel to re-enter the facility or any portion of the facility or whether or not any portion
of the facility must remain shut down;
19. Inspect facility for damage that may have resulted from a fire or explosion and identify any of
the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or
fails to function; and
o No redundant equipment is available and operable to perform the required
safety function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the
facility or whether or not any portion of the facility must be shut down because it cannot
be operated safely and in accordance with all license or permit conditions, laws and
regulations; and
• Damage to any licensed material or any device, container or equipment containing
licensed material.
20. The Incident Commander or Safety Coordinator will make a determination if it is safe for
personnel to re-enter the facility or any portion of the facility or whether or not any portion of
the facility must remain shut down;
21. The Incident Commander will make the decision to terminate the emergency or enter into
recover mode.
22. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary. The State of Utah, DWMRC (801-
536-4250) must be notified:
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 6 of 6
Date: May 2019 Tit]e: White Mesa Mill Emergency Response Plan
Appendix B
o Immediately if the event involved by-product, source or special nuclear
material possessed by the Mill that may have caused or threatens to cause any
individual to receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or
the release of radioactive material inside or outside of the restricted area that
could cause an individual to receive an intake five times the annual permissible
intake as specified in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event
that prevents immediate protective actions necessary to avoid exposures to
radiation or radioactive materials that could exceed regulatory limits or releases
of licensed material that could exceed regulatory limits (events may include
fires, explosions, toxic gas releases etc.) (see 10 CFR 40.60)
• 24 Hour Report to UDEQ may be necessary
The State of Utah, DWMRC (801-536-4250) must be notified within 24 hours after the
discovery of:
o any of the events listed in 10 CFR 40.60. ; or
o any of the events listed in 10 CFR 20.2202(b ).
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA-1-800-746-
1553.
23. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files. In addition,
Corporate Management will prepare a written report and submit it to the State of Utah
DWMRC within 30 days of the incident. The written report will contain the information
required by 10 CFR 20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
APPENDIXC
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERA TING PROCEDURES Page 1 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix C
APPENDIXC
EMERGENCY RESPONSE PROCEDURE FOR A RELEASE OF PROPANE OR
LIQUEFIED NATURAL GAS (LNG) METHANE
(See also Sections 3.1.3 and 3.1.4 of the Emergency Re ponse Plan)
The following steps will be followed for an uncontrolled release of propane or LNG. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which
case some of the steps can be taken simultaneously by different crews. The Incident Commander
has the authority to vary from the steps set out below if he deems it necessary in the circumstances
to protect public health, safety or the environment.
CAUTION: PROPANE AND LNG IS EXTREMELY FLAMMABLE. RISK OF FIRE OR
EXPLOSION
1. A release of propane or LNG would most likely occur suddenly. The person who would first
witness the release should immediately contact his or her supervisor who would activate the
evacuation alarm by pressing one of the evacuation buttons.
2. Evacuate all personnel from the Mill site to a location upwind of the spill and account for all
personnel, including all contractors and visitors at the Mill and all ore, product and reagent
truck drivers, in accordance with the Emergency Evacuation and Shutdown Procedure
described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 5.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety
Administration 2012 Emergency Response Guidebook (the "DOT Guidebook") for
appropriate protective clothing. In that Guidebook, propane has an ID No. of 1075 and is
covered by Guide No. 115. A copy of Guide 115 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
Book#16 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-6.0 STANDARD OPERATJNG PROCEDURES Page 2 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix C
7. In the event of a spill or leak, follow the procedures set out under the heading "Spill or Leak"
in Guide No. 115.
8. Guard against possible fires by shutting off electrical circuits, isolating gas lines and
eliminating ignition sources from affected areas. See Exhibit 1 for a list and locations of main
shut-off valves.
9. In the event of fire, follow procedures set out under the heading "Fire" in Guide No. 115.
10. Isolate utility lines affected by the fire.
11. Extinguish the fire and post a fire watch for flare-ups.
12. In cases where the fire is not extinguished within thi1ty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and EFRI
management.
13. Attend to any injured persons:
• First Aid trained personnel should be contacted, if they are on-site to aid in the event
of any injuries to personnel:
• Move victim to fresh air;
• Give a1tificial respiration if victim is not breathing;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• Clothing frozen to the skin should be thawed before being removed;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water;
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhering to skin;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix C
• Ensure that medical personnel are aware of the materials involved and take precautions
to protect themselves;
• If the Mill ambulance is used, an attendant must ride with the injured person in addition
to the driver, except where the injured person could normally be transported in a car or
pickup.
14. If the incident involves an uncontrolled release of propane or LNG that could result in an
explosion it is classified as an Alert. As a result, notify the community emergency response
coordinator for the local emergency planning committee as soon as possible (within 15 minutes
after declaration of the emergency, if possible) as follows:
• San Juan County EMS Supervisor 587-3225 (work)
After hours call 911
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of propane released and provide the Mill's initial
recommendation for offsite protective actions, which are that the offsite response authorities
should follow the recommendations for releases of propane or LNG contained in the DOT
Guidebook. In the DOT Guidebook, propane has an ID No. of 1075 and is covered by Guide
No. 115 and LNG has an ID No. of 1972 and is also covered by Guide No. 115. Initial isolation
and evacuation recommendations are set out in Guide No. 115. Copies of the relevant portions
of the DOT Guidebook are attached to this Appendix. An uncontrolled release of the contents
of the Mill 's propane tank or LNG would be similar to an uncontrolled release from a rail car
or tanker truck.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix C
15. If the incident involves an uncontrolled release of propane or LNG that could result in an
explosion report the release to the State of Utah Division of Waste Management and Radiation
Control (DWMRC) (801-536-4250) immediately after notification of off site authorities, and
in any event within one hour after declaration of the emergency, if possible. This immediate
notification is required because an uncontrolled release of propane that could result in an
explosion is classified as an Alert.
16. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
17. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146
18. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediate I y.
Paul Goranson (COO............................. 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303-389-4155 (office)
303-801-7026
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
19. Inspect facility for residual concentrations of propane, paying particular attention to low points.
20. Inspect facility for damage that may have resulted from a fire or explosion and identify any of
the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix C
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or
fails to function; and
o No redundant equipment is available and operable to perform the required
safety function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the
facility or whether or not any portion of the facility must be shut down because it cannot
be operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
21. The Incident Commander or Safety Coordinator will make a determination if it is safe for
personnel to re-enter the facility or any portion of the facility or whether or not any portion of
the facility must remain shut down;
22. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode, or to escalate the emergency to a different category if necessary.
23. Notification of Regulatory Agencies:
A member ofMiJl management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, DWMRC (801-536-4250) must be notified:
o Immediately if the event involved by-product, source or special nuclear
material possessed by the Mill that may have caused or threatens to cause any
individual to receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or
the release of radioactive material inside or outside of the restricted area that
could cause an individual to receive an intake five times the annual permissible
intake as specified in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event
that prevents immediate protective actions necessary to avoid exposures to
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERA TING PROCEDURES Page 6 of 6
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix C
radiation or radioactive materials that could exceed regulatory limits or releases
of licensed material that could exceed regulatory limits ( events may include
fires, explosions, toxic gas releases etc.) (see 10 CFR 40.60);
• 24 Hour Report to UDEQ may be necessary
The State of Utah, DWMRC (801-536-4250) must be notified within 24 hours after the discovery
of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CFR 20.2202(b ).
• Report to MSHA
Any fire or explosion at the Mill facility must be reported within 15 minutes to the MSHA
-1-800-746-1553.
24. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files. In addition,
Corporate Management will prepare a written report and submit it to the State of Utah
DWMRC within 30 days of the incident. The written report will contain the information
required by 10 CFR 20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
APPENDIXD
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix D
APPENDIXD
EMERGENCY RESPONSE PROCEDURE FOR A LEACH TANK FAILURE OR
SULFURIC ACID TANK FAILURE
(See a]so Sections 3.1.4 and 3.1.5 of the Emergency Response Plan)
The following steps will be followed for a leach tank failure or a sulfuric acid tank failure. The
steps should be followed in the order set out below, unless more than one crew is mobilized, in
which case some of the steps can be taken simultaneously by different crews. The Incident
Commander has the authority to vary from the steps set out below if he deems it necessary in the
circumstances to protect public health, safety or the environment.
1. The person who would first witness the tank failure should immediately contact his or her
supervisor who would, as an immediate precautionary measure, isolate the spill or leak area in
all directions for at least 150 feet. All unauthorized personnel will be required to stay out of
this area.
2. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
3. Determine crews that may be required (see Section 5.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
4. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See the Safety Data Sheet for sulfuric acid.
5. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
6. Guard against possible fires by shutting off electrical circuits, isolating gas lines and
eliminating ignition sources from affected areas. See Exhibit 1 for a list and locations of the
main shut-off valves.
7. Attend to any injured persons:
• A First Aid trained personnel should be contacted, if they are on-site to aid in the event
of any injuries to personnel;
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix D
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance;
give artificial respiration with the aid of a pocket mask equipped with a one-way
valve or other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with substance, immediately flush skin or eyes with running water
for at least 20 minutes;
• For minor skin contact, avoid spreading material on unaffected skin;
• Removal of solidified molten material from skin requires medical assistance;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet;
• Effects of exposure (inhalation, ingestion or skin contact) to substance may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• Ensure that medical personnel are aware of the materials involved and take precautions
to protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured in addition to the
driver, except where the injured could normally be transported in a car or pickup.
8. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146 or 435-485-0584
9. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediate! y.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix D
Paul Goranson (COO) ...................................... 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303-389-4155 (office)
303-801-7026 ( cell)
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 3 of 5
10. Initiate necessary steps to contain and/or neutralize the release, in accordance with precautions
set out in the Safety Data Sheet attached to this Appendix.
11. In the case of a release from the sulfuric acid tank, remove any contaminated soil to the Mill's
tailings cells for disposal, in accordance with the precautions set out in the Safety Data Sheet.
12. Inspect facility for damage that may have resulted from a leach tank failure and identify any
of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or
fails to function; and
o No redundant equipment is available and operable to perform the required
safety function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the
facility or whether or not any portion of the facility must be shut down because it cannot
be operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material.
13. The Incident Commander or Safety Coordinator will make a determination if it is safe for
personnel to re-enter the facility or any portion of the facility or whether or not any portion of
the facility must remain shut down.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix D
14. The Incident Commander will make the decision to terminate the emergency or enter into
recover mode.
15. Notification of Regulatory Agencies:
A member of Mill management or Cornorate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary:
The State of Utah, Division of Waste Management and Radiation Control (DWMRC) (801-
536-4250) must be notified:
o Immediately if the event involved by-product, source or special nuclear
material possessed by the Mill that may have caused or threatens to cause any
individual to receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or
the release of radioactive material inside or outside of the restricted area that
could cause an individual to receive an intake five times the annual permissible
intake as specified in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event
that prevents immediate protective actions necessary to avoid exposures to
radiation or radioactive materials that could exceed regulatory limits or releases
of licensed material that could exceed regulatory limits ( events may include
fires, explosions, toxic gas releases etc.) (see 10 CFR 40.60);
• 24 Hour Report to UDEQ may be necessary:
The State of Utah, DWMRC (801-536-4250) must be notified within 24 hours after the
discovery of:
o any of the events listed in 10 CFR 40.60; or
o any of the events listed in 10 CFR 20.2202(b ).
• Report to MSHA
Not reportable to MSHA.
16. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files. In addition,
if notification is required to be submitted to the State under paragraph 15 above, Corporate
Management will prepare a written report and submit it to the State of Utah DWMRC within
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix D
30 days of the incident. The written report will contain the information required by 10 CFR
20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
APPENDIXE
Book #16 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date:May2019 Title: White Mesa Mill Emergency Response Plan
Appendix E
APPENDIXE
EMERGENCY RESPONSE PROCEDURE FOR A FIRE IN THE SOLVENT
EXTRACTION BUILDING
(See also Section 3.1.7 of the Emergency Response Plan)
(See Appendix F fo1· all other fire )
Page 1 of 5
The following steps will be followed for a fire in the SX building. All other fires will be addressed
in Appendix F. The steps should be followed in the order set out below, unless more than one
crew is mobilized, in which case some of the steps can be taken simultaneously by different crews.
The Incident Commander has the authority to vary from the steps set out below if he deems it
necessary in the circumstances to protect public health, safety or the environment.
1. The fire will be reported by the individual who finds the incident by activating the fire paging
system by pressing one of the fire evacuation buttons. When the paging system cycles through,
the fire siren (alternating frequency) will automatically sound for approximately forty-five
seconds then automatically shut off, allowing radio communications to resume.
2. Evacuate all personnel to a direction upwind of the fire and account for all personnel, including
all contractors and visitors at the Mill and all ore, product and reagent truck drivers, in
accordance with the Emergency Evacuation and Shutdown Procedure described in Appendix
J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
4. Mobilize the fire crew. Because of the various chemicals that may be present, fire-crews and
emergency response-crews must not be in the danger zone without self-contained breathing
apparatus and protective clothing.
5. Notify the community emergency response coordinator for the local emergency planning
committee as soon as possible (within 15 minutes after declaration of the emergency, if
possible) as follows:
• San Juan County EMS Supervisor 587-3225 (work)
After hours call 911
Also make the following notifications as soon as possible:
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 5
Date:May2019 Title: White Mesa Mill Emergency Response Plan
Appendix E
• Blanding Police
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
6. Report the fire to and request the assistance of the following Emergency off site centers:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
7. Report the fire to the State of Utah DWMRC (801-536-4250) immediately after notification of
offsite authorities, and in any event within one hour after declaration of the emergency, if
possible. This immediate notification is required because a fire in the SX building is classified
as an Alert.
8. Determine other crews that may be required (see Section 5.2.2 of the Plan for a discussion of
the available crews at the disposal of the Incident Commander)
9. Rescue any victims of the fire; do this only with properly trained and equipped personnel.
10. Isolate utility lines affected by the fire and shut off all valves as appropriate. See Exhibit 1 for
a list and locations of the main shut-off valves.
11. Extinguish the fire and post a fire watch for flare-ups.
12. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and EFRI
management.
13. Attend to any injured persons:
• First Aid trained personnel should be contacted, if they are on-site to aid in the event
of any injuries to personnel;
• Give artificial respiration if necessary;
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 5
Date:May2019 Title: White Mesa Mill Emergency Response Plan
Appendix E
• Control any bleeding;
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhered to skin;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition
to the driver, except where the injured person could normally be transported in a car or
pickup.
14. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
15. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146
16. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediately.
Paul Goranson (COO) ....................................... 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303-389-4155 (office)
303-801-7026 (cell)
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 ST AND ARD OPERA TING PROCEDURES
Date:May2019 Title: White Mesa Mill Emergency Response Plan
Appendix E
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 4 of 5
17. Perform radiation surveys to determine if the fire has caused a dispersion of radioactive
materials and record the results of the surveys. These surveys will be performed in various
areas of the Mill's restricted area as well as outside of the restricted area, particularly in areas
downwind of the fire. In addition, surveys will be taken in the vicinity of the nearest residence
downwind of the fire.
18. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or
fails to function; and
o No redundant equipment is available and operable to perform the required
safety function.
In the event of any such damage, the Incident Commander or EH&S Manager or RSO
will make a determination if it is safe for personnel to re-enter the facility or any portion
of the facility or whether or not any portion of the facility must be shut down because
it cannot be operated safely and in accordance with all license or permit conditions,
laws and regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
19. The Incident Commander or Safety Coordinator will make a determination if it is safe for
personnel to re-enter the facility or any portion of the facility or whether or not a portion of the
facility must remain shut down.
20. The Incident Commander will make the decision to terminate the emergency or enter recovery
mode or to escalate the emergency to a different category if necessary.
21. Notification of Regulatory Agencies:
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERA TING PROCEDURES Page 5 of 5
Date:May2019 Title: White Mesa Mill Emergency Response Plan
Appendix E
A member of Mill management or Co1porate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Waste Management and Radiation Control (DWMRC) (801-
536-4250) must be notified:
o Immediately if the event involved by-product, source or special nuclear
material possessed by the Mill that may have caused or threatens to cause any
individual to receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or
the release of radioactive material inside or outside of the restricted area that
could cause an individual to receive an intake five times the annual permissible
intake as specified in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event
that prevents immediate protective actions necessary to avoid exposures to
radiation or radioactive materials that could exceed regulatory limits or releases
of licensed material that could exceed regulatory limits ( events may include
fires, explosions, toxic gas releases etc.) (see 10 CFR 40.60);
• 24 Hour Report to UDEQ may be necessary
The State of Utah, DWMRC (801-536-4250) must be notified within 24 hours after the
discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CFR 20.2202(b ).
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA -1-800-746-
1553.
22. Any contaminated soil identified off of the Mill property will be cleaned up and disposed of in
the Mill's tailings cells.
23. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files. In addition,
Corporate Management will prepare a written report and submit it to the State of Utah
DWMRC within 30 days of the incident. The written report will contain the information
required by 10 CFR 20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
APPENDIXF
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 ST AND ARD OPERATING PROCEDURES Page 1 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix F
APPENDIXF
EMERGENCY RESPONSE PROCEDURE FOR A FIRE
(See also Section 3.1.7 of the Emergency Response Plan)
(See Appendix E for a fiJ-e in the Solvent Extraction Building)
The following steps will be followed for all fires, other than a fire in the SX building, which is
addressed in Appendix E. The steps should be followed in the order set out below, unless more
than one crew is mobilized, in which case some of the steps can be taken simultaneously by
different crews. The Incident Commander has the authority to vary from the steps set out below
if he deems it necessary in the circumstances to protect public health, safety or the environment.
1. The fire will be reported by the individual who finds the incident by activating the fire paging
system by pressing one of the fire evacuation buttons. When the paging system cycles through,
the fire siren (alternating frequency) will automatically sound for approximately forty-five
seconds then automatically shut off, allowing radio communications to resume.
2. Evacuate all personnel and account for all personnel, including all contractors and visitors at
the Mill and all ore, product and reagent truck drivers, in accordance with the Emergency
Evacuation and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
• Mobilize the fire crew. Because of the various chemicals that may be present, fire-
crews and emergency response-crews must not be in the danger zone without self-
contained breathing apparatus and protective clothing.
4. Determine other crews that may be required (see Section 5.2.2 of the Plan for a discussion of
the available crews at the disposal of the Incident Commander)
5. Rescue any victims of the fire; do this only with properly trained and equipped personnel.
6. Isolate utility lines affected by the fire and shut off all valves as appropriate. See Exhibit 1 for
a list and locations of the main shut-off valves.
7. Extinguish the fire and post a fire watch for flare-ups.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix F
8. If the Incident Commander determines that the fire is not capable of being controlled by the
Mill's Emergency Response crews, then Report the fire to the following Emergency off site
centers:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
9. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and EFRI
management.
10. Attend to any injured persons:
• First Aid trained personnel should be contacted, if they are on-site to aid in the event
of any injuries to personnel;
• Give artificial respiration if necessary;
• Control any bleeding;
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhered to skin;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition
to the driver, except where the injured person could normally be transported in a car or
pickup.
11. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix F
12. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-674-4114 or 435-459-9463
435-678-2146
13. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediate I y.
Paul Goranson (COO) ....................................... 303-389-4168 (office)
307-801-0126 (cell)
Mark Chalmers (President/CEO)...................... 303.389.4155 (office)
303.801.7026 (cell)
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 ( cell)
14. Perform radiation surveys if necessary to determine if the fire has caused a dispersion of
radioactive materials and record the results of the surveys.
15. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or
fails to function; and
o No redundant equipment is available and operable to perform the required
safety function.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix F
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the
facility or whether or not any portion of the facility must be shut down because it cannot
be operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
16. The Incident Commander or Safety Coordinator will make a determination if it is safe for
personnel to re-enter he facility or any portion of the facility or whether or not a portion of the
facility must remain shut down
17. The Incident Commander will make the decision to terminate the emergency or enter recover
mode or to escalate the emergency to a different category if necessary.
18. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Waste Management and Radiation Control (DWMRC) (801-
536-4250) must be notified:
o Immediately if the event involved by-product, source or special nuclear
material possessed by the Mill that may have caused or threatens to cause any
individual to receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or
the release of radioactive material inside or outside of the restricted area that
could cause an individual to receive an intake five times the annual permissible
intake as specified in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event
that prevents immediate protective actions necessary to avoid exposures to
radiation or radioactive materials that could exceed regulatory limits or releases
of licensed material that could exceed regulatory limits (events may include
fires, explosions, toxic gas releases etc.) (see 10 CFR 40.60);
• 24 Hour Report to UDEQ may be necessary
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix F
The State of Utah, DWMRC (801-536-4250) must be notified within 24 hours after the
discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CFR 20.2202(b ).
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA -1-800-746-
1553 if there is an injury that has a reasonable potential to cause death.
19. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files.
In addition, if a report is required to be given to the State of Utah, DWMRC as indicated in
paragraph 19 above, Corporate Management will prepare a written report and submit it to the
State of Utah DWMRC within 30 days of such initial report. The written report will contain
the information required by 10 CFR 20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
APPRNDIXG
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix G
APPENDIXG
EMERGENCY RESPONSE PROCEDURE FOR A TORNADO OR MAJOR
EARTHQUAKE
(See also Sections 3.1.8 and 3.1.9 of the Emergency Response Plan)
Page 1 of 5
The following steps will be followed for a tornado or major earthquake. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some
of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to
protect public health, safety or the environment.
1. In the case of a tornado, seek cover in areas where there is no potential for falling objects.
Such as in a doorway. After the incident has concluded, the emergency evacuation alarm will
be sounded and a head count will then take place. After all employees have been accounted
for, the emergency response activities will begin, such as shutting down valves, flows, etc ...
2. In case of a major earthquake, seek cover in areas where there is no potential for falling objects.
Such as in a doorway. After the incident has concluded, the emergency evacuation alarm will
be sounded and a head count will then take place. After all employees have been accounted
for, the emergency response activities will begin, such as shutting down valves, flows, etc ...
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
4. If the earthquake or tornado has caused one of the other incidents referred to in the Plan, refer
to the specific procedures to be followed for that incident set out in Section 3 .1 of the Plan and
the applicable Appendix A through I.
5. Determine the crews that may be required (see Section 5.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
6. Rescue any victims of the tornado or earthquake; do this only with properly trained and
equipped personnel.
7. Isolate utility lines and turn off any valves etc necessary in order to prevent fires or explosions.
See Exhibit 1 for a list and locations of the main shut-off valves.
8. Attend to any injured persons:
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix G
• First Aid personnel should be contacted, if they are on-site to aid in the event of any
injuries to personnel;
• Give artificial respiration, if necessary;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transp01ting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition
to the driver, except where the injured person could normally be transported in a car or
pickup.
9. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
10. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146 or 435-485-0584
11. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediately.
Paul Goranson (COO) ...................................... 303-389-4168 (office)
307-801-0126 (cell)
Mark Chalmers (President/CEO) .......................... 303.389.4155 (office)
303.801.7026 (cell)
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix G
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 3 of 5
12. Perform radiation surveys to determine if the tornado or earthquake has caused a dispersion of
radioactive materials and record the results of the surveys. In the case of a tornado, those
surveys will be performed in various areas of the Mill's restricted area as well as outside of the
restricted area, particularly in areas along the path of the tornado.
13. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or
fails to function; and
o No redundant equipment is available and operable to perform the required
safety function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the
facility or whether or not any portion of the facility must be shut down because it cannot
be operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
14. The Incident Commander or Safety Coordinator will make a determination if it is safe for
personnel to re-enter he facility or any portion of the facility or whether or not a portion of the
facility must remain shut down.
15. The Site Incident Commander will make the decision to terminate the emergency or enter
recover mode or to escalate the emergency to a different category if necessary.
16. Notification of Regulatory Agencies:
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix G
A member of Mill management or Corporate managemenl will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Waste Management and Radiation Control (DWMRC) (801-
536-4250) must be notified:
o Immediately if the event involved by-product, source or special nuclear
material possessed by the Mill that may have caused or threatens to cause any
individual to receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or
the release of radioactive material inside or outside of the restricted area that
could cause an individual to receive an intake five times the annual permissible
intake as specified in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event
that prevents immediate protective actions necessary to avoid exposures to
radiation or radioactive materials that could exceed regulatory limits or releases
of licensed material that could exceed regulatory limits (events may include
fires, explosions, toxic gas releases etc.) (see 10 CFR 40.60)
• 24 Hour Report to UDEQ may be necessary
The State of Utah, DWMRC (801-536-4250) must be notified within 24 hours after the
discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CFR 20.2202(b ).
• Report to MSHA
Any tornado or major earthquake that resulted in structural damage or potentially life
threatening injuries at the Mill facility must be reported within 15 minutes to the MSHA -
1-800-746-1553.
17. Any contaminated soil identified off of the Mill property will be cleaned up and disposed of in
the Mill's tailings cells.
18. Written Reports
The Safety Coordinator will prepare a written report of the incident for Mill files. In addition, if a
report has been given to the State under paragraph 61 above, Corporate Management will prepare
a written report and submit it to the State of Utah DWMRC within 30 days of the incident. The
Book#l6 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix G
written report will contain the information required by 10 CFR 20.2203(b) and 10 CFR40.60
(c)(2), as applicable.
APPENDIXH
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 2
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix H
APPENDIXH
EMERGENCY RESPONSE PROCEDURE FOR TAILINGS ACCIDENTS
(See also Sections 3.1.10.l, 3.1.10.2 and 3.1.10.3 of the Emergency Response Plan
The following steps will be followed in the event of a tailings accident (flood water breaching,
structural failure of tailings dike or damage to tailings transport system). The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some
of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to
protect public health, safety or the environment.
1. The person who first witnesses the tailings accident should immediately contact his or her
supervisor, who will initiate the procedures set out below.
2. Evacuate personnel from areas around the impacted area as necessary to prevent possible injury
to those personnel. Access to those areas will be limited to authorized personnel.
3. Turn off all feed of tailings or solutions to the tailings cells and to the tailings transport system.
4. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
5. Notification of Mill Management
The Supervisor will notify one of the following if not already alerted and part of the Emergency
Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146 or 435-485-0584
6. To the extent possible, solutions from an impacted tailings cell will be pumped to an un-
impacted tailings cell.
7. Notification of Corporate Management:
Book #16 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 2
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix H
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediately.
Paul Goranson (COO) ....................................... 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303.389.4155 (office)
303-801-7026 (cell)
David Frydenlund (Sr. Vice President) ................... 303-303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
8. In the event of damage to the transport system, the system will be shut down and repaired.
Any spills will be cleaned up and deposited in the tailings cells.
9. In the case of flood water breaching the retention system or structural failure of the tailings
dikes, mobilize large operating equipment to construct temporary earthen dikes or berms
downgradient to the impacted dike, if appropriate in the circumstances.
10. In the case of flood water breaching the retention system or structural failure of the tailings
dikes, report the incident to the State of Utah Division of Waste Management and Radiation
Control (DWMRC) (801-536-4250) within 24 hours of the discovery of the incident.
11. Take other measures and perform remediation work as necessary and in accordance with
advice and instructions of the State of Utah DWMRC.
12. Other reporting
• Report to MSHA
Does not have to be reported.
• Report to State of Utah Department of Natural Resources, Division of Dam Safety
• A written report will be made to the State of Utah DWMRC within 5 days after the
incident.
APPENDIX I
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix I
APPENDIX I
EMERGENCY RESPONSE PROCEDURE FOR A TERRORIST/BOMB THREAT
(See aJso Section 3.1.11 of the Emergency Response Plan)
The following steps will be followed in the event of a terrorist/bomb threat. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some
of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to
protect public health, safety or the environment.
1. The person who would first witness the threat should immediately contact his or her supervisor
who would activate the evacuation alarm by pressing one of the evacuation buttons.
2. Evacuate all personnel from the Mill site, and account for all personnel, including all
contractors and visitors at the Mill and all ore, product and reagent truck drivers, in accordance
with the Emergency Evacuation and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of the Mill Manager and the Mill
Superintendent, the Safety Coordinator. Shift Foremen are in charge and are responsible for
all emergency procedures until the Incident Commander arrives.
4. Since the consequences of the threat are unknown, the incident is considered an Alert. Notify
the community emergency response coordinator for the local emergency planning committee
immediately (within 15 minutes after declaration of the emergency, if possible) as follows:
• San Juan County EMS Supervisor 587-3225 (work)
After hours call 911
Also make the following notifications immediately:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
Book #16 ENERGY FUELS RESOURCES (USA) JNC.
Rev. No.: R-6.0 STANDARD OPERATJNG PROCEDURES Page 2 of 3
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix I
• Blanding Police
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
5. Notify the State of Utah Division of Waste Management and Radiation Control (DWMRC)
(801-536-4250) immediately after notification of off site authorities, and in any event within
one hour after declaration of the emergency, if possible.
6. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• L. Shumway
• T. Slade
• G. Palmer
• W. Palmer
435-459-9878
435-678-4128 or 435-459-3545
435-678-4114 or 435-459-9463
435-678-2146 or 435-485-0584
7. Notification of Corporate Management:
The Incident Commander is to call Paul Goranson, Mark Chalmers or David Frydenlund
immediate I y.
Paul Goranson (COO) ....................................... 303-389-4168 (office)
307-287-0126 (cell)
Mark Chalmers (President/CEO)...................... 303.389.4155 (office)
303.801.7026 (cell)
David Frydenlund (Sr. Vice President) ................... 303-389-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
8. Follow instructions given by offsite emergency response officials.
9. To the extent that the threat or bomb results in any of the incidents, such as fire, release of
anhydrous ammonia etc. described elsewhere in the Plan, follow the specific procedures
applicable to such incidents set out in Section 3.1 of the Plan and in Appendices A through I,
to the extent applicable.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix I
10. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode or to escalate the emergency to a different category if necessary.
APPENDIX J
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 1
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix J
APPENDIXJ
EMERGENCY EVACUATION AND SHUT DOWN PROCEDURE
1. Activate evacuation alarm by pressing one of the evacuation buttons. Evacuate and account
for all personnel.
2. Personnel are to assemble in one of the following areas:
• The parking lot south of the office building;
• The scalehouse;
• The north side of Tailings Cell 1, or
• North of the Mill.
The area will be designated by the Incident Commander or Shift Foreman.
3. Specific Procedure for Operations Personnel
• See specific emergency shutdown procedure for Operations by area under the
relevant Operating Procedure for your area.
o A list of the main shut-off valves and their locations is set out in Exhibit 1 to
the Plan.
• All employees not mentioned under Operating Procedures are to immediately report
to the assembly area and congregate by crew so that all persons can be accounted for.
As employees leave their work areas, they must pass the word to evacuate to any
persons who may not be aware of the emergency.
• After the Mill has been determined to be safe for re-entry, employees will be verbally
notified to return to their work stations.
APPENDIX K
(.f"\ EPA FACILITY ID:
,_:~ 1000001157 42 White Mesa Uranium Mill Resubmission
Section 1. Registration Information
Reason for Resubmission 5-vear uodate (40 CFR 68.190(b)(1 ))
1.1 Source Identification
1.1.a. Facilitv Name White Mesa Uranium Mill
1.1.b. Parent Company #1 Name Enen:iv Fuels Resources (USA) Inc
1.1.c. Parent Comoanv #2 Name
1.2 EPA Facility Identifier 100000115742
1.3 Other EPA Systems Facility Identifier
1.4 Dun and Bradstreet Numbers (DUNS)
1.4.a. Facilitv DUNS 082658865
1.4.b. Parent Comoany #1 DUNS
1.4.c. Parent Company #2 DUNS
1.5 Facility Location
1.5.a. Street -Line 1 6425 S. HWY 191
1.5.b. Street -Line 2
1.5.c. Citv Blandinq
1.5.d. State UT
1.5.e. Zip Code -Zip +4 Code 84115
1.5.f. County SAN JUAN
1.5.a. Facility Latitude (in decimal dearees) 37.570833
1.5.h. Facilitv Lonaitude (in decimal degrees -109.478056
1.5.i. Method for determinina Lat/Lona Public Land Survev -Section
1.5.j. Description of location identified by Administrative Building
Lat/Lona
1.5.k. Horizontal Accuracy Measure (meters) 1
1.5.1. Horizontal Reference Datum Code North American Datum of 1983
1.5.m. Source Map Scale Number
1.6 Owner or Operator
1.6.a. Name Enerav Fuels Resources (USA) Inc.
1.6.b. Phone [phone]
1.6.c. Street -Line 1 225 Union Boulevard Suite 600
1.6.d. Street -Line 2
1.6.e. City Lakewood
1.6.f. State co
1.6.a. Zip Code -Zip +4 Code 80228
Foreign Country
Foreian State/Province
Foreian Zip/Postal Code
1.7 Name, title and email address of person or position responsible for RMP (part 68)
implementation
1.7.a. Name of person Kathv Weinel
1.7.b. Title of oerson or position Quality Assurance Manaqer
1.7.c. Email address of person or position [e-mail]
RMP*eSubmit KATHY.WEINEL
08/05/2019
11 :45:28
Page 1
, ·~ G J EPA FACILITY ID:
100000115742 White Mesa Uranium Mill
Section 1. Registration Information
1.8 Emergency Contact
1.8.a. Name
1.8.b. Title of person or position
1.8.c. Phone
1.8.d. 24-Hour Phone
1.8.e. 24-Hour Phone Extension/PIN #
1.8.f. Email address for emeraencv contact
1.9 Other Points of Contact
1.9.a. Facility or Parent Company E-mail
Address
1.9.b. Facilitv Public Contact Phone Number
1.9.c. Facility or Parent Company WWW
Homeoaae Address
1.10 Local Emergency Planning Committee
(LEPC)
1.11 Number of fulltime equivalent (FTEs)
emolovees on site
1.12 Covered bv
1.12.a. OSHA PSM
1.12.b. EPCRA section 302
1.12.c. CAA Title V Air Operating Permit
Proaram
1.12.d. Air Ooeratina Permit ID #
1.13 OSHA Star or Merit Rankina
1.14 Last Safety Inspection (by an External
Agency) Date
1.15 Last Safety Inspection Performed by an
External Agency
1.16 Will this RMP involve Predictive Filina?
1.18 RMP Preparer Information
1.18.a. Name
1.18.b. Phone
1.18.c. Street -Line 1
1.18.d. Street -Line 2
1.18.e. Citv
1.18.f. State
1.18.a. ZiD
Foreian Countrv
Foreign State/Province
Foreian ZiD Code
RMP*eSubmit KATHY.WEINEL
Resubmission
Terrv Slade
RSO
[phone]
[phone]
NA
[e-mail]
[e-mail]
[phone]
NA
San Juan County LEPC
50
y
AN112050020-19
07/18/2019
MSHA
Kathv Weinel
[phone]
225 Union Boulevard Suite 600
Lakewood
co
80228
08/05/2019
11:45:28
Page 2
(,...D.\ EPA FACILITY ID: m: 1 White Mesa Uranium Mill -~ 100000115742
Section 1. Registration Information
Section 1.17 Process Specific Information
Process 1
Process ID# 1000102104
Process Description Uranium Extraction
1.17.a. Program Level 2
1.17.b. NAICS Code(s)
21229 (Other Metal Ore Mininq)
1.17.c. Chemical(s)
I Chemical Name I CAS Number
I Ammonia (anhydrous) I 7664-41-7
RMP*eSubmit KATHY.WEINEL
Resubmission
I Quantity
I 280000
08/05/2019
11 :45:28
Page 3
EPA FACILITY ID:
100000115742 White Mesa Uranium Mill
Section 2. Toxics: Worst Case
Scenario 1
Process Name
2.1 Chemical
2.1.a. Name
2.1.b. Percent Weight of Chemical
2.2 Phvsical State
2.3 Model Used
2.4 Scenario
2.5 Quantitv Released (lbs)
2.6 Release Rate (lbs/min)
2.7 Release Duration (minsl
2.8 Wind Speed (meters/sec)
2.9 Atmospheric stability class
2.10 Topoaraphv
2.11 Distance to endpoint (miles)
2.12 Estimated residential population within
distance to endpoint (numbers)
2.13 Public receptors within distance to endpoint
2.13.a. Schools
2.13.b. Residences
2.13.c. Hospitals
2.13.d. Prison/Correctional Facilities
2.13.e. Recreational Areas
2.13.f. Major commercial, office or industrial
areas
2.13.a. Other
Resubmission
Uranium Extraction
Ammonia (anhydrous)
Gas liauified by pressure
EPA's RMP*Comp(TM)
Liauid soill and vaoorization
140000
14000
10
1.5
F
Rural
6.9
4500
y
y
y
y
y
2.14 Environmental receptors within distance to endpoint
2.14.a. National or State Parks, Forests or
Monuments
2.14.b. Officially Designated Wildlife
Sanctuaries Preserves or Refuges
2.14.c. Federal Wilderness Area
2.14.d. Other
2.15 Passive mitiaation considered
2.15.a. Dikes y
2.15.b. Enclosures
2.15.c. Berms y
2.15.d. Drains
2.15.e. Sumps
2.15.f. Other
2.16 Graphic file
RMP*eSubmit KATHY.WEINEL
08/05/2019
11 :45:28
Page 4
EPA FACILITY ID:
100000115742 White Mesa Uranium Mill
Section 3. Toxics: Alternative Release
Scenario 1
Process Name
3.1 Chemical
3.1.a. Name
3.1.b. Percent Weight of Chemical
3.2 Phvsical State
3.3 Model Used
3.4 Scenario
3.5 Quantitv Released (lbs)
3.6 Release Rate (lbs/min)
3.7 Release Duration (mins)
3.8 Wind Speed (meters/sec)
3.9 Atmospheric stability class
3.1 O Topoaraphv
3.11 Distance to endpoint (miles)
3.12 Estimated residential population within
distance to endpoint (numbers)
3.13 Public receptors within distance to endpoint
3.13.a. Schools
3.13.b. Residences
3.13.c. Hospitals
3.13.d. Prison/Correctional Facilities
3.13.e. Recreational Areas
3.13.f. Major commercial, office or industrial
areas
3.13.a. Other
3.14 Environmental receptors within distance to endpoint
3.14.a. National or State Parks, Forests or
Monuments
3.14.b. Officially Designated Wildlife
Sanctuaries. Preserves or Refuaes
3.14.c. Federal Wilderness Area
3.14.d. Other
3.15 Passive mitiaation considered
3.15.a. Dikes
3.15.b. Enclosures
3.15.c. Berms
3.15.d. Drains
3.15.e. Sumps
3.15.f. Other
3.16 Active mitigation considered
3.16.a. Sprinkler svstems
3.16.b. Deluge svstems
3.16.c. Water curtain
3.16.d. Neutralization
3.16.e. Excess flow valve
RMP*eSubmit KATHY.WEINEL
Resubmission
Uranium Extraction
Ammonia (anhydrous)
Gas liauified by oressure
EPA's RMP*Como(TM)
Transfer hose failure
500
500
1
3
D
Rural
0.4
0
y
y
y
y
y
08/05/2019
11 :45:28
Page 5
EPA FACILITY ID:
100000115742 White Mesa Uranium Mill
Section 3. Toxics: Alternative Release
3.16.f. Flares
3.16.g. Scrubbers
3.16.h. Emeraencv shutdown svstems
3.16.i. Other
3.17 Graohic file
RMP*eSubmit KATHY.WEINEL
Resubmission 08/05/2019
11:45:28
Page 6
EPA FACILITY ID:
100000115742 White Mesa Uranium Mill Resubmission
Section 8. Prevention Program: Program Level 2
Program 1
Prevention Program Description:
Uranium Extraction
8.1 NAICS Code for process
8.1.a. Process Name 1000102104 (Uranium Extraction)
8.1.b. NAICS 21229 (Other Metal Ore Minina)
8.2 Chemicals
Ammonia (anhvdrous)
8.3 Safetv Information
8.3.a. Date on which the safety information 05/21/2019
was last reviewed or revised
8.3.b. Federal/State regulations or industry-specific design codes and standards used to
demonstrate compliance with safetv information recrnirement
8.3.b.1. NFPA 58 (or state law based on y
NFPA 58)
8.3.b.2. OSHA (29 CFR 1910.111)
8.3.b.3. ASTM Standards y
8.3.b.4. ANSI Standards y
8.3.b.5. ASME Standards y
8.3.b.6. None
8.3.b.7. Other
8.3.b.8. Comments
8.4 Hazard Review
8.4.a. Date of completion of most recent 05/21/2019
hazard review or update
8.4.b. Expected or actual date of completion
of all changes resulting from the hazard
review
8.4.c. Maior hazards identified
8.4.c.1. Toxic release y
8.4.c.2. Fire y
8.4.c.3. Explosion y
8.4.c.4. Runaway reaction
8.4.c.5. Polvmerization
8.4.c.6. Overpressurization y
8.4.c.7. Corrosion y
8.4.c.8. Overfillina y
8.4.c.9. Contamination y
8.4.c.10. Equipment failure y
8.4.c.11. Loss of cooling, heating, electricitJ•,
instrument air
8.4.c.12. Earthauake y
8.4.c.13. Floods y
8.4.c.14. Tornado y
8.4.c.15. Hurricanes
8.4.c.16. Other
RMP*eSubmit KATHY.WEINEL
08/05/2019
11 :45:28
Page 7
,~~\ EPA FACILITY ID: \:.J 10000011 5742 White Mesa Uranium Mill
Section 8. Prevention Program: Program Level 2
8.4.d. Process controls in use
8.4.d.1. Vents
8.4.d.2. Relief valves
8.4.d.3. Check valves
8.4.d.4. Scrubbers
8.4.d.5. Flares
8.4.d.6. Manual shutoffs
8.4.d.7. Automatic shutoffs
8.4.d.8. Interlocks
8.4.d.9. Alarms and procedures
8.4.d.10. Keyed bypass
8.4.d.11. Emeraencv air supplv
8.4.d.12. Emernency power
8.4.d.13. Backup oumo
8.4.d.14. Groundina eauipment
8.4.d.15. Inhibitor additions
8.4.d.16. Rupture disks
8.4.d.17. Excess flow device
8.4.d.18. Quench system
8.4.d.19. Purae svstem
8.4.d.20. None
8.4.d.21. Other
8.4.e. Mitiaation systems in use
8.4.e.1. Sprinkler system
8.4.e.2. Dikes
8.4.e.3. Fire walls
8.4.e.4. Blast walls
8.4.e.5. Deluae svstem
8.4.e.6. Water curtain
8.4.e.7. Enclosure
8.4.e.8. Neutralization
8.4.e.9. None
8.4.e.10. Other
8.4.f. Monitorina/detection systems in use
8.4.f.1. Process area detectors
8.4.f.2. Perimeter monitors
8.4.f.3. None
8.4.f.4. Other
8.4.a. Chanaes since last hazard review or hazard update
8.4.a.1. Reduction in chemical inventorv
8.4.g.2. Increase in chemical inventorv
8.4.a.3. Chanae in process parameters
8.4.a.4. Installation of process controls
8.4.g.5. Installation of process detection
svstems
8.4.g.6. Installation of perimeter monitoring
svstems
8.4.g.7. Installation of mitiaation svstems
RMP*eSubmit KATHY.WEINEL
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
Resubmission 08/05/2019
11 :45:28
Page 8
<'& ~ ~ 100000115742
EPA FACILITY ID: White Mesa Uranium Mill Resubmission
Section 8. Prevention Program: Program Level 2
8.4.g.8. None recommended y
8.4.a.9. None
8.4.g.10. Other
8.5 Date of most recent review or revision of 12/17/2018
operating procedures
8.6 Trainina
8.6.a. Date of most recent review or revision 11/01/2018
of trainina oroarams
8.6.b. Tvpe of traininq provided
8.6.b.1. Classroom y
8.6.b.2. On the iob y
8.6.b.3. Other
8.6.c. Tvoe of comoetencv testina used
8.6.c.1. Written test y
8.6.c.2. Oral test
8.6.c.3. Demonstration y
8.6.c.4. Observation y
8.6.c.5. Other Discussion
8.7 Maintenance
8.7.a. Date of most recent review or revision 12/17/2018
of maintenance procedures
8.7.b. Date of most recent equipment 04/19/2019
inspection or test
8.7.c. Equipment most recently inspected or Ammonia Tankage, Valves, Piping and Pressure
tested (eauipment list) Releif Svstem
8.8 Compliance audits
8.8.a. Date of most recent comoliance audits 04/11/2019
8.8.b. Expected or actual date of completion
of all changes resulting from the most recent
compliance audits
8.9 Incident investigation
8.9.a. Date of most recent incident
investigation
8.9.b. Expected or actual date of completion
of all changes resulting from the incident
i nvestiaation
8.10 Date of most recent change that 06/09/2016
triggered a review or a revision of safety
information, the hazard review, operating or
maintenance orocedures. or trainina
RMP*eSubmit KATHY.WEINEL
08/05/2019
11 :45:28
Page 9
~lli~l EPA FACILITY ID: ~ 100000115742 White Mesa Uranium Mill Resubmission
Section 9. Emergency Response
9.1 Written emergency response (ER) plan
9.1.a. Is your facility included in the written y
community emergency response plan?
9.1.b. Does your facility have its own written y
emergency response plan?
9.2 Does your facility's ER plan include y
specific actions to be taken in response to
accidental releases of regulated substances?
9.3 Does your facility's ER plan include y
procedures for informing the public and local
agencies resoondina to accidental releases?
9.4 Does your facility's ER plan include y
information on emeraencv health care?
9.5 Date of most recent review or update of 05/21/2019
I your facility's ER plan
9.6 Date of most recent ER training for your 08/01/2018
facility's employees
9.7 Local aaencv with which vour facilitv's ER olan or response activities are coordinated
9.7.a. Name of agency Blandinq Fire Department
9.7.b. Phone number [phone]
9.8 Subject to
9.8.a. OSHA Regulations at 29 CFR 1910.38
9.8.b. OSHA Reaulations at 29 CFR 1910.120
9.8.c. Clean Water Act Regulations at 40 CFF
112
9.8.d. RCRA Regulations at 40 CFR 264, 265,
279.52
9.8.e. OPA-90 Regulations at 40 CFR 112, 33
CFR 154 49 CFR 194 30 CFR 254
9.8.f. State EPCRA Rules of Laws
9.8.g. Other UDEQ and MSHA
RMP*eSubmit KATHY.WEIN EL
08/05/2019
11 :45:28
Page 10
EPA FACILITY ID:
100000115742 White Mesa Uranium Mill Resubmission
Executive Summary
RMP*eSubmit
This facility follows MSHA Standards, ASTM Standards, ANSI Standards, and ASME Standards
pertaining to the storage and use of anhydrous ammonia. Emergency response training in the form
of site evacuation drills are conducted routinely and site environmental and safety personnel are fully
aware of the hazards and responses necessary should an anhydrous ammonia release occur. The
Emergency Response Plan is revised as needed annually and reviewed with all site personnel to
ensure they are familiar with any changes to the plans. It is our policy and practice to utilize the
facilities own response team to respond to onsite emergencies and to notify the Blanding Fire
Department to enlist their assistance, as necessary.
The facility utilizes two 140,000 lb tanks for storage of anhydrous ammonia. This reagent is used in
the uranium extraction process. The ammonia tanks are inspected on a daily basis, including
exterior tankage and piping. There has never been an accident at the facility involving anhydrous
ammonia that caused deaths injuries environmental damage propertv damaae or evacuations.
KATHY.WEINEL
08/05/2019
11 :45:28
Page 11
Certification Statement for Program Level 2 and 3 Process(es)
To the best of the undersigned's knowledge, information, and belief formed after reasonable
inquiry, the information submitted is true, accurate, and complete.
Certifier's Name
Facility Name and Location Address
EPA Facility ID
Certification Signed Date
Certifier's Email
Katherine Weinel
White Mesa Uranium Mill
6425 S. HWY 191
Blanding, UT 84115
1000 0011 5742
08/05/2019
[e-mail]
APPENDIXL
ENERGY FUELS RESOURCES (USA) INC.
Transportation Accident Response Plan
Fora
Uranium Concentrate Spill
Appendix L to the Emergency Response Plan for White Mesa Mill
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
PLAN SUMMARY
TRANSPORTATION ACCIDENTS RESPONSE PLAN FOR URANIUM CONCENTRATE
Driver or carrier instructions will be given to each driver of each transport leaving the plant site
with a load of uranium concentrate. These instructions will consist of an explanation of the
product, preliminary precautions at the accident site, whom to notify and what to do in case of
fire.
In the event of a transportation-related accident, immediate containment of the product will be
achieved by covering the spill area with a plastic sheeting or equivalent material to prevent wind
and water erosion. If sheeting is not available, and depending on where the spill occurs, soil from
the surrounding area may be used. Perimeter ditching will be used to contain the spill if it should
occur in an area where runoff could result from precipitation.
All human and vehicular traffic through the spill area will be restricted. The area would be
cordoned off if possible. All persons not participating in the accident response will be restricted
to 50 feet from the accident site. Local law enforcement officers will be notified and may be
asked to assist in controlling traffic and keeping unauthorized persons out of the spill area.
Covered containers and removal equipment, i.e., large plastic sheeting, radioactive signs, ropes,
hoses, shovels, vacuums, axes, stakes, heavy equipment (front-end loaders, graders, etc.), will be
available to clean up the yellowcake. If conditions warrant, water will be applied to the spilled
yellowcake in a fine spray to assist in dust abatement.
Gloves, protective clothing, and any personal clothing contaminated during cleanup operations
will be encased in plastic bags and kept in the plant area for decontamination or disposal.
Response team members will have a thorough knowledge in basic first aid and of the physical
hazards in inhalation, ingestion, or absorption of radionuclides. Team members will adequately
protect themselves.
The cleanup operation will involve removing small amounts of pavement, topsoil and vegetation
in the immediate area of the accident. The material that will have to be removed from the
affected area will be returned to the mill for reprocessing, if possible, or disposed of in a manner
approved by the NRC or the Director of the Utah Division of Radiation Control. Following
cleanup of the affected area, an alpha survey will be conducted to ensure that radioactivity is
within the limits outlined in NRC document "Guidelines for Decontamination of Facilities and
Equipment prior to release for unrestricted use or Termination of Licenses for Byproduct,
Source, or Special Nuclear Material", dated May 1987. An investigation will be conducted by
the Radiation Protection Department. Results and recommendations of the investigation and of
the decontamination survey will be documented and maintained for at least five years.
The NRC and the Director of the Utah Division of Radiation Control will be notified promptly of
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
any accident of this type.
EMERGENCY RESPONSE MANUAL FOR A URANIUM CONCENTRATE SPILL
TABLE OF CONTENTS
1.0 INTRODUCTION ............................................................................................................... 4
1.1 Needs ................................................................................................................................ 4
1.2 Scope ................................................................................................................................ 4
1.3 Description of Company Shipments ................................................................................ 4
2.0 ORGANIZATION ............................................................................................................... 5
3.0 TRAINING REQUIREMENTS .......................................................................................... 6
4.0 NOTIFICATION OF COMPANY PERSONNEL, GOVERNMENT AGENCIES, AND
INITIAL MEDIA CONTACTS ...................................................................................................... 6
4.1 Company or Private Carrier ............................................................................................. 6
4.2 DOT Notification ............................................................................................................. 6
4.3 NRC Notification ............................................................................................................. 7
4.4 State Notification .............................................................................................................. 7
4.5 DOE Assistance Teams .................................................................................................... 8
4.6 Media ................................................................................................................................ 8
5.0 EQUIPMENT ...................................................................................................................... 8
6.0 PROCEDURES FOR HANDLING THE ACCIDENT: ...................................................... 8
6.1 Transport Vehicle Operator (Driver) ................................................................................ 9
6.2 Response Team Mobilization ........................................................................................... 9
6.3 Emergency Containment .................................................................................................. 9
6.4 Protective Clothing ......................................................................................................... 10
6.5 Radiation Measurements and Sampling ......................................................................... 10
6.6 Establish Radiation Exclusion Area ............................................................................... 10
6.7 Control Point .................................................................................................................. 10
6.8 Check Station Operation ................................................................................................. 10
6.9 Transportation Accidents Involving IX Eluate or Uranium Product Liquor ................. 11
6.10 Decontamination ......................................................................................................... 12
6.10.1 Criteria .................................................................................................................... 12
6.10.2 Personnel and Clothing ........................................................................................... 13
List of Figures
1 Transportation Route to Metropolis, Illinois
2 Transportation Route to Port Hope, Ontario, Canada
3 Transportation Route to Blind River, Ontario, Canada
4 Chain of Command For Emergency Response to a Transportation Accident
5 Notification Procedures for Transportation Accidents Involving Concentrate Spill
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
List of Forms
Form 2-1
Form 4-1
Press Release Form for Uranium Concentrate Accident
Accident Report Form
List of Tables
4-1 Emergency Response Plan Communication Directory
5-1 Equipment for Mobilization and General Support
5-2 Equipment Carried in Transport Vehicle for Operator Use
5-3 Equipment Carried by Response Team
5-4 Radiation Monitoring/Measuring Equipment Carried by Response Team
5-5 Decontamination Equipment Carried by Response Team
6-1 Acceptable Surface Contamination
List of Attachments
Page 3 of 15
Attachment 1 Personnel Training Program for Uranium Concentrate Spill Emergency Response
Attachment 2 Driver Instructions
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 ST AND ARD OPERATING PROCEDURES Page 4 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
1.0 INTRODUCTION
1.1 Needs
The Nuclear Regulatory Commission requires that uranium producers implement an
emergency response plan for containment and cleanup of a uranium concentrate spill.
Although the Department of Transpmtation ("DOT") regulations place the responsibility
for these activities on the carrier, the regulatory agencies have taken the position that the
shipper has an obligation to assist because of his knowledge of the radioactive hazard of
the concentrate.
1.2 Scope
Transportation accidents involving radioactive materials such as yellowcake consist of
the following four phases:
a. Initial
During the first 15 to 30 minutes after the accident occurs emergency action is taken by
local authorities (local or state police) to help the injured, evaluate the problem, and take
action to prevent further contamination, i.e., rerouting traffic and crowd control.
b. Confinement
This phase is accomplished by the transport vehicle operator or local service units to
complete isolation or cover the spilled material, make proper notification, and identify
contaminated areas.
c. Cleanup
This action includes the removal of any radioactive material or contamination from the
site and restoring it to original conditions. This action is the carrier's responsibility.
d. Cost Recovery
The cost of cleanup and liability for damage to life and property are borne by the carrier.
The Company's emergency response plan must address confinement and cleanup activities
outlined above; the initial and "cost recover" phases are outside the scope of this manual.
1.3 Description of Company Shipments
The type of product shipped by each plant, the carrier responsible, the specific activity,
and the total activity in a shipment are summarized below:
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
Plant Carrier Type of
Concentrate
Approximate Activity
Per Load (Ci)/UNat
White Mesa Mill Truck Shipment Calcined U 30g 10.16
The transportation routes for these shipments are presented in Figures 1, 2, and 3.
2.0 ORGANIZATION
The Chief Operating Officer ("COO") is responsible for implementing this response plan.
Among his duties are:
1. Notify the Mill Manager, who will subsequently notify the response team leaders,
plant personnel, and consultants per procedures in Section 4.0.
2. Contact local authorities to ensure timely and clear communications with respect
to incident details.
3. Notify and keep informed the President and CEO.
4. Direct press inquiries to the President and CEO. Form 2-1, Press Release Form,
for use by the CEO or COO, only.
The other elements of the organization and their responsibilities are shown in Figure 4,
Chain of Command for Emergency Response to a Transportation Accident and as
follows:
1. Mill Manager
Designate an on-site responsible person as necessary. Coordinate the
activities of the response team with those of the regulatory agencies.
2. Re ponse Team Leader
Supervise the cleanup and decontamination of the spill area and coordinate
site activities with local, state and federal authorities.
3. Respon e Team Member
Carry out the activities involved in the cleanup and decontamination as
outlines in Section 6.10.
4. Plant Personnel
Provide assistance in stabilizing the spill, if possible, and in the cleanup
and decontamination operations.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 6 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
5. Consultants
Recommend procedures for the cleanup and decontamination operations
and/or provide personnel and equipment for these operations.
3.0 TRAINING REQUIREMENTS
Transport vehicle operators and emergency response personnel are given a basic
indoctrination with respect to radioactivity, personal protection, identification and
decontamination associated with natural uranium. Additionally, a field demonstration and
exercise including all emergency response personnel is conducted on a periodic basis to
assure preparedness. Attachment 1 is the detailed "Emergency Response Training
Outline".
4.0 NOTIFICATION OF COMPANY PERSONNEL, GOVERNMENT AGENCIES,
AND INITIAL MEDIA CONTACTS
The key to a successful emergency response plan is good communication to and within
the Company. This section provides information to assure that key Company personnel
and required Governmental Agencies are properly notified of the accident. Additionally,
guidance regarding release of information to the general public is provided.
Figure 4-1 shows, schematically, the notifications and critical telephone numbers
required in making the contacts. Table 4-1 lists the telephone numbers for the President
and CEO, COO, Mill Manager, response team leaders and members, plant personnel,
consultants, and DOE assistance teams.
Figure 4-1 shows the network that will be utilized to contact people and organizations in
the event of an emergency involving a uranium concentrate spill. The individuals,
organizations, and phone numbers are shown on Table 4-1. Supplementary information
on these procedures is presented below.
4.1 Company or Private Carrier
The accident report form, Form 4-1, is carried by the driver with his emergency
instructions. (See Attachment 2) The form should be completed prior to calling the COO
or the Mill Manager. This document provides the information required for other
notifications.
4.2 DOT Notification
The DOT reporting procedures require that an accident involving hazardous materials
which results in any of the following must be reported:
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 7 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
1. A person is killed.
2. A person requires hospitalization.
3. An evacuation of the general public occurs lasting one or more hours.
4. One or more major transportation arteries or facilities are closed or shut down for
one hour or more.
5. The operational flight pattern or routine of an aircraft is altered.
6. Fire, breakage, spillage, or suspected radioactive contamination occurs following
an accident involving radioactive materials.
7. A situation exists in the judgment of the carrier that there is a continuing danger
to life.
8. Release; i.e. rupture of drums in excess of 0.1 Ci U-Nat (approximately 1/2 drum)
constitutes a CERCLA Reportable Quantity (RQ) under 40 CFR 302 and 49 CFR
171 and requires immediate notification to the National Response Center.
As soon as practical but no later than 12 hours after the occurrence of any incident
described above, each person in physical possession of the hazardous material must
provide notice by telephone to the National Response Center at 800.424.8802 (toll free)
or 202.267.2675 (toll call). Note that the private carriers are responsible for reporting
accidents involving their vehicles.
Hazardous Materials Incident Report on DOT Form F-5800.1 (Rev. 01/2004) must be
filed within 30 days of discovery of the accident.
4.3 NRC Notification
Notification must be submitted to the NRC Operations Center at 301.816.5100 and to the
Director at 801.536.4250 (after hours to the UDEQ Duty Officer at 801.536.4123) within
24 hours on an incident.
4.4 State Notification
Notification to the State or States involved where the incident is involved should take
place as soon as possible. Promptly recommend to authorities specific protective action
to limit the danger to the public including evacuation and sheltering and the prophylactic
use of potassium iodide (Kl) as appropriate.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 8 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
4.5 DOE Assistance Teams
These teams would only be alerted in situations such as widespread contamination in a
metropolitan area.
4.6 Media
The responsible company representative at the accident scene will be required to make
statements to the press providing general information regarding the accident and status of
emergency activities. To simplify this matter during the initial stages of emergency
response, a "canned" press release form, outlined below is used. State, that additional
comment on the status of the situation will be available later in the day. Other
information released to the general public must have prior approval of the COO.
5.0 EQUIPMENT
Equipment for emergency response as well as its location and intended use is listed in
Tables 5-1 through 5-5 in the Tables Tab found at the back of this plan.
6.0 PROCEDURES FOR HANDLING THE ACCIDENT:
Vehicle accidents involving yellowcake can be categorized in three basic radiological
severity types as follows:
1. No apparent release of concentrate from its drum containers (drums may or may
not be outside the vehicle).
2. Concentrate is released from the drum but contained within the van.
3. Concentrate is spilled from its container outside the transport vehicle.
This characterization, as it applies to UPL shipments, consists of no apparent leakage
from the tank trucks, or a spill of solution. Section 6.9 outlines the procedures for
handling this type of accident.
Situations arising from each of these accident types can be highly variable depending on;
a. Proximity of waterways and populated areas;
b. Weather conditions at the accident site;
c. The condition of the vehicle operator after the accident; and
d. Availability of local emergency response personnel (police, firemen, etc.).
In view of these variables, this section is intended as a basic guide requiring certain judgmental
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 9 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
decisions on a case-by-case basis.
6.1 Transport Vehicle Operator (Driver)
Filling out the accident form and notifying the COO. They will then follow the following
emergency instructions carried in his kit.
a. If there is not apparent leakage ( drums may or may not be thrown from the
vehicle):
1. Caution people not to tamper with containers (use civil authorities to assist
if necessary) and have them stay 10 to 15 feet away.
2. Containers lying on the road should be moved to the road edge (if
assistance can be obtained), and
3. Assure local authorities there is no danger in handling closed containers.
6.2 Response Team Mobilization
The response team leader will access available accident information and assemble the
required personnel at the White Mesa Mill Office. Required vehicle and facility keys are
stored in the White Mesa Mill Office (labeled "Y. C. Response"). Mobilization will be
accomplished in the following sequence:
a. Obtain radiation monitoring/measuring equipment (Section 5.3),
b. Proceed to the Radiation Department storage containers,
c. Load emergency equipment in the vehicle (Section 5.0),
d. Obtain pool vehicles as required to transport all personnel, and
e. Proceed to the accident site.
The response team leader will check to make certain that available air samplers
(including filters), flashlights, and Geiger counters are dispatched with the plant
representative.
6.3 Emergency Containment
Upon arrival at the accident site inform local authorities of your presence, purpose, and
proposed activities. Gather information regarding current status of activities and assign
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page IO of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
one individual to record this information as well as names and positions of persons
present at the site. If the spilled material is not stabilized, proceed with this activity in
completing the procedures outlined in Section 6.1.
6.4 Protective Clothing
Protective clothing is normally required when spillage is evident. The need and use for
these are established by the response team leader on a case-by-case basis. He is also
responsible for controlling, maintaining, decontamination, testing and instructing in the
proper use of protective clothing and respiratory protective equipment.
6.5 Radiation Measurements and Sampling
Response team members are trained in proper operation of portable radiation detectors as
well as monitoring techniques (Attachment 1). Initial monitoring for spread of
contamination is accomplished with portable, open window, Geiger counters.
Additionally high volume air samples are located and activated 50 feet upwind and
downwind from the spill.
6.6 Establish Radiation Exclusion Area
The boundaries of the yellowcake spill area, whether inside the transport vehicle or
outside, are defined through a combination of visual observation (identifying yellow
color) and radiation monitoring (GM detectors). The area is then roped off, leaving about
ten feet between the tape barricade and the spill boundary, and "Caution Radioactive
Materials" signs are installed on the barricade. The barricaded area is referred to as the
"radiation exclusion" (RADEX) area and unauthorized equipment or personnel are not
allowed to enter.
6. 7 Control Point
A base of operations where needed equipment or data is stored and maintained is
established outside the RADEX area (normally about ten feet away from the barricade).
This base is referred to as the "control point". The control point is also used as a
debriefing area and personnel contamination station.
6.8 Check Station Operation
Receptacles (plastic bags) for used protective clothing and equipment are fastened to the
inside tape barricade, near the "control point," of the RADEX area. This location is used
as the only area where ingress and egress to the RADEX area is allowed, and it is referred
to as the "check station". One response team member is assigned to man the check station
and his responsibilities are:
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 11 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
a. Assure only required people enter the area and they are properly equipped with
protective clothing and respirators (Section 6.4).
b. When personnel exit the RADEX area, make certain protective clothing is
properly removed and placed in receptacles with the shoe covers being the last
items removed.
c. Monitor the person's exposed skin areas (hands, face, etc.) and clothing using
the alpha scintillation detector probe.
d. If personal clothing monitoring reveals contamination, remove the involved
clothing and monitor skin beneath it.
e. Collect nose swipes and monitor same.
f. If contamination is evident on nose swipes, label a urine sample bottle (name and
date) and request a donation at the earliest convenience; follow up this sampling
on a 24-hour basis.
g. If monitoring reveals skin contamination, direct the individual to the personnel
decontamination station.
h. Equipment being removed from the RADEX area is monitored for alpha radiation
at the check station and sealed in plastic bags or decontaminated if found
contaminated.
6.9 Transportation Accidents Involving IX Eluate or Uranium Product Liquor
The shipment of a solution in a tank truck is less hazardous than shipping a U30s
concentrate. The reasons are as follows:
1. The activity released to the environment by spillage of the contents of the tank
truck is approximately 8e-3 Ci/U-Nat per 300 gallons of solution.
2. There is no hazard from airborne material.
3. If a transportation accident occurred which resulted in the loss of the tank content,
the material released would not constitute a regulatory notification as defined in
40 CFR 302 or 49 CFR 171.
4. In the event of a fire, the solution would tend to extinguish it. The type of accident
that must be considered is a rupture of the vessel wall, and the resultant need to
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 12 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
contain the spillage.
The driver carries with the truck an emergency kit which contains respirators, clothing,
hammer, knife, tent pegs and 1,000 square feet of plastic sheeting. In the event of an
accident he is instructed to do the following:
a. Place the plastic sheeting under the leak.
b. If the leak is small, try to repair it with the aluminum tape.
c. If the leak cannot be contained by the above procedure, the foam pack will
be used to build a dike over the plastic sheet which is dropped on the
ground.
6.10 Decontamination
This section establi hed the criteria and procedure. for personnel, ground area and
equipment decontamination. Prompt decontamination is essential to avoid possible
internal exposure to radioactive material.
6.10.1 CI"iteria
Criteria presented are based on radioactive contamination resulting from an accident
involving natural uranium (yellowcake) and is excerpted from the U.S. Nuclear
Regulatory Commission (NRC) "guidelines" where appropriate.
1. Personnel and Cl thing
Personal clothing, skin and hair must not have any detectable alpha contamination
as measured with the Ludlum Model 3 (or equivalent) incorporating the alpha
scintillation detector probe.
2. LandArea and Equipment
The following instructions apply in all cases:
a. A reasonable effort must be made to completely eliminate residual
contamination.
b. Radioactivity on equipment or surfaces shall not be covered by paint,
plating, or other covering material unless contamination levels, as
determined by a survey and documented, are below the limits specified
below prior to applying the covering. A reasonable effort must be made to
minimize the contamination prior to use of any covering.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 13 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
c. Prior to release of equipment or abandoning the accident site, a
comprehensive survey will be made and recorded to establish that
contamination is within the limits specified below:
1. Alpha measurements will be made using the Ludlum alpha scintillation probe.
Multiplying observed cpm by efficiency to obtain dpm and multiplying dpm by
two to convert the probe area to 100 cm2
2. Removable contamination will be determined from a dry swipe sample if the total
surface area swiped is less than 100 cm2, pertinent levels must be reduced
proportionally.
3. Measurements of "average" contamination should not include more than one
square meter.
4. The maximum contamination level applies to an area of not more than 100 cm2
5. The acceptable mRem/hr@ 1 will be measured with the Texas Nuclear Ionization
Chamber (open window) (or equivalent).
6. Background mR/hr gamma is measured with the Ludlum Model 3 ( or equivalent)
incorporating the gamma scintillation detector probe and determined in an area at
least 200 feet away from the spill boundary for decontamination comparison.
6.10.2 Personnel and Clothing
Following are general guides for field use, harsher methods may be used
under direction of a Health' Physicist or Physician.
a. All contaminated clothing should be decontaminated by applying tape to
the contaminated area in an attempt to transfer the material to the tape or
by vacuuming. Contaminated clothing which cannot be decontaminated
should be removed and placed in plastic bags for future laundering.
b. A thorough washing with soap and water is the best general method of
decontaminating the face, hands, hair and body. The water should be used
only one time.
c. A soft bristled brush or nail brush may be used; however, care should
exercise not to irritate or abrade the skin. In addition, care must be taken to
prevent decontamination solutions from entering the body openings or
cuts.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 14 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Ground Areas
Appendix L
d. Several washings and rinsing may be necessary to achieve an acceptable
decontamination level. To prevent chapping, lanolin or hand cream may
be applied to areas which have been washed or scrubbed several times.
e. In many cases, tenacious surface-absorbed contamination may be
removed, from hands and/or forearms by promoting sweating in rubber
gloves sealed at the cuff between washings.
f. When contamination of a person is detected, nose swipes and urine
samples should be collected (Section 6.8).
The bulk spilled yellowcake will be shoveled into a lined metal drum and residual material will
be vacuumed. Always clean the area ahead of you making certain to stand in a contamination
free spot while working. Dusting during decontamination will be controlled by use of the water
spraying unit (do not use excessive water). If the spill is contained under a plastic cover, remove
the cover in one-foot increments as decontamination is accomplished.
The initial decontamination can be accomplished visually by color (yellow) observation,
followed by survey with a Geiger counter and finally by alpha monitoring and monitoring with
the TN Model 2590 equipment ( or equivalent).
Equipment
Field decontamination is limited in most instances to the removal of radioactive contamination
that is loosely attached in grease, dirt or mud. Contamination that is impacted, ground-in or
caught up in rust demands more abrasive measures and fairly sophisticated techniques often not
available if the field. Basic field guidelines are:
a. A plastic sheet or other "drop cloth" should be spread on the floor or
ground to catch any loose contaminant prior to commencement of
decontamination operations.
b. Dry items may be vacuumed thoroughly incorporating scraping or wire
brushing to loosen surface material.
c. Items may be wet wiped using rags, or they may be sloshed in or sprayed
with water to remove loose contamination provided the items will not be
damaged or impaired by moisture.
d. Acetone dampened rags may be used to remove more tenacious surface-
bound contamination.
e. Failing the above, sandpaper or steel wool may be used to remove a thin
Book#l6 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 15 of 15
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Appendix L
layer of the surface material followed by vacuuming or damp wiping.
f. Rags used for cleaning should be infolded and changed often to avoid
spreading the contamination. (Used rags are placed in plastic bags.)
g. If all above fails, and after thorough documentation of circumstances and
contamination levels, the contaminant may be released from the accident
site with prior government agency approval.
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Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
·tate: Utah
Figure 3
TRANSPORTATION ROUTE TO
BLIND RIVER, ONTARIO, CANADA
cae: NTS Date: Mo , 2014 Dratted By: D.Sledd
Transport_ Routes.dwg Blind River
Figure 4
Appendix L
Figures
Revision R-5.0
Chain of Command For Emergency Response to a Transportation Accident
~
Chief Operating Officer I ~ ~ and Mill Manager i ~ ~ ~
w;. Wh! W#~
Response
Team Leader
Response Plant Consultants -Team Personnel
Figure 5
Appendix L
Figures
Revision R-5.0
Notification Procedures for Transportation Accidents Involving Concentrate Spill
Company Private -Carrier Accident r
Arr.irlPnt
'
Driver Completes -Office Hours r Report (figure 4-2) 303.628.7798 • NRC Operations
Center
301.816.5100 Immediately
Exec Sec Notify within
801.536.4250 24 hours via
(801 .536.41233) telephone
National Response
Center (CERCLA)
800.424.8802
~ DOT 202.267.2675 . 30-Day Notification
Response Team ,~
Leaders (Table 4-1) ro
... DOE -r Radiological
Assistance
(Table 4-1)
FORMS
Form2-1
Press Release Form for Uranium Concentrate Accident
Appendix L
Forms
Revision R-5.0
At approximately (time) on (date) an accident involving a truck
carrying natural uranium concentrate from Energy Fuels Resources (USA) Inc.'s White Mesa
Mill occurred near(location) _______________ _
There (were or were not) _________ injuries to the public or the driver of the truck.
There (was or was not) spillage of the concentrate from the truck.
The accident occurred at near --------------------
If no spillage: State that your purpose is to make a routine check to insure that the shipment can
continue without presenting a hazard.
If spillage ha occurred: State that this group which has been trained to clean up spills of
concentrate will act in cooperation with government authorities to clean up the spill as quickly as
possible and that there is minimal risk to the public.
1.0
2.0
3.0
4.0
FORM4-1
Accident Report Form
Date Time
Appendix L
Forms
Revision R-5.0
----------------------------
Person Calling _____________ Capacity ________ _
From Telephone No. Who Else Notified ______ _
Accident Location -------------------------
Description of the Accident
Persons Injured ______ Name(s) ---------------
Treatment ___________________________ _
Accident Description ------------------------
5.0 Was Any Company Material Spilled from the Vehicle(s)? _________ _
6.0 What Action Has Been Taken to Contain the Material? -----------
7 .0 Please report this information to one of the following:
Monday -Friday 8:00 a.m. to 4:30 p.m. MST
Paul Goranson, Chief Operating Officer, Lakewood, Colorado.
Telephone No. 303-389-4168 day time, work days
Night and weekend contact Cell Phone [phone]
Logan Shumway, Mill Manager, White Mesa Mill, Blanding, Utah.
Telephone No. 435-678-2221 day time, work days
Night and weekend contact Telephone No. ( 435) 459-9878
TABLES
Table 4-1
Appendix L
Tables
Revision R-5.0
Emergency Response Plan Communications Directory
Function Name Daytime Phone
President & CEO Mark Chalmers 303.389.4155
Chief operating Paul Goranson 303.389.4168
Officer
Mill Manager Logan Shumway 435.678.4119
Response Team Terry Slade 435.678.4128
Leaders Garrin Palmer 435.678.4114
White Mesa Mill Terry Slade 435.678.4128
Response Staff Garrin Palmer 435.678.4114
Wayne Palmer 435.678.4126
Abel Mendoza 435.678.4109
DOE Radiological Team
Idaho Operations 208-526-0111 Ext. 1515 CO, WY, UT
Albuquerque Operations
TX, NM, OK, KA, AK
Chicago Operations
ND, SD, NB, IA
[phone]
[phone]
[phone]-Duty hours
[phone]-Off Days
Ni~ht Contact No.
303.801.7026
307.287.0126
435.459.9878
435.459.3545
435.459.9463
435 .459 .3545
435.459.9463
435.485.0584
435 .459 .2783
Otv.
2
As
Table 5-1
Appendix L
Tables
Revision R-5.0
Equipment for Mobilization and General Support
Descriotion Location Use
Pickup Radiation Equip. & Personnel
Department
Pool Vehicles Office Personnel
Needed
*
**
*1
*4
**2
*1
1
Portable AC Generator Radiation On-Site Electricity
Department
Exten. Cord/Light (50') Radiation AC Powered
Department Equipment
Flashlights Radiation Initial Set-Up
Department
Digital Camera Radiation Documentation
Department
First Aid Kit Radiation First Aid
Department
Carried by Response Team
Carried by Response Team and Plant Representative
Table 5-2
Equipment Carried in Transport Vehicle for Operator Use
Ouantitv Descriotion
1 Box w/Lid
1 1,000 Ft2 Plastic Sheet
1 Army Shovel
24 Spikes
1 Urethane "Dike-Pak"
1 Roll, Aluminum Tape
1 Hammer
4 Respirators, Half Mask
2 Coveralls
2 Pairs Gloves
Table 5-3
Appendix L
Tables
Revision R-5.0
Equipment Carried by Response Team (Stored in Radiation Department)
Ouantitv Descriotion
1 Plastic Sheet, 20 Ft. X 2,000 Ft.
1,000 ft. Barricade Tape
20 Metal Stakes
4 Radiation Warning Signs
1 Urethane "Dike-Pak"
1 Water Sprayer -Portable
1 Roll Aluminum Tape
4 Rolls Duct Tape
6 Respirators, Full Face, Type
Combo Canister
24 Coveralls, Disposable Paper
24 Pair Gloves, Plastic Impregnated
6 Pair Gloves, Rubber
24 Pair Shoe Covers
24 Head Covers, Nun Hood
Table 5-4
Radiation Monitoring/Measuring Equipment Carried by Response Team (Stored in the
White Mesa Radiation Department)
Ouantitv Descriotion Use
1 Aluminum Suitcase containing the following:
Ludlum Instruments
1 Count Rate Meter, Model 3 (or equivalent) Gamma, Beta, Alpha
Monitoring
1 G.M. Probe, Model 44-6 (or equivalent) Beta Monitoring
1 Na I (tl) Scintillation Probe, Model 44-2 (or Gamma Monitoring
equivalent)
1 ZnS (Ag) Scintillation Probe, Model 43-5 ( or Gamma Monitoring
equivalent)
2 Geiger Counters, Portable, W/Thin Wall G.M. Beta Monitoring
Probe ( or equivalent)
1 Eberline PRM-7 (or equivalent) Gamma Monitoring
1 Set -Check Sources, Eberline (Cs-137, Te-99, Th-Instrument Operational
230) Checks
2 Air Samplers, High-Vol. (50 Cubic Ft/Mm.), AC Site Air Sampling
Powered 2/50 Each Filters
20 Sample Bottles, Urine W/Labels Urinalysis
50 Nose Swipes, Q-Tip, W /Envelopes Detection of Radioactive
Particle Inhalation
Table 5-5
Appendix L
Tables
Revision R-5.0
Decontamination Equipment Carried by Response Team (Stored in White Mesa Office)
Ouantitv Description
2 Shovels
1 Vacuum Cleaner, Pullman Model JB-75, WI Absolute Filter and Drum Adapter
(or equi valent)
40 Drum Liner Bags
4 Metal Drums, 55-Gallon
2 Drum Closure Wrenches
1 Drum Cleanin g Rags w/ 1 Gallon Acetone
50 D.O.T. Labels; Yellow II
1 Can Waterless Hand Cleaner
1 Wash Basins
2 Bars S0a2
3 Washcloths
3 Towels
Fixed
Average
5,000 dpm/100 cm2
0.2 mRem/hr @ 1 cm
Background mR/hr
Table 6-1
Acceptable Surface Contamination
Maximum
15,000 dpm/100 cm2
1.0 mRem/hr @ 1 cm
Background mR/hr
Appendix L
Tables
Revision R-5.0
Removable
1,000 dpm/100 cm2
ATTACHMENTS
ATTACHMENT 1
PERSONNEL TRAINING PROGRAM FOR URANIUM CONCENTRATE SPILL
EMERGENCY RESPONSE
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
INTRODUCTION
This Attachment outlines personnel training requirements to ensure emergency preparedness
in the event of a transportation accident involving natural uranium (yellowcake). The training
consists of classroom discussion and demonstration as well as practical field exercise.
SESSION I -CLASSROOM DISCUSSION AND DEMONSTRATION
A. General Information
Natural uranium (yellowcake) decays through a complex scheme that results in
emanation of alpha, beta, and gamma radiation. The amount of radiation associated with
a specific volume of yellowcake is very low when compared to other natural radioactive
materials such as radium; therefore, small amounts of spilled yellowcake are relatively
difficult to measure with portable instrumentation. In practical application, the
beta/gamma radiation associated with small quantities of yellowcake can be detected
more readily than alpha or gamma only; although alpha is more abundant, it does not
travel a significant distance in air, and it is easily shielded making field measurements
very time consuming and impractical for an emergency situation. Therefore, beta-gamma
monitoring with a portable Geiger Mueller (GM) detector is the primary survey
instrument used.
B. Biological Hazards
The primary hazard associated with yellowcake is the effect of alpha radiation. Since
alpha is a relatively large particle, it cannot penetrate the skin and must be inhaled or
ingested to cause biological damage. Because of the low specific activity associated with
yellowcake, it takes about 17 milligrams within the body to represent a maximum
permissible body burden as compared to 0.0002 milligrams of radium-226 required to
produce the same effect.
C. Protective Clothing and Respirators
This equipment is provided to prevent contamination of personal clothing and the body as
well as to avoid transfer of contamination to locations outside the spill area. The
protective clothing and respirators are discussed in this section ( demonstration and
practice included).
1. Coveralls
Coveralls are provided to prevent particulate contamination from coming in
contact with the skin or clothing.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 2 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
Coveralls are donned in the normal dressing manner directly over personal
clothing. All openings (front, pockets, collar, and leg and sleeve cuffs) are sealed
with tape before entering the spill area. When exiting the spill area, coveralls are
removed as follows:
a. All tape is removed;
b. The front of the coveralls is pulled open, and;
c. Coveralls are removed by pulling them off the shoulders and off the trunk
and legs by turning legs inside out as the garment is removed. Used
coveralls are placed in a plastic bag.
2. Shoe Covers
These are used to prevent liquid or pai1iculate contamination from coming in
direct contact with the wearer's shoes and to avoid tracking contamination outside
the spill area. They are pulled on over the wearer's shoes and removed by
grasping the top edge and pulling downward which results in turning the shoe
cover inside out. Used shoe covers are placed inside a plastic bag.
3. Head Covers
These are used to prevent contamination from coming in direct contact with the
hair, ears, head and neck. The head cover is placed directly on the head
underneath other head wear (hard hats, if required). Head covers are removed by
opening the front snaps, grasping the top, and pulling off toward the back of the
head. Used head covers are placed in a plastic bag.
4. Gloves
5.
Gloves are used to prevent contamination of hands from radioactive particulates
and to protect the hands from corrosive materials. When exiting the contaminated
(spill) area or after handling contaminated material, the glove is removed by
grasping it by the cuff and pulling downward off the hand; this results in turning
the glove inside out. Used gloves are then placed inside a plastic bag.
Respirator (Demonstration and Practice)
Respirators (full) are provided to prevent inhalation of particulate material which
may become air-borne during spill containment or decontamination operations.
Prior to.use, the mask shall be checked as follows:
a. Cleanliness of mask facepiece; valves, and eyepiece is visually checked.
b. The head harness is checked to assure all straps and fasteners are
functional.
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 3 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
c. The canister is examined to assure free flow of air and tightness of
connections.
d. The integrity of the facepiece is visually checked by flexing the unit inside
out and observing any cracks or holes.
Respirators are donned by placing the chin in first, then pulling the head harness
or straps over the head, and tightening the straps.
To avoid contamination transfer when disrobing, protective clothing shall be removed in
the following sequence:
1. Remove glasses;
2. Remove head cover;
3. Remove coveralls;
4. Remove respirator; and
5. Remove shoe covers.
Disrobing will take place at the "RADEX" area "control point".
D. Radiation Monitoring and Sampling
Various portable radiation detection instruments and radiation sampling devices are
provided to assist in identifying the boundaries of the spill area, determining radiation
exposure rates, documenting contamination levels, and determining if internal personnel
exposures have resulted. Since yellowcake has a very distinctive color, response team
members should incorporate visual observation with radiation monitoring and sampling
to asses contamination extent. This section discusses types of equipment provided and
application of each ( demonstration and practice included).
1. Beta-Gamma Monitoring
The Geiger Counters and Ludlum Model 3 with the Model 44-6 thin wall GM
tube detector are used for beta monitoring (or equivalent). These instruments
measure most of the beta and some (about ten percent) gamma radiation. This is
the primary tool used for monitoring ground areas and equipment associated with
a spill. Basic steps are as follows:
a. Turn the instrument on and check the batteries.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page4 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
b. Turn the scale selector switch to the appropriate scale.
c. Move the detector shield to the open window position.
d. Place the U-238 check source on a flat, clean surface.
e. Grasp the detector probe with fingers in a manner assuring not to cover the
open window.
f. Place the detector probe open window grill in contact with the check
source.
g. The meter should indicate cpm equal to about one-fifth (20 percent) of the
total dpm of the source. (Since measurements are used for relative
comparison with background radiation, and not for accurate exposure or
analytical measurements, the object of this check is to ascertain instrument
response to a radiation source.)
h. Monitor desired area by moving the open window detector slowly (about
one foot per second) over the area about one-inch above the surface.
2. Gamma Monitoring
The Ludlum Model 3 with the Model 44-2 gamma scintillation detector probe (or
equivalent) is used for these measurements. Gamma measurements are not
normally required in conjunction with a yellowcake spill; however, they can be
used to supplement monitoring normally accomplished with a Geiger counter in
the event Geiger counters are not available or operable. The instrument
operational checks and subsequent monitoring are performed in the same manner
as those discussed for beta, except the Cs-137 check source is used, and the
detector probe does not have an open window (the lower one inch of the probe is
the sensitive portion).
3. Alpha Monitoring
The Ludlum Model 3 with the Model 43-5 alpha scintillation probe (or
equivalent) is used to make alpha measurements as follows:
a. Turn the instrument on and push the "BAT" button to assure batteries are
in good condition.
b. Place the Th-230 check source on a flat, clean surface.
c. Grasp the detector probe in the palm of the hand extending thumb and
fingers about 0.5 cm below the detector window (to avoid damaging the
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
mylar when monitoring rough surfaces).
d. Turn the range selector switch to the appropriate position and center the
detector probe over the check source.
e. The meter should indicate counts per minute ( cpm) equal to about 20
percent of the total disintegrations per minute ( dpm) of the source (the
decimal equivalent of this percentage is called the "efficiency factor").
f. Counts per minute are converted to dpm through dividing them by the
efficiency factor.
g. Move the detector probe to surface requiring monitoring and hold in one
place until meter reaches its maximum deflection.
h. Since the detector probe covers about 50 cm2, it is necessary to multiply
measured dpm by 2 to obtain dpm/100 cm2 for criteria comparison.
1. Continue process in (g) above until entire surface is monitored.
4. Swipe Samples
Surface swipes are used to identify the presence of loose or removable
contamination on the areas or items of interest for comparison with "acceptable
surface contamination levels". Swipes are spot checks for the presence or spread
of contamination but they do not provide quantitative reproducible data which can
be used to document contamination levels. Therefore, swipe samples and analysis
results are treated more informally than direct instrument measurements obtained
from the surface of concern.
The person collecting swipe samples must wear gloves. A surface area of
approximately 100 cm2 is wiped with a dry Whatman filter paper to collect any
larger contaminated particles. The filter paper is dampened with acetone to wipe
surfaces for collection of very fine particles. Swipes are monitored with the alpha
scintillation detector and resulting data is converted to dpm/100 cm2. After
monitoring, the swipe is placed in an envelope (using tweezers to avoid scraping
material off the swipe), the envelope is sealed with tape, and the sampling
location and date of collection is recorded on the tape.
Nose swipes, consisting of "Q tips", are collected from all persons working in or
otherwise exposed to the yellowcake spill. Collection is accomplished by
extending the cotton tip into each nostril and gently swirling it. These swipes are
monitored and handled in the same manner as other surface swipes.
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 6 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
5. Air Sampling
High-volume air samplers are used to monitor presence of airborne radioactivity.
One unit is located about 50 feet upwind from the yellowcake spill and another is
located about 50 feet downwind from the spill as follows:
a. Locate air sampler at least three feet above the ground in an area with no
obstructions between the source (spill) and the sampler.
b. Connect extension cords between samplers and the portable generator.
c. Make certain filters are securely in place on the air sampler head.
d. Turn the air sampler on and record the date, start time, sampler flow rate,
and location.
e. At the end of the sampling period (normally 24 hours), record the sampler
flow rate, time of day and date, and secure the sampler.
Remove the sample filter and place in a plastic Petri-dish using care to
assure particles are not removed from the filter.
f. Mark the filter Petri-dish with pertinent data (d and e above) and
commence another sampling period (c through g above).
E. Contamination Control
This section combines individual subjects covered in A, B, C, and D above in the
practical manner they would be used in the field. Presentation will include
questioning class members regarding actions for each subject as well as
demonstration. Since the subjects in this section have previously been discussed
in detail, a simple outline is used.
1. Ractiation Exclusion (RADEX Area)
a. Establish spill boundaries
1) Visual
2) Radiation monitoring
b. Erect barricade
1) Rope off
2) Attach signs
a) May not be required if spill is minor and easily guarded
c. Install air samplers
2. Control Point
a. Equipment storage
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 7 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
b. Personnel decontamination station
1) Wash basins
2) Soap, etc.
c. Personnel debriefing
3. Check Station
a. Access control
b. Radiation monitoring
1) Personnel
a) Beta-gama, alpha
b) Nose swipes
c) Urine samples
2) Equipment
a) Beta-gamma, alpha
b) Swipes
c) Protective clothing
1) Disrobe at check station
a) Place in receptacles
4. Spill Containment
a. Diking
1) Soil
2) Use of "dike-pak"
b. Trenching
1) To avoid liquid passing into spill area
c. Covering
1) Plastic sheet
2) "Dike-pakTM
3) Soil
F. Decontamination
This section presents a simple outline to be presented in a question and answer
type of discussion.
1. Land Areas
a) Shoveling
b) Vacuuming
2. Personnel
a) Clothing
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019
1)
2)
3)
Title: White Mesa Mill Emergency Response Plan
Taping
Vacuuming
Removal
Attachment 1
a) Sealed in plastic bag
b) Body
1)
2)
3)
4)
5)
6)
Vacuuming
Taping
Washing
Promoting sweating
Ear openings
a) Swabs
Eyes
a) Flush
3. Equipment
a) Vacuuming
1) Scraping
2) Chipping
b) Damp wipe
1) Rags and acetone
2) Water
c) Washing
1) Detergent scrubbing
d) Sealing
1) Only after reasonable decontamination efforts
a) Tape
b) Seal in plastic
c) Paint
Page 8 of 10
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 9 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment I
SESSION II -FIELD EXERCISE
This portion of the training program will be conducted outdoors on Company-owned property.
An accident involving yellowcake spillage inside the van and on the surrounding ground area
will be simulated using a readily visible material (corn meal, flour, lime, etc.). A few radioactive
sources (probably uranium ore) will be scattered within the spilled material to accommodate
practical radiation monitoring experience. The sequence of events following a yellowcake
transportation accident will be enacted by the driver and response team members as outlined in
this Section. A least one person will act as a local authority to ask questions and provide
assistance when requested.
A.
1.
2.
3.
B.
1.
2.
3.
4.
5.
Driver Responsibilities
Emergency Information
a. What is yellowcake and associated hazards.
Emergency Containment
b. Dike
c. Rope off
d. Cover (if appropriate)
a. Access control
Accident Notification
a. Accident report form
b. Notification by telephone
Response Team Responsibilitie
Mobilization
Press Release
Containment
a. Assessment (visual)
b. Rope barricade and signs
c. Cover (if appropriate) or dike
Contamination Control
a. Radiation survey of ground area (document)
b. Establish RADEX area
c. Establish control point
1) Personnel decontamination
d. Establish check station
e. Start-up air samplers (document)
Decontamination (clean up entire piJI)
a. Ground area
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 10 of 10
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 1
1) Shovel
2) Vacuum
b. Personnel
1) Clothing
2) Body
3) Nose swipes and urine sample (document)
c. Equipment
1) Vacuum
a) Scrape
2) Damp wipe
3) Wash
4) Scale
6. Egaipment and Per onnel Release
a. Final radiation surveys
1) Documentation
b. Final sampling
1) Documentation
a) Personnel
b) Air
c) Swipes
c. Authorization
1) Company representative
2) Government agency
7. Documentation and Reports
a. Accident Report Form
b. News release
c. Radiation surveys
d. Sampling data
e. D.O.T.Reports
ATTACHMENT 2
DRIVER INSTRUCTIONS
1
Book#16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 1 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 2
ATTACHMENT 2
These instructions will be reviewed with the Company's drivers and become a part of their
standing instructions. These instructions cover items that should be checked before and after
shipment, as well as emergency procedures.
The representatives of the commercial carriers will be asked to fill out the accident questionnaire,
notify us of the accident and state whether clean-up assistance is required.
1
Book #16
Rev. No.: R-6.0
Date: May 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
Attachment 2
Shipment of Uranium Concentrate
Driver's Checklist
1.0 Preshlpment Activities
Page 2 of 5
1.1 Ensure that the emergency procedures are included with the shipping papers.
1.2 Check to ensure that the closure on the rear door of the truck is properly sealed.
1.3 Check package of emergency equipment to ensure items shown in Section 8 are
available.
2.0 During Transport
2.1 Vehicle should be attended at all times while on the highway. It may be left
unattended to obtain assistance during a breakdown.
2.2 The vehicle should not be parked on or within five feet of the public highway.
2.3 Check on parking and before start-up to ensure rear door is properly sealed.
2
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 2
EMERGENCY INFORMATION AND PROCEDURES
YOUR CARGO IS: Uranium Concentrate
THIS MATERIAL:
1. Is NOT explosive.
2. Will not burn.
Page 3 of 5
3. Is a naturally radioactive material of low specific activity. It should not be inhaled, eaten,
or allowed to get into an open wound.
4. Can be approached without danger of injury from external radiation.
IN THE EVENT OF ACCIDENT, AS SOON AS POSSIBLE:
1. Take preliminary precautions below. Display these instructions as necessary to local
authorities on the scene to obtain their help (see item 2 below).
2. Collect the information on the accident form (included in your shipping packet).
3. Call (or have local authority call for you) the Chief Operating Officer, Energy Fuels
Resources (USA) Inc., Telephone No. 303-389-4168, Lakewood, Colorado, collect (if
necessary), between 8:00 a.m. -4:30 p.m. MST. At all other times call 307-287-0126.
4. If local authorities need radiological assistance have them call the DOE offices at 208-
526-0111 Ext. 1515.
5. Make no other statements or phone calls except on instructions from Energy Fuels
Resources (USA) Inc. Management.
PRELIMINARY PRECAUTIONS
CONTAINERS ARE NOT LEAKING, and are not eriously damaged. Container may or may
not be thrown from vehicle. Vehicle may or may not be damaged.
1. Caution people not to tamper with the containers. Use civil authorities to help you if
necessary.
2. It is not necessary to have a specific distance between humans and the containers or
truck, but for ease of controlling the situation, ask people to stay back 10 to 15 feet.
3
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 4 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 2
3. If closed containers are lying on the road, obtain assistance from whatever civil authority
is available to move containers to the side of the road.
4. Assure local authorities that there is no danger in handling closed containers.
CONTAINERS ARE LEAKING OR DAMAGED TOO SERIOUSLY to be moved. Truck or
railroad car may or may not be damaged.
1. Caution people to stay away from the material. Keep them at a distance of at least 25 feet.
Extreme distance is not necessary. Use civil authorities to help if necessary.
2. Assure local authorities that there is no danger from radiation but that people should
avoid breathing any dust from the material.
3. Avoid trackage of material by people or vehicle. Obtain help from local civil authorities
if necessary to reroute traffic around the spill area.
4. Keep material from running into streets, gutters, sewers, etc., if possible. A simple
method for doing this might be to dig a trench around the material or throw up an earthen
dike several inches high.
5. If required, cover the spilled uranium concentrate. The vehicle's emergency kit contains
four approved dust respirators, respirator user instructions, 1,000 square feet of plastic
sheeting, tent stakes, nails, a hammer and a knife.
Don a respirator and cover the spilled material with the plastic sheeting and secure the
edges of the plastic to the ground using tent stakes or to the bed of the truck with nails.
Undamaged containers can be moved to the side of the road.
6. A void breathing dust from the material. When covering the material, obtain a simple
respirator if possible. If none is available, work the material in such a manner as not to
stir up excessive dust.
FIRE involving vehicle or in immediate vicinity of vehicle.
1. Isolate the vehicle from other people and property if possible. Use civil authorities for
help.
2. Obtain fire fighting help from local group.
3. The material you are hauling will not burn.
4
Book #16 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-6.0 STANDARD OPERATING PROCEDURES Page 5 of 5
Date: May 2019 Title: White Mesa Mill Emergency Response Plan
Attachment 2
4. Keep fire away from uranium containers if possible.
5. Use respirator if necessary to avoid breathing smoke from any fire involving your cargo
because of the possibility of airborne particles, if the drums are ruptured.
6. Do not spray water into open or leaking containers. There is no reaction with water but a
heavy stream of water will spread the material and make cleanup more difficult.
5
07 /2011 Revision Denison 2.3
Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan.
TABLE OF CONTENTS
1.0 Introduction .............................................................................................................. 2
2.0 Cell Design ............................................................................................................... 2
2.1 Cell 4A Design ................................................................................................. 2
2.2 Cell 4B Design .................................................................................................. 5
3.0 Cell Operation .......................................................................................................... 8
3.1 Solution Discharge to Cell 4A .......................................................................... 8
3.2 Solution Discharge to Cell 4B .......................................................................... 8
3.3 Initial Solids Discharge into Cell 4A ................................................................ 9
3.4 Initial Solids Discharge into Cell 4B ................................................................ 9
3.5 Equipment Access to Cell 4A and Cell 4B ..................................................... 10
3.6 Reclaim Water System at Cell 4A .................................................................. 10
3.7 Reclaim Water System at Cell 4B .................................................................. LO
3.8 Interim Solids Discharge to Cell 4A. .............................................................. 11
3.9 Interim Solids Discharge to Cell 4B ............................................................... LI
3.10 Liner Maintenance and QA/QC for Cell 4A ............................................... 11
3.11 Liner Maintenance and QA/QC for Cell 4B ............................................... 11
4.0 BAT Performance Standards for Tailings Cell 4A and 4B .................................... 11
5.0 Routine Maintenance and Monitoring ................................................................... 13
5.1 Solution Elevation .......................................................................................... 13
5.2 Leak Detection System ................................................................................... 13
5.3 Slimes Drain System ...................................................................................... 15
6.0 Tailings Emergencies ............................................................................................. 16
7.0 Solution Freeboard Calculations ............................................................................ 16
8.0 List of Attachments ................................................................................................ 18
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1.0 Introduction
Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25, 2007. The construction
authorization provided that Cell 4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the
Groundwater Discharge Permit No. UGW370004 ("GWDP") and fulfill the
requirements of Parts I.D.6, I.E.8, and I.F.9 of the GWDP.
Construction of Cell 4B was authorized by DRC on June 21, 2010. The construction
authorization provided that Cell 4B shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the GWDP and
fulfill the requirements of Parts I.D.12, 1.E.12, and I.F.9 of the GWDP
2.0 Cell Design
2.1 Cell 4A Design
Tailings Cell 4A consists of the following major elements:
a) Dikes -consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to 1 V. The west dike has an interior slope of 2H to
1 V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation -including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90%. Floor of
Cell 4A has an average slope of 1 % that grades from the northeast to the
southwest corners.
c) Tailings Capacity-the floor and inside slopes of Cell 4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, m
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of impermeable 60
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mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
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2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML -consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Perrnittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System -including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material ( solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. The non-woven geotextile
material is overlain at the surface by a woven geotextile fabric, which is
ballasted laterally by sandbags on each side of the backbone of the berm.
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In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as
the "backbone" to the slimes drain system and runs from the far northeast
corner downhill to the far southwest corner of Cell 4A where it joins the
slimes drain access pipe.
3) Slimes Drain Access Pipe -consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and nonwoven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted by sandbags.A reducer
connects the horizontal 18-inch pipe with the 4-inch SDC pipe. At some
future time, a pump will be set in this 18-inch pipe and used to remove
tailings wastewaters for purposes of de-watering the tailings cell.
f) Dike Splash Pads -A minimum of eight (8) 20-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads consist of an extra layer of 60 mil
HDPE membrane that is placed down the inside slope of Cell 4A, from the top
of the dike and down the inside slope. The pads extend to a point 5-feet
beyond the toe of the slope to protect the liner bottom during initial startup of
the Cell. The exact location of the splash pads is detailed on the As-Built
Plans and Specifications.
g) Rub Protection Sheets -In addition to the splash pads described in f) above,
rub sheets are installed beneath all piping entering or exiting Cell 4A that is
not located directly on the splash pads.
h) Emergency Spillway -a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. A second
spillway has been constructed in the southwest corner of Cell 4A to allow
emergency runoff from Cell 4A into Cell 4B. All stormwater runoff and
tailings wastewaters not retained in Cells 3 and 4A, will be managed and
contained in Cell 4B, including the Probable Maximum Precipitation and
flood event.
2.2 Cell 4B Design
Tailings Cell 4B consists of the following major elements:
a) Dike -consisting of a newly-constructed dike on the south side of the cell
with a 15-foot wide road at the top (minimum) to support an access road.
The grading plan for the Cell 4B excavation includes interior slopes of 2H
to 1 V. The exterior slope of the southern dike will have the typical slopes
of 3H to 1 V. Limited portions of the Cell 4B interior sideslopes in the
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northwest corner and southeast corner of the cell (where the slimes drain
and leak detection sump will be located) will also have a slope of 3H to
1 V. The base width of the southern dike varies from approximately 100
feet at the western end to approximately 190 feet at the eastern end of the
dike, with no exterior embankment present on any other side of the cell.
b) Foundation -including sub grade soils over bedrock materials. Foundation
preparation included 6-inch over excavation of rock and placement and
compaction of imported soils to a maximum dry density of 90% at a
moisture content between +3% and -3% of optimum moisture content, as
determined by ASTM D-1557. The floor of Cell 4B has an average slope
of 1 % that grades from the northwest corner to the southeast corner.
c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass
about 45 acres and the cell will have a water surface area of 40 acres and a
maximum capacity of about 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of 60 mil high
density polyethylene (HDPE) membrane that extends across both the
entire cell floor and the inside side-slopes, and is anchored in a trench at
the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4B floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4B, and
drains to a leak detection sump in the southeast corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML -consisting of a 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends
across the entire Cell 4B floor, up the inside side-slopes and is also
anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4B, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight.
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e) Slimes Drain Collection System -including a two-part system of strip
drains and perforated collection pipes both installed immediately above
the primary FML, as follows:
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4B that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southeasterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of ~he strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
by a layer of non-woven geotextile to serve as an additional filter material.
The non-woven geotextile material is overlain at the surface by a woven
geotextile fabric, which is ballasted by sandbags. This perforated
collection pipe serves as the "backbone" to the slimes drain system and
runs from the far northwest corner downhill to the far southeast corner of
Cell 4B where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe -consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4B at the southeast corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and non-woven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted laterally by sandbags on each
side of the backbone of the berm. A reducer connects the horizontal 18-
inch pipe with the 4-inch SDC pipe. At some future time, a pump will be
set in this 18-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
f) Cell 4B North and East Dike Splash Pads -Nine 20-foot-wide splash pads
will be constructed on the north and east dikes to protect the primary FML
from abrasion and scouring by tailings slurry. These pads will consist of
an extra layer of textured, 60 mil HDPE membrane that will be installed in
the anchor trench and placed down the inside slope of Cell 4B, from the
top of the dike, under the inlet pipe, and down the inside slope to a point at
least 5 feet onto the Cell 4B floor beyond the toe of the slope.
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g) Rub Protection Sheets -In addition to the splash pads described in f)
above, rub sheets are installed beneath all piping entering or exiting Cell
4B that is not located directly on the splash pads.
h) Emergency Spillway -a concrete lined spillway constructed near the
southern corner of the east dike to allow emergency runoff from Cell 4A
into Cell 4B. This spillway will be limited to a 6-inch reinforced concrete
slab, with a welded-wire fabric installed within its midsection, set atop a
cushion geotextile placed directly over the primary FML in a 4-foot deep
trapezoidal channel. A 100 foot wide, 60 mil HDPE geomembrane splash
pad will be installed beneath the emergency spillway. No other spillway
or overflow structure will be constructed at Cell 4B. All stormwater
runoff and tailings wastewaters not retained in Cells 2, 3 and 4A, will be
managed and contained in Cell 4B, including the Probable Maximum
Precipitation and flood event.
3.0 Cell Operation
3.1 Solution Discharge to Cell 4A
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3, or transferred from Cell 2
tailings dewatering operations. The solution will be pumped to Cell 4A through
appropriately sized pipelines. The initial solution discharge will be in the
southwest corner of the Cell. The solution will be discharged in the bottom of
the Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and Cell 4A, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.
3.2 Solution Discharge to Cell 4B
Cell 4B will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3 or Cell 4A, or transferred
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from Cell 2 dewatering operations. The solution will be pumped to Cell 4B
through appropriate sized pipelines pipelines. The initial solution discharge will
be in the southeast corner of the Cell. The discharge pipe will be routed down the
Splash Pad provided in the southeast corner of the Cell at the spillway to protect
the primary FML. The solution will be discharged in the bottom of the Cell, away
from any sand bags or other installation on the top of the FML. Building the
solution pool from the low end of the Cell will allow the solution pool to
gradually rise around the slimes drain strips, eliminating any damage to the strip
drains or the sand bag cover due to solution flowing past the drainage strips. The
solution will eventually be discharged along the dike between Cell 3 and Cell 4B,
utilizing the Splash Pads described above. The subsequent discharge of process
solutions will be near the floor of the pond, through a discharge header designed
to discharge through multiple points, thereby reducing the potential to damage the
Splash Pads or the Slimes Drain system. At no time, subsequent to initial filling,
will the solution be discharged into less than 2 feet of solution. As the cell begins
to fill with solution the discharge point will be pulled back up the Splash Pad and
allowed to continue discharging at or near the solution level.
3.3 Initial Solids Discharge into Cell 4A
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through appropriately sized
pipelines. The pipelines will be routed along the dike between Cell 3 and Cell
4A, with discharge valves and drop pipes extending down the Splash Pads to the
solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure lA. Figure
2A illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2A. Because of the
depth of Cell 4A, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
3.4 Initial Solids Discharge into Cell 4B
Once Cell 4B is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through appropriately sized
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pipelines. The pipelines will be routed along the dike between Cell 3 and Cell
4B, with discharge valves and drop pipes extending down the Splash Pads to the
solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure lB. Figure
2B illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2B. Because of the
depth of Cell 4B, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
3.5 Equipment Access to Cell 4A and Cell 4B
Access will be restricted to the interior portion of the cells due to the potential to
damage the flexible membrane liners. Only low pressure rubber tired all terrain
vehicles or foot traffic will be allowed on the flexible membrane liners. Personnel
are also cautioned on the potential damage to the flexible membrane liners
through the use and handling of hand tools and maintenance materials.
3.6 Reclaim Water System at Cell 4A
A pump barge and solution recovery system is operating in the southwest corner
of the cell to pump solution from the cell for water balance purposes or for re-use
in the Mill process. Figure 3A illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
3.7 Reclaim Water System at Cell 4B
A pump barge and solution recovery system will be installed in the southeast
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3B illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
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the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
3.8 Interim Solids Discharge to Cell 4A
Figure 4A illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4A. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
3.9 Interim Solids Discharge to Cell 4B
Figure 4B illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4B. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
3.10 Liner Maintenance and QA/QC for Cell 4A
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised Construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
3.11 Liner Maintenance and QA/QC for Cell 4B
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Construction Quality Assurance Plan
for the Construction of the Cell 4B Lining System, October 2009, by
Geosyntec Consultants.
4.0 BAT Performance Standards for Tailings Cell 4A and 4B
DUSA will operate and maintain Tailings Cell 4A and 4B so as to prevent release of
wastewater to groundwater and the environment in accordance with this BAT Monitoring
Operations and Maintenance Plan, pursuant to Part I.H.8 of the GWDP. These
performance standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment -the
leak detection system pumping and monitoring equipment in each cell
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includes a submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system in each
cell at no more than 1 foot above the lowest level of the secondary flexible
membrane, not including the sump. A second leak detection pump with
pressure transducer, flow meter, and manufacturer recommended spare
parts for the pump controller and water level data collector is maintained
in the Mill warehouse to ensure that the pump and controller can be
replaced and operational within 24 hours of detection of a failure of the
pumping system. The root cause of the equipment failure will be
documented in a report to Mill management with recommendations for
prevention of a re-occurrence.
2) Maximum Allowable Head-the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane in each cell
by the use of procedures and equipment specified in the White Mesa
Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan, 10/10 Revision: Denison-10.2,
or the currently approved DMT Plan. Under no circumstance shall fluid
head in the leak detection system sump exceed a 1-foot level above the
lowest point in the lower flexible membrane liner, not including the
sump.
3) Maximum Allowable Daily LDS Flow Rates -the Permittee shall
measure the volume of all fluids pumped from each LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell
4B. The maximum daily LDS flow volume will be compared against the
measured cell solution levels detailed on the attached Table lA or lB for
Cells 4A or 4B, respectively, to determine the maximum daily allowable
LDS flow volume for varying head conditions in the cell.
4) 3-foot Minimum Vertical Freeboard Criteria -the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell 4A and Cell 4B. Said measurements
shall be made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring-immediately after the
Permittee initiates pumping conditions in the Tailings Cell 4A or Cell
4B slimes drain system, quarterly recovery head tests and fluid level
measurements will be made in accordance with a plan approved by the
DRC Executive Secretary. The slimes drain system pumping and
monitoring equipment, includes a submersible pump, pump controller,
water level indicator (head monitoring), and flow meter with volume
totalizer.
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Cell 4A BAT Monitoring, Operations and Maintenance Plan
5.0 Routine Maintenance and Monitoring
01/21/2010 Revision
Denison 2.2
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager and RSO.
5.1 Solution Elevation
Measurements of solution elevation in Cell 4A and Cell 4B are to be taken by
survey on a weekly basis, and measurements of the beach area in Cell 4A and Cell
4B with the highest elevation are to be taken by survey on a monthly basis, by the
use of the procedures and equipment specified in the latest approved edition of the
DMT Plan.
5.2 Leak Detection System
The Leak Detection System in Cell 4A and Cell 4B is monitored on a
continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The water levels are measured
every hour and the information is stored for later retrieval. The water
levels are measured to the nearest 0.10 inch. The data collector is
currently programmed to store 7 days of water level information. The
number of days of stored data can be increased beyond 7 days if needed.
The water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill's environmental monitoring data base,
and into the files for weekly inspection reports of the tailings cell leak
detection systems. Within 24 hours after collection of the weekly water
level data, the information will be evaluated to ensure that: 1) the water
level in the Cell 4A and Cell 4B leak detection sumps did not exceed the
allowable level (5556.14 feet amsl in the Cell 4A LDS sump and 5558.5
feet amsl in the Cell 4B sump), and 2) the average daily flow rate from the
LDS did not exceed the maximum daily allowable flow rate at any time
during the reporting period. For Cell 4A and Cell 4B, under no
circumstance shall fluid head in the leak detection system sump exceed a
I-foot level above the lowest point in the lower flexible membrane liner,
not including the sump. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and Cell 4B leak detection system, the
total volume of all fluids pumped from the LDS of each cell on a weekly
basis shall be recovered from the data collector, and that information will
be used to calculate an average volume pumped per day for each cell.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day from Cell 4A or 26,145 gallons/day from Cell 4B. The
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maximum daily LDS flow volume will be compared against the measured
cell solution levels detailed on the attached Tables lA and lB, to
determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4A and Cell 4B. Any abnormal or out of
compliance water levels must be immediately reported to Mill
management. The data collector on each cell is also equipped with an
visual strobe light that flashes on the control panel if the water level in the
leak detection sump exceeds the allowable level (5556.14 feet amsl in the
Cell 4A LDS sump and 5558.5 feet amsl in the Cell 4B sump). The
current water level is displayed at all times on each data collector and
available for recording on the daily inspection form. Each leak detection
system is also equipped with a leak detection pump, EPS Model # 25S05-
3 stainless steel, or equal. Each pump is capable of pumping in excess of
25 gallons per minute at a total dynamic head of 50 feet. Each pump has a
1.5 inch diameter discharge, and operates on 460 volt 3 phase power.
Each pump is equipped with a pressure sensing transducer to start the
pump once the level of solution in the leak detection sump is
approximately 2.25 feet (elevation 5555.89 in the Cell 4A LDS sump and
5557.69 feet amsl in the Cell 4B sump) above the lowest level of the leak
detection sump (9 inches [0.75 feet] above the lowest point on the lower
flexible membrane liner for Cell 4A and 2 1/4 inches [0.19 feet] for Cell
4B), to ensure the allowable 1.0 foot (5556.14 feet amsl in the Cell 4A
LDS sump and 5558.5 feet amsl in the Cell 4B sump) above the lowest
point on the lower flexible membrane liner is not exceeded). The attached
Figures 6A and 6B (Cell 4A and 4B, respectively), Leak Detection Sump
Operating Elevations, illustrates the relationship between the sump
elevation, the lowest point on the lower flexible membrane liner and the
pump-on solution elevation for the leak detection pump. The pump also
has manual start and stop controls. The pump will operate until the
solution is drawn down to the lowest level possible, expected to be
approximately 4 inches above the lowest level of the sump (approximate
elevation 5554.0 and 5555.77 ft amsl for Cells 4A and 4B, respectively).
The pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
are recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
perforated section of the PVC collection pipe. The distance from the top
flange face, at the collection pipe invert, to the centerline of the 22.5
degree elbow is 133.4 feet in Cell 4A and 135.6 feet in Cell 4B, and the
vertical height is approximately 45 feet in Cell 4A and approximately 42.5
feet in Cell 4B. The pump is installed at least 2 feet beyond the centerline
of the elbow. The bottom of the pump will be installed in the leak
detection sump at least 135.4 feet in Cell 4A and 137.6 feet in Cell 4B or
more from the top of the flange invert. A pressure transducer installed
within the pump continuously measures the solution head and is
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programmed to start and stop the pump within the ranges specified above.
The attached Figure 5, illustrates the general configuration of the pump
installation.
A spare leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller on either cell can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.
5.3 Slimes Drain System
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe of each cell and a near
as possible to the bottom of the slimes drain sump. The bottom of the
slimes drain sump in Cell 4A and Cell 4B are 38 and 35.9 feet below a
water level measuring point, respectively, at the centerline of the slimes
drain access pipe, near the ground surface level. Each pump discharge
will be equipped with a 2 inch flow meter, E/H Model #33, or equal, that
reads the pump discharge in gallons per minute, and records total gallons
pumped. The flow rate and total gallons will be recorded by the Inspector
on the weekly inspection form.
(ii) The slimes drain pumps will be on adjustable probes that allow the pumps
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A and Cell 4B slimes drain pumps will be checked weekly to
observe that they are operating and that the level probes are set properly,
which is noted on the Weekly Tailings Inspection Form. If at any time
either pump is observed to be not working properly, it will be repaired or
replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A and Cell 4B slimes drain access riser
pipes shall be monitored and recorded weekly to determine maximum and
minimum fluid head before and after a pumping cycle, respectively. All
head measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) After initiation of pumping conditions in Tailings Cell 4A or 4B, n a
quarterly basis, each slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on a Quarterly Data form, by
measuring the depth to water below the water level measuring point on the
slimes drain access pipe;
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The slimes drain pumps for each cell will not be operated until Mill management
has determined that no additional process solutions will be discharged to that cell,
and the cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell 2.
6.0 Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
7 .0 Solution Free board Calculations
The maximum tailings cell pond wastewater levels in Cell 1, Cell 2, Cell 3, Cell 4A, and
Cell 4B are regulated by condition 10.3 of the White Mesa Mill 1 le.(2) Materials
License. However, freeboard limits are no longer applicable to Cell 2, Cell 3, and Cell
4A, as discussed below.
Condition 10.3 states that "Freeboard limits, stormwater and wastewater management for
the tailings cells shall be determined as follows:
A. The freeboard limit for Cell 1 shall be set annually in accordance
with the procedures set out in Section 3.0 to Appendix E of the
previously approved NRC license application, including the
January 10, 1990 Drainage Report. Discharge of any surface water
or wastewater from Cell 1 is expressly prohibited.
B. The freeboard limit for Cell 4B shall be recalculated annually in
accordance with the procedures established by the Executive
Secretary. Said calculations for freeboard limits shall be submitted
as part of the Annual Technical Evaluation Report (ATER), as
described in Condition 12.3 below [of the license and not included
herein]. Based on approved revisions to the DMT Plan dated
January 2011, the freeboard limit is no longer applicable to Cells 2,
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Cell 4A BAT Monitoring, Operations and Maintenance Plan
3 and 4A.
01/21/2010 Revision
Denison 2.2
C. The discharge of any surface water, stormwater, or wastewater
from Cells 3, 4A, and 4B shall only be through an Executive
Secretary authorized spillway structure. [Applicable NRC
Amendment: 16] [Applicable UDRC Amendment: 3] [Applicable
UDRC Amendment:4]"
The freeboard limits set out in Section 6.3 of the DMT Plan are intended to capture the
Local 6-hour Probable Maximum Precipitation (PMP) event, which was determined in
the January 10, 1990 Drainage Report for the White Mesa site to be 10 inches.
Based on the PMP storm event, the freeboard requirement for Cell 1 is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3, 4A, or 4B.
Cells 2 and 3 have no freeboard limit because those Cells are full or near full of tailings
solids. Cell 4A has no freeboard limit because it is assumed that all precipitation falling
on Cell 4A will overflow to Cell 4B. All precipitation falling on Cell 2, 3, and 4A and
the adjacent drainage areas must be contained in Cell 4B. The flood volume from the
PMP event over the Cell 2, 3, and Cell 4A pond areas, plus the adjacent drainage areas,
which must be contained in Cell 4B, is 159.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). For the
purposes of establishing the freeboard in Cell 4B, it is assumed Cell 4A has no freeboard
limit and all of the flood volume from the PMP event will be contained in Cell 4B. The
flood volume from the PMP event over the Cell 4B area is 38.1 acre-feet of water (40
acres, plus the adjacent drainage area of 5.7 acres, times the PMP of 10 inches). This
would result in a total flood volume of 197.5 acre-feet, including the 123.4 acre-feet of
solution from Cells 2 and 3 and 36 acre-feet of solution from Cells 2, 3, and 4A that must
be contained in Cell 4B. The procedure for calculating the freeboard limit for Cell 4B is
set out in the DMT Plan.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for Cells 1, 4A, and 4B but
based on License condition 10.3 and the procedure set out in the DMT Plan, the
freeboard limits for Cells 1, 4A, and 4B will be at least three feet.
Figure 7, Hydraulic Profile Schematic, shows the relationship between the Cells, and the
relative elevations of the solution pools and the spillway elevations.
The required freeboard for Cell 4B will be recalculated annually.
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Cell 4A BAT Monitoring, Operations and Maintenance Plan
8.0 List of Attachments
01/21/2010 Revision
Denison 2.2
1) Figures lA and lB, Initial Filling Plan, Geosyntec Consultants
2) Figure 2A and 2B, Initial Filling Plan, Details and Sections, Geosyntec
Consultants
3) Figure 3A and 3B, Initial Filling Plan, Solution and Slurry Pipeline Routes,
Geosyntec Consultants
4) Figure 4A and 4B, Interim Filling Plan, Geosyntec Consultants
5) Figure 5, Leak Detection System Sumps for Cell 4A and 4B, Geosyntec
Consultants
6) Figure 6A and 6B, Leak Detection Sump Operating Elevations, Geosyntec
Consultants
7) Figure 7, Hydraulic Profile Schematic
8) Cell 4A and Cell 4B Freeboard Calculations
9) Table IA, Calculated Action leakage Rates for Various Head Conditions,
Cell 4A, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
10) Table lB, Calculated Action leakage Rates for Various Head Conditions,
Cell 4B, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
11) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan.
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consultants PROJECT NO. SC0349
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7
Geosyntec Consultants Table 1A
Calcurated Action Leakage Rates for Varlou1 Head Conditions
CeH 4A, White Mesa MIii
BlantUng, Utah
Head Above Uner Calculated Action Lukap Rate
System (feet) (pllans/acre/day)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
Geasyntec Consulta11ts Table 18
Calculated Action Leakage Rates for Various Head Conditrons
Cell 48, WhJte Mesa Mill
Bl;mdins, Utah
Head Above Liner System C'alculated Action Leakage Rate
{feet) (la Hons/acre/day)
s 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
35 570.0
37 581.2
( White Mesa Mill
Operations and Maintenance Plan
Chloroform Pumping System
Revision 2.2
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 21, 2013
Contents
1.0 INTRODUCTION ........................................................................................................ 1
2.0 OPERATIONS .............................................................................................................. 2
2.1 Groundwater Pumping .............................................................................................. 2
2.2 Water Level Monitoring ........................................................................................... 2
2.3 Water Quality Monitoring ......................................................................................... 2
3.0 DEFINITION OF THE PUMPING SYSTEM ............................................................. 3
4.0 WINTERIZA TION FOR LONG-TERM OPERATIONS ............................................ 3
5.0 MAINTANENCE ......................................................................................................... 4
6.0 MONITORING AND REPORTING ............................................................................ 5
1.0 INTRODUCTION
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
The presence of chloroform was initially identified in groundwater at the White Mesa
Mill (the "Mill") as a result of split sampling performed in May 1999. The discovery
resulted in the issuance of State of Utah Notice of Violation ("NOV") and Groundwater
Corrective Action Order ("CAO") State of Utah Department of Environmental Quality
("UDEQ") Docket No. UGW-20-01, which required that Energy Fuels Resources (USA)
Inc. ("EFRI") submit a Contamination Investigation Plan and Report pursuant to the
provisions ofUAC R317-6-6.15(D).
EFRI developed a Corrective Action Plan ("CAP") for the chloroform investigation area.
The CAP specified the removal of chloroform by pumping areas that have higher
concentration of chloroform and high productivity.
Beginning in April of 2003 a long-term pumping test was started in the area of the
chloroform investigation with the pumping from wells MW-4 and TW4-19. Initially the
pump discharge was routed to temporary holding tanks located next to each well. Water
pumped to the tanks was periodically removed and transported to Tailings Cell 1 for
disposal. Later, discharge lines were extended directly to Cell 1.
On August 8, 2003, pumping was started from MW-26 (formerly TW4-15). To date,
water from this well has been routed to Cell 1.
In late November 2003, pumping from all of the wells was stopped suddenly due to the
freezing of the discharge pipelines. The long term pumping test was essentially complete
when the system was shut down in November 2003. Pumping from all three of the wells
was restarted in August of 2004.
After re-start of the pumping, preparations were made to winterize the installations in
order to prevent a re-occurrence of the problems encountered during the winter of 2003.
In August 2005, pumping of well TW4-20 was started and to date, the water from this
well has been pumped to Cell 1.
In January, 2010, pumping was started from TW4-4. Water from this well has also been
routed to Cell 1.
Based on discussions with DRC on February 11, 2013 (documented by e-mail on
February 13, 2012) and March 7, 2013 the requirements to transfer pumped groundwater
to the tailings cells includes pumping and re-use in the Mill process which discharges to
the tailings cells. This Operations and Maintenance Plan (O&M Plan) has been revised
to include transferring pumped groundwater to the Mill process followed by discharge to
the tailings cells.
1
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
This operations and maintenance plan is required for all pumping wells approved by the
Director associated with the chloroform pumping system.
2.0 OPERA TIO NS
2.1 Groundwater Pumping
Wells MW-04, MW-26, TW4-04, TW4-19, and TW4-20, will be pumped at the
maximum practical rates. Pumped water will be disposed in the tailings cells or may be
used for the Mill process water. The wellfield will be maintained as noted herein.
Monitoring will include pumping rates and volumes for each well. Monitoring will be
documented on the Weekly Inspection Form included as Attachment A to this O&M
Plan.
2.2 Water Level Monitoring
Water level monitoring will consist of weekly water level monitoring of pumping wells
MW-04, MW-26, TW4-04, TW4-19, and TW4-20 and monthly water level monitoring in
all chloroform program wells. Water level monitoring will be documented on the
Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A
and B to this O&M Plan. Water level contour maps of the data will be generated
quarterly.
2.3 Water Quality Monitoring
Water quality monitoring for all wells in the chloroform program will be quarterly.
Samples will be analyzed for Volatile chloroform, dichloromethane, chloromethane, and
carbon tetrachloride, nitrogen (nitrate and nitrite as N) and chloride. Field parameters will
be recorded during the sampling as described in the Mill's DRC-approved Groundwater
Quality Assurance Plan ("QAP"). Water quality monitoring will be reported and
documented in the quarterly reports submitted as described in Section 5.0 of this O&M
Plan. Water quality monitoring for the foregoing constituents and field parameters for all
other wells at the site will continue at the frequency required under the Groundwater
Discharge Permit ("GWDP") or nitrate program, as applicable.
2
(
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
3.0 DEFINITION OF THE PUMPING SYSTEM
The pumping system used for the chloroform program is defined as follows:
• Structure of the pumping wells including: well casing, well slotted screen casing,
sand/gravel pack, bentonite seal, cement grout seal, protective steel surface
casing;
• Pump
• All structural materials that hold the pump in place;
• Electrical power for the pump and well heat lamps;
• Electrical wiring to the pump and well head heat lamps;
• All hosing, piping, and associated hose and pipe fittings from the pump, including
sampling ports, to discharge hose at the tailings cells;
• Temporary water storage tanks;
• Protective boxes over the well heads lined with insulating foam.
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS
The following actions are implemented to provide continuous operations of the pumping
well system at the White Mesa Mill during cold weather conditions.
1) Protective boxes are placed around the wellheads of the five (5) pumping
wells. The protective boxes are lined with insulating foam and heat lamps
are installed to ensure that the interior of the box is maintained at a
temperature above freezing during the winter months. Winter months are
generally defined as the months of November through March, but
winterization of the pumping wells is maintained at any time the outside
air temperature is forecast to fall below 20° F for a duration of one (1) day
or more.
2) The pump discharge from each of the pumping wells is connected to a 2-
inch polypropylene drain line, which discharges to the Mill process or the
tailings cells. Lines are protected from freezing by covering them with a
minimum of 3 feet of soil to prevent freezing during the winter months.
3) During winter weather with potentially freezing conditions (i.e. less than
20°F), the radiation safety department staff, observe the pumping daily to
ensure that the heat lamps remain functional. The Mill maintenance
department is immediately notified if anything unusual is noted with the
system, or if a specific well has encountered a problem.
3
(
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
4) The protective features, discharge line placement and winter inspections
described in items 1 ), 2), or 3) above will apply to not only the (5)
pumping wells currently in operation, but will apply also to any future
pumping wells associated with the chloroform pumping system.
5.0 MAINTANENCE
The operation of each of the pumping wells is monitored on a daily basis during the
winter under potentially freezing conditions by the Environmental Health and Safety
Department. Any malfunction or abnormal operation of the pumping wells is
immediately reported to the Environmental Health and Safety Department.
Environmental Health and Safety Department personnel will periodically inspect the
pumps, flow meters and operational controls and perform preventative maintenance to
reduce the frequency of unscheduled down time of the pumping system. Spare pumps
are maintained in the Mill warehouse. If a pump is replaced in any of the wells a new
spare is promptly ordered. When a system failure occurs and is not repaired and fully
made operational within 24 hours of discovery, DUSA shall call the Director or the
Director's staff, to verbally report the system failure and will report to the Director in a
written report within 5 days of the failure. A system failure is defined as any downtime
of a system component (as described in Section 3.0) that (a) causes cessation of the
pumping of groundwater from the designated pumping wells, and (b) the pumping of
groundwater from the designated pumping well is not restored and fully made operational
within 24 hours of discovery of the system failure. A failure of any system component
which does not cause the cessation of pumping of groundwater from the designated
pumping wells or where pumping of groundwater from the designated pumping well is
restored and fully made operational within 24 hours of discovery, will not be considered
a failure that is reportable under this requirement. For example, and without limiting the
generality of the foregoing, a failure of a component that can be rectified by re-routing
the pumped water from the tailings to the Mill process or vice versa, or by transporting
the pumped water via portable tank rather than pipeline, and which does not cause the
pumping activities to be halted for more than 24-hours, would not be considered a
reportable system failure.
Each written submission shall contain the following information:
a) A description of the pumping system failure(s) and their root causes
b) The period of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational;
d) Steps taken or tha:t will be taken to repair and have the system fully
operational;
e) Steps taken or that will be taken to eliminate and prevent reoccurrence of
system failure (s)
4
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
f) Each system failure and corrective actions, listed above, will be summarized
in the corresponding quarterly chloroform groundwater monitoring reports.
In addition, all system failures will be reported in the following quarterly chloroform
groundwater monitoring report.
6.0 MONITORING AND REPORTING
Monitoring of the system by the Mill's Environmental Health and Safety Department
occurs weekly and includes well depths, flow rates, pump operating times and gallons
pumped. These items are recorded on a weekly basis on the Weekly Inspection Form
included as Attachment A.
On a quarterly basis, all chloroform investigation wells are sampled for chloroform,
nitrate+nitrite, dichloromethane, chloromethane, chloride and carbon tetrachloride.
These data, including copies of chain of custody forms and laboratory analytical reports,
are reported to the DRC concurrent with the schedule for submission of Quarterly
Groundwater Monitoring Reports, and according to the following schedule.
First Quarter -June 1
Second Quarter -September 1
Third Quarter -December 1
Fourth Quarter -March 1
In addition to the quarterly sampling information, the following information regarding the
chloroform pumping system, is included in the quarterly reports:
1) Description of the pumping operations including any operational problems
encountered during the quarter.
2) Flow rates and total gallons pumped for the quarter.
3) Historical gallons pumped to date.
4) Updated water level contour map for the site indicating cones of depression
from the pumping and an evaluation of the potential of the pumping to
hydraulically capture the chloroform plume.
5) Any additions, modifications or observations during the quarter.
6) Suggestions for changes or modifications to the pumping system.
7) Weekly Inspection Form.
5
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
ATTACHMENT A
Weekly Inspection Form
Date
Weekly Inspection Form
Name
Time Well Depth* Comments
MW-4 Flow
Meter
MW-26 Flow
Meter
TW4-19 Flow
Meter
TW4-20 Flow
Meter
TW4-4 Flow
Meter
TWN-2 Flow
Meter
TW4-22 Flow
Meter
TW4-24 Flow
Meter
TW4-25 Flow
Meter
TW4-1 Flow
Meter
TW4-2 Flow
Meter
TW4-11 Flow
Meter
TW4-21 Flow
Meter
TW4-37 Flow
Meter
TW4-39 Flow
Meter
TW4-41 Flow
Meter
Operational Problems (Please list well number):
Corrective Action(s) Taken (Please list well number):
* Depth is measured to the nearest 0.01 feet.
System Operational (If no note
anv problems/corrective actions)
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
(
Monthly Depth Check Form
Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
ATTACHMENTB
Monthly Depth Check Form
Date Name
Time Well Depth* Time Well Depth*
MW-4 TWN-1
TW4-1 TWN-2
TW4-2 TWN-3
TW4-3 TWN-4
TW4-4 TWN-7
TW4-5 TWN-18
TW4-6 MW-27
TW4-7 MW-30
TW4-8 MW-31
TW4-9
TW4-10
TW4-11
TW4-12
TW4-13 TW4-28
TW4-14 TW4-29
TW4-15 TW4-30
TW4-16 TW4-31
TW4-17 TW4-32
TW4-18 TW4-33
TW4-19 TW4-34
TW4-20 TW4-35
TW4-21 TW4-36
TW4-22 TW4-37
TW4-23 TW4-38
TW4-24 TW4-39
TW4-25 TW4-40
TW4-26 TW4-41
TW4-27
Comments: (Please note the well number for any comments)
* Depth is measured to the nearest 0.01 feet
White Mesa Mill -Standard
Operating Procedures
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 1 of 15
WIDTE MESA URANIUM MILL
CONTINGENCY PLAN
As Contemplated by Part I.G.4(d)
of
State of Utah Groundwater Discharge Permit No.UGW370004
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver CO 80265
December 2, 2010
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
TABLE OF CONTENTS
Date: 12/11 Revision: DUSA-4
Page 2 of 15
1.0 INTRODUCTION ................................................................................................... 3
2.0 PURPOSE ................................................................................................................ 3
3.0 GROUNDWATER CONTAMINATION ............................................................... 3
3.1 Notification ........................................................................................................... 4
3.2 Continuation of Accelerated Monitoring ............................................................. 4
3 .3 Submission of Plan and Timetable ....................................................................... 4
3.4 Groundwater Remediation Plan ........................................................................... 5
4.0 MILL DISCHARGE VIOLATIONS -INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONT AMIN ANTS TO THE
TAILING CELLS ............................................................................................................... 6
4.1 Notifications ......................................................................................................... 6
4.2 Field Activities ..................................................................................................... 6
4.3 Request for Approvals and/or Waivers ................................................................ 7
5.0 DMT VIOLATIONS ............................................................................................... 7
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations ....... 7
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems .............. 8
5.3 Excess Cell 4A Leak Detection System Fluid Head or Daily Leak Rate ............ 9
5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate ........... 10
5.5 Excess New Decontamination Pad Leak Detection System Fluid Head ........... 11
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad .... 11
5.7 Excess Elevation For Tailings Solids ................................................................. 12
5.8 Roberts Pond Wastewater Elevation .................................................................. 13
5.9 Feedstock Storage Area ...................................................................................... 13
5 .10 Mill Site Chemical Reagent Storage .............................................................. 14
5.11 Failure to Construct as per Approval.. ............................................................ 15
5.12 Failure to Comply with Stormwater Management and Spill Control
Requirements ................................................................................................................ 15
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 3 of 15
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No. UGW370004
1.0 INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
"GWDP") for Denison Mines (USA) Corp.'s ("Denison's") White Mesa Uranium Mill
(the "Mill"). The GWDP specifies the construction, operation, and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into the underlying aquifer.
2.0 PURPOSE
This Contingency Plan (the "Plan") provides a detailed list of actions Denison will take to
regain compliance with GWDP limits and Discharge Minimization Technology Plan
("DMT") and the Best Available Technology Plan ("BAT") requirements defined in Parts
LC, LD, and LH.4 of the GWDP. The timely execution of contingency and corrective
actions outlined in this Plan will provide Denison with the basis to exercise the
Affirmative Action Defense provision in Part I.G.3.c) of the GWDP and thereby avoid
noncompliance status and potential enforcement action 1•
The contingency actions required to regain compliance with GWDP limits and DMT and
BAT requirements defined in Parts LC, LD, and I.H.4 of the GWDP are described below.
3.0 GROUNDWATER CONTAMINATION
Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
1 Part I.G.3.c) of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications, that the failure was
not intentional or caused by Denison's negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions of UCA 19-5-107 have not been violated.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 4 of 15
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to Part I.G.2 of the GWDP.
When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:
3.1 Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part I.G.4.a) of the GWDP.
3.2 Continuation of Accelerated Monitoring
Denison will continue accelerated sampling for the parameter in that compliance
monitoring well pursuant to Part I.G.1 of the GWDP, unless the Executive Secretary
determines that other periodic sampling is appropriate, until the facility is brought into
compliance, as required under Part I.G.4.b) of the GWDP.
If the accelerated monitoring demonstrates that the monitoring well has returned to
compliance with respect to a parameter in a well, then, with written approval from the
Executive Secretary, Denison will cease accelerated monitoring for that parameter, and
will continue routine monitoring for that parameter.
3.3 Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT or
BAT will be reestablished, as required under part I.G.4.c) of the GWDP. This plan will
normally include, but is not limited to:
a) The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 5 of 15
b) A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
c) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
contamination. This will normally include a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone, the analytical parameters to be obtained, the
samples of ground water to be taken, and any other means to measure and
characterize the affected ground water and contamination zone; and
d) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions
to restore and maintain groundwater quality to ensure that permit limits will not
be exceeded at the compliance monitoring point and that DMT and BAT will be
reestablished, as well as actions that merely allow natural attenuation to operate
and actions that involve applying for Alternate Concentration Limits ("ACLs").
ACLs require approval of the Water Quality Board prior to becoming effective.
If groundwater remediation is required, Denison will prepare and submit for
Executive Secretary approval a Ground Water Remediation Plan, as described in
Section 3.4 below.
3.4 Groundwater Remediation Plan
If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary. The Ground Water Remediation Plan will
normally include, but is not limited to:
a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s) or other locations
approved by the Executive Secretary, by removing the contaminants, treating
them in place, or by other means as approved by the Executive Secretary;
b) A description of the remediation monitoring program to demonstrate the
effectiveness of the plan; and
c) Descriptions of how corrective action will apply to each source of the pollution.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 6 of 15
Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.
4.0 MILL DISCHARGE VIOLATIONS -INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS
Part I.C.2. of the GWDP provides that only 1 le.(2) by-product material authorized by the
Mill's State of Utah Radioactive Materials License No. UT-2300478 (the "Radioactive
Materials License") shall be discharged to or disposed of in the Mill's tailings cells.
Part I.C.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as 1 le.(2) material is prohibited.
In the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials") to the Mill's tailings cells, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
4.1 Notifications
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery.
4.2 Field Activities
a) Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
b) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill
personnel will nevertheless mark or record the location of the Unauthorized
Materials in the tailings cells;
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Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 7 of 15
c) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from
the tailings cells; and
d) Denison will dispose of the removed Unauthorized Material under applicable
State and Federal regulations with the approval of the Executive Secretary.
4.3 Request for Approvals and/or Waivers
If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will, in accordance with a schedule to be approved by the
Executive Secretary:
a) Submit a written report to the Executive Secretary analyzing the health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
b) Apply to the Executive Secretary for any amendments that may be required to
the GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health, safety and the environment; and
c) Make all applications required under the United States Nuclear Regulatory
Commission's ("NRC's") Non-lle.(2) Disposal Policy (NRC Regulatory Issue
Summary 2000-23 (November 2000), Interim Guidance on Disposal of Non-
Atomic Energy Act of 1954, Section 11 e.(2) Byproduct Material in Tailings
Impoundments), including obtaining approval of the Department of Energy as
the long term custodian of the Mill's tailings, in order to obtain approval to
permanently dispose of the Unauthorized Material in the Mill's tailings cells.
5.0 DMT VIOLATIONS
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations
Part I.D.2 and Part I.D.6.d) of the GWDP provide that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorized by the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet, as measured from the top of the flexible
membrane liner ("FML").
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Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 8 of 15
In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirements of the Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Upon discovery, Mill personnel will cease to discharge any further tailings to
the subject tailings cell, until such time as adequate freeboard capacity exists in
the subject tailings cell for the disposal of the tailings;
d) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly pump
fluids from the subject tailings cell to another tailings cell until such time as the
freeboard limit for the subject tailings cell is in compliance. If there is no room
available in another tailings cell, without violating the freeboard limit of such
other cell, then, as soon as reasonably practicable, Mill personnel will cease to
discharge any further tailings to any tailings cell until such time as adequate
freeboard capacity exists in all tailings cells;
e) If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject
tailings cell will be reduced through natural evaporation; and
f) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems
Part I.D.3.b)l) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable, in accordance with the Mill's currently approved DMT Monitoring Plan, and
that for Cell 3, this requirement shall apply only after initiation of de-watering operations.
Similarly, Part I.D.6.c) of the GWDP provides that after Denison initiates pumping
conditions in the slimes drain layer in Cell 4A, Denison will provide: 1) continuous
declining fluid heads in the slimes drain layer, in a manner equivalent to the requirements
found in Part I.D.3.b); and 2) a maximum head of 1.0 feet in the tailings (as measured
from the lowest point of the upper FML) in 6.4 years or less.
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Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 9 of 15
In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
after initiation of de-watering activities, Cell 3 or initiation of pumping conditions in the
slimes drain layer in Cell 4A exceeds the levels specified in the DMT Monitoring Plan,
Denison will, subject to any specific requirements of the Executive Secretary as set forth
in any notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to minimize the chance of a recurrence.
5.3 Excess Cell 4A Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.6.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
4A shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.6.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4A shall not exceed 24,160 gallons/day.
In the event that the fluid head in the LDS for Cell 4A exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4A LDS
exceeds 24,160 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
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Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/l l Revision: DUSA-4
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c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to remediate the exceedance and to minimize the chance of
a recurrence.
5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.13.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
4B shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.13.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4B shall not exceed 26,145 gallons/day.
In the event that the fluid head in the LDS for Cell 4B exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4B LDS
exceeds 26,145 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
If not due to an identified equipment failure, Denison will perform a root cause analysis
of the exceedance and will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
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Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
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5.5 Excess New Decontamination Pad Leak Detection System Fluid Head
In order to ensure that the primary containment of the New Decontamination Pad water
collection system has not been compromised, and to provide an inspection capability to
detect leakage from the primary containment in each of the three settling tanks, a vertical
inspection portal has been installed between the primary and secondary containment of
each settling tank.
Section 3.l(e) of the Mill's DMT Monitoring Plan provides that the fluid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete floor in
any of the three standpipes. Compliance is defined in Part I.D.14 a) of the GWDP as a
depth to standing water present in any of the LDS access pipes of more than or equal to
6.2 feet as measured from the water measuring point (top of access pipe).
In the event that the fluid head in the standpipe for a settling tank exceeds 0.10 feet above
the concrete floor in the standpipe, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within the
ensuing 24 hours followed by a written notification within five days;
c) Mill personnel will promptly pump the fluid from the settling tank's LDS as
well as the fluids in the settling tank into another settling tank or into an active
tailings cell, or other appropriate containment or evaporation facility approved
by the Executive Secretary, until such time as the cause of the exceedance is
rectified or until such time as otherwise directed by the Executive Secretary; and
d) Denison will perform a root cause analysis of the exceedance and, if
appropriate, will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad.
Soil and debris will be removed form the wash pad of the NDP in accordance with the
currently approved DMT Monitoring Plan. In the event that cracks of greater than 1/8
inch (width) are observed on the concrete wash pad, Deni on will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following proces :
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 12 of 15
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) The NDP shall be taken out of service and the cracks will be repaired utilizing
industry standard materials and procedures appropriate for the defect within five
working days of discovery. Following recommended cure times, the cracks or
deficiencies will be re-inspected and, if acceptable, the NDP will be placed back
into service.
c) A record of the repairs will be maintained as a part of the inspection records at
the White Mesa Mill.
5.7 Excess Elevation For Tailings Solids
Part I.D.3.c) of the GWDP provides that upon closure of any tailings cell, Denison shall
ensure that the maximum elevation of the tailings waste solids does not exceed the top of
the FML.
In the event that, upon closure of any tailings cell, the maximum elevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly remove
tailings solids from the subject tailings cell to another tailings cell, or other
location approved by the Executive Secretary, until such time as the maximum
elevation of the tailings waste solids in the subject tailings cell does not exceed
the top of the FML; and
d) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
5.8 Roberts Pond Wastewater Elevation
Date: 12/11 Revision: DUSA-4
Page 13 of 15
Part I.D.3.e) of the GWDP provides that the Permittee shall operate Roberts Pond so as to
provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Cell 1 within 72
hours of discovery, as specified in Part I.D.3.e) of the GWDP.
In the event that, Denison fails to remove the excess wastewater within 72 hours of
discovery, Denison will, subject to any specific requirements of the Executive Secretary
as set forth in any notice, order, remediation plan or the equivalent, implement the
following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.9 Feedstock Storage Area
Part I.D.3.f) and Part I.D.11 of the GWDP provide that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
eastern portion of the Mill site area described in Table 4 of the GWDP, and that storage
of feedstock materials at the facility outside that area shall be performed in accordance
with the provisions of Part I.D.11 of the GWDP.
In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.f) and Part I.D.11 of the GWDP, Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Mill personnel will:
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 14 of 15
(i) move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
(ii) ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in
accordance with the provisions of Part I.D.11 of the GWDP; and
(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers or
otherwise dealt with in accordance with the provisions of Part I.D.11 of
the GWDP, and any impacted soils will be removed and will be deposited
into the Mill's active tailings cell; and
d) Denison will perform a root cause analysis of the non-compliant activity and
will implement new procedures or change existing procedures to minimize the
chance of a recurrence.
5.10 Mill Site Chemical Reagent Storage
Part I.D.3.g) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction of reagent storage facilities, the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.
In the event that Denison fails to provide the required secondary containment required
under Part I.D.3.g) of the GWDP, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and
c) Denison will promptly remediate any spilled re-agent resulting from the failure
to provide the required secondary containment under Part I.D.3.g) of the
GWDP, by removal of the contaminated soil and disposal in the active tailings
cell.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
5.11 Failure to Construct as per Approval
Date: 12/11 Revision: DUSA-4
Page 15 of 15
Part I.D.4 of the GWDP provides that any construction, modification, or operation of new
waste or wastewater disposal, treatment, or storage facilities shall require submittal of
engineering design plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.
In the event that, any new waste or wastewater disposal, treatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.12 Failure to Comply with Stormwater Management and Spill Control Requirements
Part I.D.10 of the GWDP provides that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the Mill facility in accordance with the
currently approved Stormwater Best Management Practices Plan.
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Stormwater Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery; and
c) To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill's approved Stormwater Best
Management Practices Plan. To the extent it is no longer practicable to so
manage any such spill, Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
(
White Mesa Mill
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2. 0
State of Utah
Stipulation and Consent Order Docket Number UGW12-04
Prepared by:
Energy Fuels Resoul'Ces (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 21, 2013
Table of Contents
1.0 INTRODUCTION ................................................................................................ 1
2.0 OPERATIONS ........................................................................................................... 2
2.1 Groundwater Pumping ........................................................................................... 2
2.2 Water Level Monitoring ......................................................................................... 2
2.3 Water Quality Monitoring ....................................................................................... 2
3.0 DEFINITION OF THE PUMPING SYSTEM ........................................................... 2
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS ........................................... 3
5.0 MAINTENANCE ...................................................................................................... 3
6.0 MONITORING AND REPORTING .......................................................................... 4
i
i \
1.0 INTRODUCTION
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
The Utah Department of Environmental Quality ("UDEQ") Division of Radiation Control
("DRC") noted in a Request dated September 30, 2008 (the "Request"), for a Voluntary Plan and
Schedule to Investigate and Remediate Nitrate Contamination at the White Mesa Uranium Mill
(the "Mill") (the "Plan"), that nitrate levels have exceeded the State water quality standard of 10
mg/L in certain monitoring wells in the perched groundwater zone. As a result of the Request,
Energy Fuels Resources (USA) Inc. ("EFRI") entered into a Stipulated Consent Agreement (the
"Consent Agreement") with the Utah Water Quality Board in January 2009 which directed the
preparation of a Nitrate Contamination Investigation Report ("CIR"). A subsequent letter dated
December 1, 2009, among other things, recommended that EFRI also address elevated chloride
concentration in the CIR. The Consent Agreement ("CA") was amended in August 2011. Under
the amended Consent Agreement, EFRI submitted a Corrective Action Plan ("CAP"), pursuant
to the requirements of the Utah Groundwater Quality Protection Rules [UAC R317-6-6.15(C -
E)] on November 29, 2011 and revised versions of the CAP on February 27, 2012 and May 7,
2012. On December 12, 2012, DRC signed the Stipulation and Consent Order ("SCO"), Docket
Number UGW12-04, which approved the EFRI CAP, dated May 7, 2012. The SCO ordered
EFRI to fully implement all elements of the May 7, 2012 CAP.
The CAP addresses nitrate+ nitrite (as nitrate) (heretofore referred to as "nitrate") contamination
in the shallow perched groundwater zone at the Mill site. It should be noted that while the CAP
requires monitoring of chloride concentrations, the CAP does not specify measures for
controlling chloride levels per se, because there is no health standard for chloride in
groundwater. However, as discussed and agreed to with DRC during meetings in October 2011,
chloride appears to be co-located with-nitrate in groundwater at the Mill and hydrogeological
measures to contain nitrate will also contain chloride.
The CAP describes a phased approach to the nitrate corrective actions. The Phases described in
the CAP are as follows:
• Phase I will involve source control in the vicinity of the Mill's ammonium sulfate tanks,
• Phase II will involve active remediation of the nitrate contamination. The active
remediation will be accomplished by pumping contaminated water, into the Mill's
tailings cells for disposal or into the Mill as process water, combined with monitored
natural attenuation,
• Phase III, if necessary, will be at the discretion of EFRI and would involve a long term
solution for the nitrate contamination, in the event that the continuation of Phase 1I is not
considered adequate or appropriate.
Phases I and II are addressed in the CAP and will commence as required by the schedule
delineated in the CAP. Phase III is not covered in detail in the CAP and, if determined to be
necessary, will be addressed in a separate CAP revision.
1
Operations and Maintenance ·Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
This Operations and Maintenance ("O&M") Plan has been prepared to meet the requirements of
Phase II as described in the CAP, Section 7.2.2 to address operations (including winterization
procedures), maintenance (including inspection forms and response to and documentation of
system failures), monitoring and data reporting.
2.0 OPERATIONS
2.1 Groundwater Pumping
Wells TW4-22, TW4-24, TW4-25, and TWN-2 will be pumped at the maximum practical rates.
Pumped water will be disposed in the tailings cells or may be used for the Mill process water.
The wellfield will be maintained as noted herein. Monitoring will include pumping rates and
volumes for each well. Monitoring will be documented on the Weekly Inspection Form included
as Attachment A to this O&M Plan.
2.2 Water Level Monitoring
Water level monitoring will consist of weekly water level monitoring of pumping wells TW4-22,
TW4-24, TW4-25, and TWN-2, and, for the first twelve months after approval of the CAP,
monthly water level monitoring of non-pumped wells MW-27, MW-30, MW-31, TW4-21,
TWN-1, TWN-3, TWN-4, TWN-7, and TWN-18. Thereafter, water level monitoring of the non-
pumping wells will continue quarterly. Water level monitoring will be documented on the
Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A and B
to this O&M Plan. Water level contour maps of the data will be generated quarterly. ·
2.3 Wate1· Quality Monitoring
Water quality monitoring for pumped wells TW4-22, TW4-24, TW4-25, and TWN-2 will be
quarterly. Samples will be analyzed for nitrogen (nitrate and nitrite as N) and chloride. Field
parameters will be recorded during the sampling as described in the Mill's DRC-approved
Groundwater Quality Assurance Plan ("QAP"). Water quality monitoring will be reported and
documented in the quarterly nitrate reports submitted as described in Section 5.0 of this O&M
Plan. Water quality monitoring for nitrate, chloride, and field parameters for all other wells at the
site will continue at the frequency required under the Grou11dwater Discharge Permit ("GWDP")
or chloroform investigation, as applicable.
3.0 DEFINITION OF THE PUMPING SYSTEM
The pumping system used for Phase II is defined as follows:
• Structure of the pumping wells including: well casing, well slotted screen casing,
sand/gravel pack, bentonite seal, cement grout seal, protective steel surface casing;
• Pump
2
• All structural materials that hold the pump in place;
• Electrical power for the pump and well heat lamps;
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
• Electrical wiring to the pump and well head heat lamps;
• All hosing, piping, and associated hose and pipe fittings from the pump, including
sampling ports, to discharge hose at the tailings cells;
• Temporary water storage tanks;
• Protective boxes_ over the well heads lined with insulating foam.
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS
The following actions are implemented to provide continuous operations of the pumping well
system at the White Mesa Mill during cold weather conditions.
1) Protective boxes are placed around the wellheads of the pumping wells. The
protective boxes are lined with insulating foam and heat lamps are installed to
maintain the interior of the box at a temperature above freezing during the winter
months. Winter months are generally defined as the months of November
through March, but winterization of the pumping wells is maintained at any time
the outside air temperature is forecast to fall below 20° F for a duration of one (1)
day or more.
2) The pump discharge from each of the pumping wells is connected to a 2-inch
polypropylene drain line, which qischarges to the Mill process or to the tailings
cells 1. Lines are protected from freezing by covering them with a minimum of 3
feet of soil to prevent freezing during the winter months.
3) During winter weather with potentially freezing conditions (i.e less than 20°F),
the radiation safety department staff observe the pumping daily to verify that the
heat lamps remain functional. The Mill maintenance department is immediately
notified if anything unusual is noted with the system, or if a specific well has
encountered a problem.
4) The protective features, discharge line placement and winter inspections described
in items 1), 2), or 3) above will apply to not only the pumping wells currently in
operation, but will apply also to any future pumping wells associated with the
nitrate pumping system.
5.0 MAINTENANCE
The operation of each of the pumping wells is monitored on a daily basis during the winter under
potentially freezing conditions by the Environment, Health and Safety Department. Any
malfunction or abnormal operation of the pumping wells is immediately reported to the
Environment, Health and Safety Manager. Environment, Health and Safety Department
3
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
personnel will periodically inspect the pumps, flow meters and operational controls and perform
preventative maintenance to reduce the frequency of unscheduled down time of the pumping
system. Spare pumps are maintained in the Mill warehouse. If a pump is replaced in any of the
wells a new spare is promptly ordered. When a system failure occurs and is not repaired and
fully made operational within 24 hours of discovery, EFRI will call the Director of the Division
of Radiation Control ("Director"), or the Director's staff, to verbally report the system failure
and will report to the Director in a written report within 5 days of the failure. A system failure is
defined as any downtime of a system component (as described in Section 3.0) that (a) causes
ce~ation of the pumping of groundwater from the designated pumping wells, and (b) the
pumping of groundwater from the designated pumping well is not restored and fully made
operational within 24 hours of discovery of the system failure. A failure of any system
component which does not cause the cessation of pumping of groundwater from the designated
pumping wells or where pumping of groundwater from the designated pumping well is restored
and fully made operational within 24 hours of discovery, will not be considered a failure that is
reportable under this requirement. For example, and without limiting the generality of the
foregoing, a failure of a component that can be rectified by re-routing the pumped water from the
tailings to the Mill process or vice versa, or by transporting the pumped water via portable tank
rather than pipeline, and which does not cause the pumping activities to be halted for more than
24-hours, would not be considered a reportable system failure.
Each written submission shall contain the following information:
a) A description of the pumping system failure(s) and their root causes
b) The period of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational;
d) Steps taken or that will be taken to repair and have the system fully operational;
e) Steps taken or that will be taken to eliminate and prevent reoccurrence of system
failure (s)
In addition, all system failures will be reported in the next quarterly nitrate monitoring report.
6.0 MONITORJNG AND REPORTING
Monitoring of the system by the Mill's Environment, Health and Safety Department occurs
weekly other than as noted above except for cold weather checks which are done daily during
freezing weather. Monitoring includes well depths, flow rates, pump operating times and gallons
pumped. These items are recorded on a weekly basis on the Weekly Inspection Report included
as Attachment A to this Plan.
On a quarterly basis, the nitrate investigation wells designated in the CAP are sampled for nitrate
and chloride. These data, including copies of chain of custody forms and laboratory analytical
reports are included in the Quarterly Nitrate Reports, and are reported to the DRC according to
the following schedule.
4
(
First Quarter -June 1
Second Quarter -September 1
Third Quarter -December 1
Fourth Quarter -March 1
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
In addition to the quarterly sampling information, the nitrate pumping system information
specified in the CAP will be included in the quarterly reports.
5
Date
· Weekly Inspection Form
Name
Time Well Depth* Comments
MW-4 Flow
Meter
MW-26 Flow
Meter
TW4-19 Flow
Meter
TW4-20 Flow
Meter
TW4-4 Flow
Meter
TWN-2 Flow
Meter
TW4-22 Flow
Meter
TW4-24 Flow
Meter
TW4-25 Flow
Meter
TW4-1 Flow
Meter
TW4-2 Flow
Meter
TW4-11 Flow
Meter
TW4-21 Flow
Meter
TW4-37 Flow
Meter
TW4-39 Flow
Meter
TW4-41 Flow
Meter
Operational Problems (Please list well number):
Corrective Action(s) Taken (Please list well number):
* Depth is measured to the nearest 0.01 feet.
System Operational (If no note
anv problems/corrective actions)
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Monthly Depth Check Form
Date Name
Time Well Depth* Time Well Depth*
MW-4 TWN-1
TW4-1 TWN-2
TW4-2 TWN-3
TW4-3 TWN-4
TW4-4 TWN-7
TW4-5 TWN-18
TW4-6 MW-27
TW4-7 MW-30
TW4-8 MW-31
TW4-9
TW4-10
TW4-11
TW4-12
TW4-13 TW4-28
TW4-14 TW4-29
TW4-15 TW4-30
TW4-16 TW4-31
TW4-17 TW4-32
TW4-18 TW4-33
TW4-19 TW4-34
TW4-20 TW4-35
TW4-21 TW4-36
TW4-22 TW4-37
TW4-23 TW4-38
TW4-24 TW4-39
TW4-25 TW4-40
TW4-26 TW4-41
TW4-27
Comments: {Please note the well number for any comments)
* Depth is measured to the nearest 0.01 feet
Mill -Groundwater Discharge Permit
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Date: 08-22-2019 Revision 7.6
Quality Assurance Plan (QAP)
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN (QAP)
State of Utah
Groundwater Discharge permit No. UGW370004
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Page 1 of60
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Page 2 of60
TABLE OF CONTENTS
1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2.2 Overall Responsibility For the QA/QC Program 6
2.3 Data Requestors/Users 6
2.4 Data Generators 7
2.4.1 Sampling and QC Monitors 7
2.4.2 Analysis Monitor 8
2.4.3 Data Reviewers/Approvers 8
2.5 Responsibilities Of Analytical Laboratory 8
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 9
3.1 Precision 9
3.2 Accuracy 10
3.3 Representativeness 10
3.4 Completeness 10
3.5 Comparability 11
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11
4.1 Controlling Well Contamination 11
4.2 Controlling Depth to Groundwater Measurements 11
4.3 Water Quality QC Samples 11
4.3.1 VOC Trip Blanks 11
4.3.2 Equipment Rinsate Samples 11
4.3.3 Field Duplicates 12
4.3.4 Definition of "Batch" 12
5.0 CALIBRATION 12
5.1 Depth to Groundwater Measurements 12
5.2 Water Quality 12
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6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 12
6.1 Groundwater Head Monitoring 12
6.1.1 Location and Frequency of Groundwater Head Monitoring 13
6.1.2 Groundwater Head Monitoring Frequency 13
6.2 Ground Water Compliance Monitoring 13
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 13
6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.l.b) or I.E.l.c) of the GWDP 14
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G. l or I.G.2 of the GWDP 14
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 14
6.2.5 Decontamination Procedure 15
6.2.6 Pre-Purging/ Sampling Activities 15
6.2.7 Well Purging/Measurement of Field Parameters 15
6.2.8 Samples to be taken and order of taking samples 15
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 16
7.1 Field Data Worksheets 16
7.2 Chain-Of-Custody and Analytical Request Record 17
7 .3 Record Keeping 18
8.0 ANALYTICAL PROCEDURES AND QA/QC 18
8.1 Analytical Quality Control 18
8.1.2 Spikes, Blanks and Duplicates 19
8.2 Analytical Laboratory Procedures 20
9.0 INTERNAL QUALITY CONTROL CHECKS 25
9.1 Field QC Check Procedures 25
9 .1.1 Review of Compliance With the Procedures Contained in this QAP 25
9.1.2 Analyte Completeness Review 25
9.1.3 Blank Comparisons 25
9.1.4 Duplicate Sample Comparisons 26
9.2 Analytical Laboratory QA Reviews 27
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 27
9.4 Analytical Data 28
10.0 CORRECTIVE ACTION 29
10.1 When Corrective Action is Required 29
10.2 Procedure for Corrective Action 29
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11.0 REPORTING 30
12.0 SYSTEM AND PERFORMANCE AUDITS 31
12.1 QA Manager to Perform System Audits and Performance Audits 31
12.2 System Audits 31
12.3 Performance Audits 32
12.4 Follow-Up Actions 32
12.5 Audit Records 32
13.0 PREVENTIVE MAINTENANCE 32
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC Reporting
14.2 Periodic Reporting to Management
15.0 AMENDMENT
16.0 REFERENCES
33
33
33
33
34
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ATTACHMENTS
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Attachment 1 Field and Data Forms
Attachment 1-1 Quarterly Depth to Water Data Sheet
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example Field Data Report
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures
Attachment 2-2 Decontamination Procedures
Attachment 2-3 Purging Procedures
Attachment 2-4 Sample Collection Procedures
Attachment 2-5 Field QC Samples
APPENDICES
Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa
Uranium Mm Blanding Utah
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1.0 INTRODUCTION
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Page 6 of60
This Groundwater Monitoring Quality Assurance Plan (the "QAP") details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental
analytical laboratories, data validation, and sampling and other corrective actions necessary to
comply with UAC R317-6-6.3(1) and (L) at the White Mesa Uranium Mill (the "Mill"), as
required by the State of Utah Groundwater Discharge Permit No. UGW370004 (the
"GWDP") for the Mill. This Procedure incorporates the applicable provisions of the United
States Environmental Protection Agency ("EPA") RCRA Groundwater Monitoring Technical
Enforcement Guidance Document (OSWER-9950.1, September, 1986), as updated by EPA's
RCRA Ground-Water Monitoring: Draft Technical Guidance (November 1992).
Activities in an integrated program to generate quality data can be classified as management
(i.e., quality assurance or "QA") and as functional (i.e., quality control or "QC"). The
objective of this QAP is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, completeness, representativeness and comparability
required for management purposes and to comply with the reporting requirements established
by applicable permits and regulations.
2.0 ORGANIZATION AND RESPONSIBILITIES
2.1 Functional Groups
This QAP specifies roles for a QA Manager as well as representatives of three different
functional groups: the data users; the data generators, and the data reviewers/approvers. The
roles and responsibilities of these representatives are described below.
2.2 Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the QNQC measures are properly employed is the
responsibility of the QA Manager. The QA Manager is typically not directly involved in the
data generation (i.e., sampling or analysis) activities. The QA Manager is designated by
Energy Fuels Resources (USA) Inc. ("EFRI") corporate management.
2.3 Data Requestors/Users
The generation of data that meets the objectives of this QAP is necessary for management to
make informed decisions relating to the operation of the Mill facility, and to comply with the
reporting requirements set out in the GWDP and other permits and applicable regulations.
Accordingly, the data requesters/users (the "Data Users") are therefore EFRI's corporate
management and regulatory authorities through the implementation of such permits and
regulations. The data quality objectives ("DQOs") required for any groundwater sampling
event, such as acceptable minimum detection limits, are specified in this QAP.
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2.4 Data Generators
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The individuals who carry out the sampling and analysis activities at the request of the Data
Users are the data generators. For Mill activities, this involves sample collection, record
keeping and QA/QC activities conducted by one or more sampling and quality control/data
monitors ( each a "Sampling and QC Monitor"). The Sampling and QC Monitors are
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors
perform all field sampling activities, collect all field QC samples and perform all data
recording and chain of custody activities in accordance with this QAP. Data generation at the
contract analytical laboratory (the "Analytical Laboratory") utilized by the Mill to analyze the
environmental samples is performed by or under an employee or agent (the "Analysis
Monitor") of the Analytical Laboratory, in accordance with specific requirements of the
Analytical Laboratory's own QA/QC program.
The responsibilities of the data generators are as follows:
2.4.1 Sampling and OC Monitors
The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in this
QAP;
b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the samples,
to the Analytical Laboratory in accordance with this QAP;
c) Maintaining records of all samples, tracking those samples through subsequent
processing and analysis, and, ultimately, where applicable, appropriately disposing of
those samples at the conclusion of the program;
d) Preparing quality control samples for field sample collection during the sampling
event;
e) Preparing QC and sample data for review by the QA Manager; and
f) Preparing QC and sample data for reporting and entry into a computerized database,
where appropriate.
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2.4.2 AnaJvsis Monitor
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The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory.
These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and
analytical procedures, prior to receiving samples;
b) Receiving samples from the field and verifying that incoming samples correspond to
the packing list or chain-of-custody sheet; and
c) Verifying that Analytical Laboratory QC and analytical procedures are being
followed as specified in this QAP, by the Analytical Laboratory's QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program ("NELAP") certification.
2.4.3 Data Reviewers/Approvers
The QA Manager has broad authority to approve or disapprove project plans, specific
analyses and final reports. In general, the QA Manager is responsible for reviewing and
advising on all aspects of QA/QC, including:
a) Ensuring that the data produced by the data generators meet the specifications set out
in this QAP;
b) Making on-site evaluations and submitting audit samples to assist m reviewing
QA/QC procedures;
c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate
sampling equipment and sample containers, in accordance with this QAP, to
minimize contamination; and
d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personnel.
2.5 Responsibilities Of Analytical Laboratory
Unless otherwise specified by EFRI corporate management, all environmental analysis of
groundwater sampling required by the GWDP or by other applicable permits, will be
performed by a contract Analytical Laboratory.
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The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with
the requirements for maintaining National Environmental Laboratory Accreditation Program
("NELAP") certification, which is a national accreditation program developed by the NELAC
institute ("TNI").
In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U.S. EPA Guideline SW-846 and, to the extent
consistent with NELAP and EPA practices, the applicable portions of NRC Regulatory Guide
4.14.
The Analytical Laboratory will be chosen by EFRI and must satisfy the following criteria:
(1) experience in analyzing environmental samples with detail for precision and accuracy, (2)
experience with similar matrix analyses, (3) operation of a stringent internal quality assurance
program meeting NELAP certification requirements and that satisfies the criteria set out in
Section 8 below, ( 4) ability to satisfy radionuclide requirements as stipulated in the
applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the State of Utah for
and capable of performing the analytical methods set out in Table 1. The analytical
procedures used by the Analytical Laboratory will be in accordance with Utah Administrative
Code R317-6-6.3L.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this QAP is to ensure that monitoring data are generated at the Mill that
meet the requirements for precision, accuracy, representativeness, completeness, and
comparability required for management purposes and to comply with the reporting
requirements established by applicable permits and regulations (the Field and Analytical QC
samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are
satisfied). Data subject to QNQC measures are deemed more reliable than data without any
QNQC measures.
3.1 Precision
Precision is defined as the measure of variability that exists between individual sample
measurements of the same property under identical conditions. Precision is measured
through the analysis of samples containing identical concentrations of the parameters of
concern. For duplicate measurements, precision is expressed as the relative percent
difference ("RPD") of a data pair and will be calculated by the following equation:
RPD = [(A-B)/{(A+B) /2}] x 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate
samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the
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percent recoveries for matrix spike and matrix spike duplicate samples) (EPA SW-846,
Chapter 1, Section 5.0, page 27 -28).
3.2 Accuracy
Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and a known value. The accuracy of laboratory analyses is evaluated based
on analyzing standards of known concentration both before and during analysis. Accuracy
will be evaluated by the following equation:
Where:
% Recovery= (IA-BI /C) x 100
A= the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added
3.3 Representativeness
Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an
environmental condition. Representativeness is controlled by performing all sampling in
compliance with this QAP.
3.4 Completeness
Completeness refers to the amount of valid data obtained from a measurement system in
reference to the amount that could be obtained under ideal conditions. Laboratory
completeness is a measure of the number of samples submitted for analysis compared to the
number of analyses found acceptable after review of the analytical data. Completeness will
be calculated by the following equation:
Completeness = (Number of valid data points/total number of measurements) x 100
Where the number of valid data points is the total number of valid analytical measurements
based on the precision, accuracy, and holding time evaluation. Completeness is determined
at the conclusion of the data validation.
The Director ("Director") of the Utah Division of Waste Management and Radiation Control)
("DWMRC") approval will be required for any completeness less than 100 percent.
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3.5 Comparability
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Comparability refers to the confidence with which one set of data can be compared to another
measuring the same property. Data are comparable if sampling conditions, collection
techniques, measurement procedures, methods, and reporting units are consistent for all
samples within a sample set.
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over
the surface casing and cementing the surface section of the drill hole. Wells have surface
covers of mild steel with a lockable cap cover. Radiation Safety staff has access to the keys
locking the wells.
4.2 Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.
4.3 Water Quality QC Samples
Quality assurance for groundwater monitoring consists of the following QC samples:
4.3.1 VOC Trip Blanks
Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds ("VOCs") through diffusion during sample transport and storage.
At a minimum (at least) one trip blank will be in each shipping container containing samples
to be analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site, and then returned to the Analytical Laboratory for analysis
along with the samples collected during the sampling event. The trip blank will be unopened
throughout the transportation and storage processes and will accompany the technician while
sampling in the field.
4.3.2 Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non-
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples. Rinsate
blanks will be collected after decontamination and prior to subsequent use. Rinsate blank
samples for a non-dedicated pump are prepared by pumping de-ionized water into the sample
containers. Rinsate blank samples for a non-disposable or non-dedicated bailer are prepared
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Quality Assurance Plan (QAP) Page 12 of 60
by pouring de-ionized water over and through the bailer and into the sample containers.
Equipment rinsate blanks will be analyzed only for the contaminants required during the
monitoring event in which they are collected.
Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
4.3.3 Field Duplicates
Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.
Field duplicate sampling procedures are described in Attachment 2-5.
4.3.4 Definition of "Batch"
For the purposes of this QAP, a Batch is defined as 20 or fewer samples.
5.0 CALIBRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance
with manufacturers' recommendations, and Analytical Laboratory equipment shall be
calibrated in accordance with Analytical Laboratory procedures.
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to use as noted
in Attachment 2 to ensure that the Water Sounding Device is functional.
5.2 Water Quality
The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer's specifications (for
example, by using two known pH solutions and one specific conductance standard.) Per the
manufacturer, temperature cannot be calibrated but will be periodically checked
comparatively by using a thermometer. Conductivity and pH calibration results will be
recorded as described in Section 7 .1.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS
6.1 Groundwater Head Monitoring
Groundwater head measurements ("depth to water") will be completed as described m
Attachment 2 using the equipment specified in Attachment 2.
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6.1.1 Location and Frequency of Groundwater Head Monitoring
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Depth to groundwater shall be measured quarterly in the following wells and piezometers:
a) All Point of Compliance wells listed in the GWDP;
b) Monitoring well MW-34;
c) All piezometers (P-1, P-2, P-3A, P-4, P-5 and the Dry Ridge piezometers);
d) All contaminant investigation wells required by the Director as part of a
contaminant investigation or groundwater corrective action (chloroform and
nitrate wells).
6.1.2 Groundwater Head Monitoring Frequency
Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5-day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an electronic
data management system (spreadsheet and/or database). The data from the quarterly depth to
water measurements will be included in the quarterly reports.
In addition, weekly and monthly depth to groundwater measurements are taken in the chloroform
pumping wells MW-4, MW-26, TW4-1, TW4-2, TW4-11, TW4-19, TW4-20, TW4-4, TW4-21,
TW4-37, TW4-39 TW4-40 (starting in May 2019) and TW4-41, and the nitrate pumping wells TW4-
22, TW4-24, TW4-25, and TWN-2.
The depth to groundwater measured immediately prior to purging/sampling will be recorded
for each well as described in Section 7 .1.
6.2 Ground Water Compliance Monitoring
6.2.1 Location and Frequency of Groundwater Compliance Monitoring
Groundwater quality shall be measured in the wells specified in the GWDP at the frequencies
specified in the GWDP. In addition, the Chloroform Investigation and Nitrate Corrective
Action wells will be sampled quarterly as described in Appendix A and Appendix B of this
QAP.
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Quality Assurance Plan (QAP) Page 14 of60
Accelerated quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in the GWDP. Sampling personnel should
coordinate with the QA Manager prior to conducting any monitoring well sampling to
determine if any parameters in any wells are subject to accelerated monitoring.
6.2.2 Quarterly and Semi-Annual Sampling Required In Accordance With the GWDP
All quarterly and semi-annual samples collected in accordance with the GWDP shall be
analyzed for the following parameters:
a) Field parameters -depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) turbidity and dissolved oxygen ("DO"); and
b) Laboratory Parameters:
(i) All parameters specified in Table 2 of the GWDP; and
(ii) General inorganics -chloride, sulfate, carbonate, bicarbonate, sodium
potassium, magnesium, calcium, and total anions and cations.
6.2.3 Accelerated Quarterly or Monthly Sampling Required By the GWDP
Any quarterly or monthly accelerated sampling required by the GWDP shall be analyzed for
the specific parameters as required by previous sampling results as determined by the QA
Manager.
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.
Purging and sampling equipment is described in Attachment 2-3 of this QAP.
Field parameters are measured by using a flow cell system that enables the measurements to
be taken on a real-time basis without exposing the water stream to the atmosphere;
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6.2.5 Decontamination Procedure
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Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.
6.2.6 Pre-Purging/ Sampling Activities
Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the well' s historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.
6.2.7 Well Purging/Measurement of Field Parameters
The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.
Purging wells prior to sampling removes the stagnant water column present in the well casing
and assures that representative samples of the formation water are collected. Purging will be
completed as described in Attachment 2-3.
There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
6.2.8 Samples to be taken and order of taking samples
For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP. The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single container
due to like sampling requirements (filtering) and/or like preservation. The container
requirements will be determined by the Analytical Laboratory and specified with the bottles
supplied to the Field Personnel. Bottle requirements may change if the Analytical Laboratory
is changed or if advances in analytical techniques allow for reduced samples volumes. The
following list is a general guideline.
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a) VOCs, 3 sample containers, 40 ml each;
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b) Nutrients (arrunonia, nitrate/nitrite as N), 1 sample container, 250 ml;
c) All other non-radiologies (anions, general inorganics, TDS, total cations and total
anions), 2 sample containers, 500 and 250 ml,;
d) Gross alpha, 1 sample container, 1,000 ml, filtered; and
e) Metals, 1 sample container, 500 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.
Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7.1 Field Data Collection
Documentation of observations and data from sampling provide important information about
the sampling process and provide a permanent record for sampling activities. All
observations and field sampling data will be recorded.
Field data collection will be completed using either an electronic device (such as a tablet) or a
hardcopy form. Hardcopy forms will be completed in waterproof ink. If field data collection
is completed using an electronic device, a data report for each well sampled will be printed
after the completion of the sampling event and signed by one member of the sampling crew.
The signed sheets will be maintained on file and the Mill and will be included in the quarterly
reports. The electronic data collection will be accomplished using a standardized collection
module. An example of a hardcopy field collection form as well as an example data report are
included as Attachment IA and lB respectively.
The hardcopy data sheets and data reports included herein are examples and may be changed
to accorrunodate additional data collection. If a change is made to a data sheet to
accorrunodate additional information, a copy will be provided to the Director. Changes to
hardcopy field forms and data reports will not eliminate any data collection activity without
written approval of the Director.
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Regardless of the field data collection method, the following information will be collected:
• Name of the site/facility
• description of sampling event
• location of sample (well name)
• sampler's name(s) and/or initials(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump or bailer)
• previous well sampled during the sampling event
• well depth
• depth to groundwater before purging and sampling
• field measurements (pH, specific conductance, water temperature, redox
potential, turbidity, DO)
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory.
Field data collection will also include detailed notes describing any other significant factors
noted during the sampling event as necessary, including, as applicable: condition of the well
cap and lock; water appearance, color, odor, clarity; presence of debris or solids; any
variances from this procedure; and any other relevant features or conditions.
7.2 Chain-Of-Custody and Analytical Request Record
A Chain-of-Custody (the "COC Form") will accompany the samples being shipped to the
Analytical Laboratory. Standard Chain-of-Custody protocol is initiated for each sample set.
A COC Form is to be completed for each set of samples collected and is to include the
following:
• sampler's name
• company name
• date and time of collection
• sample matrix (e.g., water)
• sample location
• number of sample containers in the shipping container
• analyses requested
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• signatures of persons involved in the chain of possession
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• internal temperatures of the shipping container when opened at the laboratory
• remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.
Chain-of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.
The person shipping the samples to the Analytical Laboratory will sign the COC Form,
document shipment method, and send the original COC Form with the samples. Upon
receipt of the samples, the person receiving the samples will sign the COC Form and return
an electronic copy to the Mill and the QA Manager.
Copies of the COC Forms and other relevant documentation will be retained at the Mill.
7.3 Record Keeping
The data collection records are retained in an electronic database and hardcopies are retained
at the Mill.
Data from the Analytical Laboratory, showing the laboratory analytical results for the water
samples, are maintained at the Mill.
EFRI will ensure that the Analytical Laboratory or Laboratories used, have certifications for
each parameter and method required by Section 8.2, Table 1 of the QAP. The QA Manager
will check the Utah certifications at least annually.
Once all the data for the quarter (all wells sampled during the quarter) is completed, key data
from the field and from the data packages are managed using electronic data management
software. The data management software will be managed and administered by the QA
Manager or designee.
8.0 ANALYTICAL PROCEDURES AND QA/QC
Analytical Laboratory QA provides a means for establishing consistency in the performance
of analytical procedures and assuring adherence to analytical methods utilized. Analytical
Laboratory QC programs include traceability of measurements to independent reference
materials and internal controls.
8.1 Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In
choosing and retaining the Analytical Laboratory, EFRI shall ensure that the Analytical
Laboratory is certified by the State of Utah and by NELAP, is capable of performing the
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analytical procedures specified in Section 8.2, and that the QA/QC program of the Analytical
Laboratory includes the spikes, blanks and duplicates described in Section 8.1.2.
8.1.2 Spikes, Blanks and Duplicates
Analytical Laboratory QC samples will assess the accuracy and precision of the analyses.
The following describes the type of QC samples that will be used by the Analytical
Laboratory to assess the quality of the data. The following procedures shall be performed at
least once with each analytical Batch of samples:
a) Matrix Spike/Matrix Spike Daplicate
A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.
b) Method Blanks
Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.
c) Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) shall be spiked with
surrogate compounds prior to purging or extraction. Surrogates are organic
compounds which are similar to analytes of interest in chemical composition,
extraction, and chromatography, but which are not normally found in environmental
samples. Surrogates shall be spiked into samples according to the appropriate organic
analytical methods.
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d) Check Sample
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Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.
8.2 Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory will be as specified in
Table 1, or as otherwise authorized by the Director. With respect to Chloroform
Investigation and Nitrate Corrective Action sampling, the analytical procedures for
parameters monitored under those programs are specified in Appendix A and B respectively.
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Contaminant Analytical
Methods
to be Used
Nutrients
Ammonia ( as N) A4500-
NH3 Gor
E350.l
Nitrate & Nitrite E353.l or
(as N) E353.2
Heavy Metals
Arsenic E200.7 or
E200.8
Beryllium E200.7 or
E200.8
Cadmium E200.7 or
E200.8
Chromium E200.7 or
E200.8
Cobalt E200.7 or
E200.8
Copper E200.7 or
E200.8
Iron E200.7 or
E200.8
Lead E200.7 or
E200.8
Manganese E200.7 or
E200.8
Mercury E 245.1 or
E200.7 or
E200.8
Molybdenum E200.7 or
E200.8
Nickel E200.7 or
E200.8
Selenium E200.7 or
E200.8
Silver E200.7 or
E200.8
Thallium E200.7 or
E200.8
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Table 1
Reporting Maximum Sample Sample
Limit1 Holding Preservation Temperature
Times ReQuirements Requirements
0.05 mg/L 28 days H2S04 to :5 6°C
pH<2
0.1 mg/L 28 days H2S04 to :5 6°C
pH<2
5 µg/L 6 months HN03topH<2 None
0.50 µg/L 6 months HN03topH<2 None
0.50 µg/L 6 months HN03topH<2 None
25 µg/L 6 months HN03topH<2 None
10 µg/L 6 months HN03topH<2 None
10 µg/L 6 months HN03topH<2 None
30 µg/L 6 months HN03topH<2 None
1.0 µg/L 6 months HN03topH<2 None
10 µg/L 6 months HN03tO pH<2 None
0.50 µg/L 28 days HN03tO pH<2 None
10 µg/L 6 months HN03topH<2 None
20 µg/L 6 months HN03topH<2 None
5 µg/L 6 months HN03topH<2 None
10 µg/L 6 months HN03topH<2 None
0.50 µg/L 6 months HN03topH<2 None
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Contaminant Analytical
Methods
to be Used
Tin E200.7 or
E200.8
Uranium E200.7 or
E200.8
Vanadium E200.7 or
E200.8
Zinc E200.7 or
E200.8
Radiolosdcs
Gross Alpha E 900.0 or
E900.1 or
903.0
Volatile
Organic
Compounds
Acetone SW8260B,
SW8260C
or
SW8260D
Benzene SW8260B,
SW8260C
or
SW8260D
2-Butanone SW8260B,
(MEK) SW8260C
or
SW8260D
Carbon SW8260B,
Tetrachloride SW8260C
or
SW8260D
Chloroform SW8260B,
SW8260C
or
SW8260D
Chloromethane SW8260B,
SW8260C
or
SW8260D
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Reporting Maximum Sample Sample
Limit1 Holding Preservation Temperature
Times Requirements Requirements
100 µg/L 6 months HN03to pH<2 None
0.30 µg/L 6 months HN03topH<2 None
15 µg/L 6 months HN03topH<2 None
10 µg/L 6 months HN03to pH<2 None
1.0 pCi/L 6 months HN03topH<2 None
20 µg/L 14 days HCl to pH<2 :5 6°C
1.0 µg/L 14 days HCl to pH<2 :5 6°C
20 µg/L 14 days HCl to pH<2 :5 6°C
1.0 µg/L 14 days HCl to pH<2 :5 6°C
1.0 µg/L 14 days HCl to pH<2 :5 6°C
1.0 µg/L 14 days HCl to pH<2 :5 6°C
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Contaminant Analytical
Methods
to be Used
Dichloromethane SW8260B,
(Methylene SW8260C
Chloride) or
SW8260D
Naphthalene SW8260B,
SW8260C
or
SW8260D
Tetrahydrofuran SW8260B,
SW8260C
or
SW8260D
Toluene SW8260B,
SW8260C
or
SW8260D
Xylenes (total) SW8260B,
SW8260C
or
SW8260D
Others
Field pH (S.U.) A4500-H
B
Fluoride A4500-F C
orE300.0
TDS A2540 C
General
In organics
Chloride A4500-Cl
B or
A4500-Cl
E
orE300.0
Sulfate A4500-
S04 E or
E300.0
Carbonate as A2320B
C03
Bicarbonate as A2320B
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Reporting Maximum Sample Sample
Limit1 Holding Preservation Temperature
Times Requirements Requirements
1.0 µg/L 14 days HCl to pH<2 $ 6°C
1.0 µg/L 14 days HCl to pH<2 $6°C
1.0 µg/L 14 days HCl to pH<2 $ 6°C
1.0 µg/L 14 days HCl to pH<2 $6°C
1.0 µg/L 14 days HCl to pH<2 $6°C
0.01 s.u. Immediate None None
0.1 rng/L 28 days None None
10 mg/L 7 days None $ 6°C
1 rng/L 28 days None None
1 mg/L 28 days None $ 6°C
1 rng/L 14 days None $6°C
1 mg/L 14 days None $6°C
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Contaminant Analytical
Methods
to be Used
HC03
Sodium E200.7
Potassium E200.7
Magnesium E200.7
Calcium E200.7
Reporting
Limit1
0.5 mg/L
0.5 mg/L
0.5 mg/L
0.5 mg/L
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Maximum Sample Sample
Holding Preservation Temperature
Times Requirements Requirements
6 months HN03topH<2 None
6 months HN03topH<2 None
6 months HN03topH<2 None
6 months HN03topH<2 None
1. The Analytical Laboratory will be required to meet the reporting limits ("RLs") in the foregoing Table,
unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the
increased RL will be used, or unless otherwise approved by the Director.
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Internal quality control checks are inherent in this QAP. The QA Manager will monitor the
performance of the Sample and QC Monitors, and, to the extent practicable, the Analysis
Monitor to ensure that they are following this QAP. In addition, either the QA Manager or a
Sampling and QC Monitor will review and validate the analytical data generated by the
Analytical Laboratory to ensure that it meets the DQOs established by this QAP. Finally,
periodic system and performance audits will be performed, as detailed in Section 12 below.
9.1 Field QC Check Procedures
The QA Manager will perform the following QA/QC analysis of field procedures:
9.1.1 Review of Compliance With the Procedures Contained in this OAP
Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.
9.1.2 Analyte Completeness Review
The QA Manager will review all Analytical Results to confirm that the analytical results are
complete (i.e., there is an analytical result for each required constituent in each well). The
QA Manager shall also identify and report all instances of non-compliance and non-
conformance as required by the Permit. Director approval will be required for any
completeness (prior to QA/QC analysis) less than 100 percent. Non-conformance will be
defined as a failure to provide field parameter results and analytical results for each parameter
and for each well required in Sections 6.2.2 and 6.2.3, for the sampling event, without prior
written Director approval.
9.1.3 Blank Comparisons
Trip blanks, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not an order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).
Corrective actions for blank comparison non-conformance shall first determine if the non-
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will:
1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
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4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.
9.1.4 Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:
a) Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD 2:_20%, unless the measured concentrations
are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review,
February 1994, 9240.1-05-01, p. 25).
b) Radiologic Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting
variance that is equal to or less that 20% of the reported activity concentration. An error
term may be greater than 20% of the reported activity concentration when the sum of the
activity concentration and error term is less than or equal to the GWCL.
c) Radiologic , Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:
Where:
A = the first duplicate measurement
B = the second duplicate measurement
Sa 2 = the uncertainty of the first measurement squared
Sb 2 = the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is > 2.
(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. Vl-9).
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Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non-
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
9.2 Analytical Laboratory QA Reviews
Full validation will include recalculation of raw data for a minimum of one or more analytes
for ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC
review which will include validating holding times and QC samples. Overall data assessment
will be a part of the validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality of the data based
on SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The
reviewer will check the following:
( 1) sample preparation information is correct and complete,
(2) analysis information is correct and complete,
(3) appropriate Analytical Laboratory procedures are followed,
( 4) analytical results are correct and complete,
(5) QC samples are within established control limits,
(6) blanks are within QC limits,
(7) special sample preparation and analytical requirements have been met, and
(8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation. The
Analytical Laboratory will report the data as a group of one batch or less, along with the
QNQC data. The Analytical Laboratory will provide the following information:
( 1) cover sheet listing samples included in report with a narrative,
(2) results of compounds identified and quantified,
(3) reporting limits for all analytes, and
( 4) QNQC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
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a) Reporting Limit (RL) Compari on
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The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are
in conformance with the reporting limits set out on Table 1. Non-conformance shall be
defined as:
1) a reporting limit that violates these provisions, unless the reporting limit must be increased
due to sample matrix interference (i.e., due to dilution); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory
are those specified in Table 1, unless otherwise approved by the Director. Non-conformance
shall be defined when the Analytical Laboratory uses analytical methods not listed in Table 1
and not otherwise approved by the Director.
c) Holcling Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.
d) Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received
by the Analytical Laboratory at a temperature no greater than the approved temperature listed
in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.
9.4 Analytical Data
All QA/QC data and records required by the Analytical Laboratory's QA/QC program shall
be retained by the Analytical Laboratory and shall be made available to EFRI as requested.
Analytical data submitted by the Analytical Laboratory should contain the date/time the
sample was collected, the date/time the sample was received by the Analytical Laboratory,
the date/time the sample was extracted (if applicable), and the date/time the sample was
analyzed.
All out-of-compliance results will be logged by the Analysis Monitor with corrective actions
described as well as the results of the corrective actions taken. All raw and reduced data will
be stored according to the Analytical Laboratory's record keeping procedures and QA
program. All Analytical Laboratory procedures and records will be available for on-site
inspection at any time during the course of investigation.
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If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will be
consulted to establish more appropriate analytical approaches for problem samples.
10.0 CORRECTIVE ACTION
10.1 When Corrective Action is Required
The Sampling and QC Monitors and Analytical Laboratory are responsible for following
procedures in accordance with this QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. All deviations from
field sampling procedures will be noted during field data collection. Any QNQC problems
that arise will be brought to the immediate attention of the QA Manager. Analytical
Laboratory deviations will be recorded by the Analysis Monitor in a logbook as well.
When a procedural or systematic non-conformance is identified, EFRI shall:
a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to be
systematic or procedural, EFRI shall determine the root cause, and provide specific
steps to resolve problems(s) in accordance with the procedure set forth in Section
10.2. Any non-conformance with QAP requirements in a given quarterly
groundwater monitoring period will be corrected and reported to the Director on or
before submittal of the next quarterly ground water monitoring report.
b) When a sample is lost, sample container broken, or the sample or analyte was
omitted, resample within 10 days of discovery and analyze again in compliance with
all requirements of this QAP. The results for this sample(s) should be included in the
same quarterly monitoring report with other samples collected for the same sampling
event; and
c) For any other material deviation from this QAP, the procedure set forth in Section
10.2 shall be followed.
10.2 Procedure for Corrective Action
The need for corrective action for non-conformance with the requirements of this QAP, may
be identified by system or performance audits or by standard QNQC procedures. The
procedures to be followed if the need for a corrective action is identified, are as follows:
a) Identification and definition of the problem;
b) Assignment of responsibility for investigating the problem;
c) Investigation and determination of the cause of the problem;
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d) Determination of a corrective action to eliminate the problem;
e) Assigning and accepting responsibility for implementing the corrective action;
f) Implementing the corrective action and evaluating its effectiveness; and
g) Verifying that the corrective action has eliminated the problem.
The QA Manager shall ensure that these steps are taken and that the problem which led to the
corrective action has been resolved. The corrective actions will be documented either in a
memorandum explaining the steps outlined above, which will be placed in the applicable
monitoring files and the Mill Central Files, or the corrective action will be documented in the
quarterly reports prepared in accordance with Section 11.
11.0 REPORTING
As required by the GWDP, the Mill will send a groundwater monitoring report to the
Director on a quarterly basis. Both the Routine Groundwater Monitoring Reports and
Chloroform Investigation and Nitrate Corrective Action Reports shall be submitted according
to the following schedule:
Quarter Period Due Date
First January -March June 1
Second April-June September 1
Third July -September December 1
Fourth October -December March 1
The Routine Groundwater Monitoring Reports (required by the GWDP) will include the
following information:
• Description of monitor wells sampled
• Description of sampling methodology, equipment and decontamination
procedures to the extent they differ from those described in this QAP
• A summary data table of groundwater levels for each monitor well and
piezometer
• A summary data table showing the results of the sampling event, listing all
wells and the analytical results for all constituents and identifying any
constituents that are subject to accelerated monitoring in any particular wells
pursuant to the GWDP or are out of compliance in any particular wells
pursuant to the GWDP
• Field data recorded during sample collection
• Copies of Analytical Laboratory results
• Copies of Chain of Custody Forms (included in the data packages)
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• A Water Table Contour Map showing groundwater elevation data for the
quarter will be contemporaneous for all wells on site, not to exceed a
maximum time difference of five calendar days.
• Evaluation of groundwater levels, gradients and flow directions
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this QAP and all corrective actions taken
With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B to this document.
In addition, an electronic copy of all analytical results will be transmitted to the DWMRC in
comma separated values ("CSV") format, or as otherwise advised by the DWMRC.
Further reporting may be required as a result of accelerated monitoring under the GWDP.
The frequency and content of these reports will be defined by EFRI corporate management
working with the Director.
12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
EFRI shall perform such system audits and performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined
by EFRI.
12.2 System Audits
System audits are qualitative evaluations of all components of field and Analytical
Laboratory QC measurement systems. They determine if the measurement systems are being
used appropriately. System audits will review field and Analytical Laboratory operations,
including sampling equipment, laboratory equipment, sampling procedures, and equipment
calibrations, to evaluate the effectiveness of the QA program and to identify any weakness
that may exist. The audits may be carried out before all systems are operational, during the
program, or after the completion of the program. Such audits typically involve a comparison
of the activities required under this QAP with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data
collection and management activities.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
12.3 Performance Audits
Date: 08-22-2019 Revision 7.6
Page 32 of60
The performance audit is a quantitative evaluation of the measurement systems of a program.
It requires testing the measurement systems with samples of known composition or behavior
to evaluate precision and accuracy. With respect to performance audits of the analytical
process, either blind performance evaluation samples will be submitted to the Analytical
Laboratory for analysis, or the auditor will request that it provide results of the blind studies
that the Analytical Laboratory must provide to its NELAP accreditation agency on an annual
basis. The performance audit is carried out without the knowledge of the analysts, to the
extent practicable.
12.4 Follow-Up Actions
Response to the system audits and performance audits is required when deviations are found
and corrective action is required. Where a corrective action is required, the steps set out in
Section 10.2 will be followed.
12.5 Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records
will contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit findings or corrective actions.
13.0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.
Field instruments will be maintained as per the manufacturer's specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in
accordance with Section 5. Batteries will be charged and checked daily when these
instruments are in use. All equipment out of service will be immediately replaced. Field
instruments will be protected from adverse weather conditions during sampling activities.
Instruments will be stored properly at the end of each working day. Calibration and
maintenance problems encountered will be recorded and addressed as soon as practical.
The Analytical Laboratory is responsible for the maintenance and calibration of its
instruments in accordance with Analytical Laboratory procedures and as required in order to
maintain its NELAP certifications. Preventive maintenance will be performed on a scheduled
basis to minimize downtime and the potential interruption of analytical work.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
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Quality Assurance Plan (QAP)
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC Reporting
The following reporting activities shall be undertaken on a regular basis:
Page 33 of60
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding
progress of the applicable sampling program. The Sample and QC Monitors will
also brief the QA Manager on any QA/QC issues associated with such sampling
activities.
b) The Analytical Laboratory shall maintain detailed procedures for laboratory record
keeping. Each data set report submitted to the Mill's QA Manager or his staff will
identify the analytical methods performed and all QA/QC measures not within the
established control limits. Any QA/QC problems will be brought to the QA
Manager's attention as soon as possible; and
c) After sampling has been completed and final analyses are completed and reviewed, a
brief data evaluation summary report ( case narrative) will be prepared by the
Analytical Laboratory for review by the QA Manager, by a Sampling and QC
Monitor or by such other qualified person as may be designated by the QA Manager.
The report will be prepared in accordance with NELAP requirements and will
summarize the data validation efforts and provide an evaluation of the data quality.
14.2 Periodic Reporting to Management
The QA Manager shall present a report to EFRI' s ALARA Committee at least once per
calendar year on the performance of the measurement system and the data quality. These
reports shall include:
a) Periodic assessment of measurement quality indicators, i.e., data accuracy, precision
and completeness;
b) Results of any performance audits, including any corrective actions;
c) Results of any system audits, including any corrective actions; and
d) Significant QA problems and recommended solutions.
15.0 AMENDMENT
This QAP may be amended from time to time by EFRI only with the approval of the
Director.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
16.0 REFERENCES
Date: 08-22-2019 Revision 7.6
Page 34 of60
United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.
United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document (TEGD), Office of Solid Waste and
Emergency Response, OSWER-9950.1.
United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.
Standard Methods for the Examination of Water and Wastewater, 20th Edition, 1998.
American Public Health Association, American Water Works Association, Water
Environment Federation. Washington, D.C. p. 1-7.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENT 1
Field and Data Forms
Date: 08-22-2019 Revision 7.6
Page 35 of60
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Attachment 1-1
Quarterly Depth to Water Data Sheet
NAME:
DATE:
Depth to Depth to
Date Time Well Water (ft) Date Time Well Water (ft.)
Date: 08-22-2019 Revision 7.6
Date Time
Page 36 of60
Well
Depth to
Water
(ft.)
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 08-22-2019 Revision 7 .6
Quality Assurance Plan (QAP)
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
ATIACHMENT 1-2
Page 37 of60
C WHITE MESA URANIUM MILL \ fYi See inslruclion
FIELD DATA WORKSHEETFOR GROUNDWATER
Description of Sampling Event:
Location (well name): ......_ ____________ __.
Sampler Name
and initials:
Field Sample ID
Date and Time for Purging.__ ________ .....
Well Purging Equip Used: [Q]pump or @] bailer
Purging Method Used: [QJ2 casings [g]3 casings
Sampling Event ~----------~
pH Buffer 7 .0 ~I -----~
Specific Conductance ~I -----~! µMHOS/ cm
Depth to Water Before Purging! ~---~
Weather Cond.
Time
Conductance
Temp. °C
Redox Potential Eh (mV)
Turbidity (NTU)
Time
Gal. Purged
pH
Gal. Purged
I Conductance~ l ___ ~I pH I~---~
Temp. °C I
Redox Potential Eh (mV)
Turbidity (NTU)
I
and Sampling (if different)
Well Pump (if other than Bennet)
Prev. Well Sampled in Sampling Event '~---------~
pH Buffer 4.0
Well Depth(O.Olft):
Casing Volume (V) 4" Well:~----11(.653h)
3" Well:_ _ (.367h)
Ext'I Amb. Temp. ·c (prior sampling event)._! ___ ....,
Time Gal. Purged
Conductance pH I
Temp. °C
Redox Potential Eh (mV) I
Turbidity (NTU)
Time Gal. Purged
Conductance pH
Temp. °C
Redox Potential Eh (mV) I
Turbidity (NTU)
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Volume of Water Purged
Pumping Rate Calculation
Date: 08-22-2019 Revision 7.6
Page 38 of 60
gallon(s)
Flow Rate (Q). in gpm.
S/60 = '-[ ____ _,
Time to evacuate two ca ing volumes (2V)
T =2V/Q=! I
Number of casing volumes evacuated (if other than two)
lf well evacuated to dryness, number of gallons evacuated
Name of Certified Analytical Laboratory if Other Than Energy Labs
Sample Taken Sample Vol (indicate if Filtered Preservative Preservative Added Type of Sample other than as specified
y N below) y N Type y N
voes D D 3x40 ml D D HCL D D
Nutrients D D 100ml D D H2S04 D D
Heavy Metals D D 250ml D D HN03 D D
All Other Non Radiolo!!ics D D 250 ml D D No Preserv. D D
Gross Alpha D D 1.000ml D D HN03 D D
Other (specify) D D Sample volume D D D D
If preservative is used, specify
Type and Quantity of
Preservative:
Final Depth '--------' Sample Time
Comment
[ ,~ See instruction
'---------~Do not touch this cell (SheetName)
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Quality Assurance Plan (QAP)
Date: 08-22-2019 Revision 7.6
Page 39 of60
ATTACHMENT 1-3
EXAMPLE FIELD DATA REPORT
Location ID
Field Sample ID
Pur11• Date & Time
Samplo Dato & Tlmo
Pur11ln11 l:.qulpmont
PumpTvru,
Purging Method
Casing Volume (gal)
Calculai.ct Casino Volumes Purae Durauon (mini
pH Buffer7.0
pH Buffer 4.0
Specl_nc Conductance (m_lcromhos)
Date/Time Gallons Puraacl
3/6/2019 11:22 57.93
3/6/2019 11:23 58.15
3/6/2.019 ll:24 58.37
3/6/2019 11:25 58.59
!Volumo of wai.. purgacl (pals)
!Final Depth to Water (IHI)
INaffl* of c,rtlfltd AnalvUt11I Laboratory
WSL
Anal lcal Sa.m les Information
'l' • or Sam le/Analv>I•
Heavy Metals -Mn onl
Comments:
Groundwater Ol9chargo Permit
Groundwater Mcnllor1ng Ou11llty Assur11nce Plan
White Mesa MIii
Field Data Worksheet For Groundwater
MW·U
MW·ll 03062019
3/6/20J!J 6:55
3/6/2019 11:25
Pump
QED
2 Casings
29.12
268.42
7.0
4.0
1000
Conductlvltv
2917
2927
2925
2930
58.59
85.60
Sample
Collected7
y
Matrix
WATER
!Sampler
aH Temp(DeaCl Raclox
7.45 14.02 266
7.46 14.01 262
7.411 14.00 259
7.48 14.01 256
PumPna Rate C tl afcul1 ons-
Flow Rate (Q = S/60) (gal/min)
Time to evacuate 2 Casino Volumes {min}
Number of casing Volumes
Volume, If well evacuated to dryness()
Container
Number T e Sample Filtered7
250-ml HOPE y
March 201.9
TH/Ol
Cloud
0
MW-30
130.00
85.40
IDISSOIVOQ
Turbldltv Oxvaen Before/After
0
0
0
0
.217
270.00
2.00
0
Preservative
Type Added7
HN03 ( H<2J y
! Artlved on site st 0551. PurgellegGn al 0655. PurgeG wtJII W a total ot 170 ml'"-'l&S. P1.uge onded Ond same;~·ootlecttld at , 125. Water WIilet clear Le~ site el 1130
Signature of Field Technician
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENT 2
Field Procedures
Date: 08-22-2019 Revision 7.6
Page 40 of60
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP) Page 41 of60
Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures
Measure and record all depth to water data to the nearest 0.01 feet.
Equipment Used For Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist -IT 300 or
equivalent device (the "Water Level Indicator").
Equipment Checks
Equipment used in depth to groundwater measurements will be checked prior to each day's
use to ensure that the Water Sounding Device is functional.
Check the Water Sounding Device as follows:
• Turn the Water Level Indicator on.
• Test the Water Level Indicator using the test button located on the instrument.
• If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.
Measurement of Depth to Water
All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:
• For monitoring wells -Measure depth to water from the top of the inner well casing at
the designated measurement point.
• For the piezometers -Measure depth to water from the top of the casing at the
designated measurement point.
• Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
• Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
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Quality Assurance Plan (QAP)
Attachment 2-2
Decontamination Procedures
Page 42 of60
Non-dedicated sampling equipment will be decontaminated using the following
procedures:
Water level meter
Decontaminate the water level meter probe with deionized ("DI") water.
Field Parameter Instrument (Hydrolab or equivalent)
Rinse the field parameter instrument probe unit with DI water prior to each
calibration.
Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.
Non-Dedicated Purging/Sampling Pump
Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:
a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;
b) pump the detergent/DI water solution through the pump and pump outlet lines;
c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
d) submerge the pump into a 55-gallon drum of DI water;
e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;
f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;
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Quality Assurance Plan (QAP)
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Page 43 of60
h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).
All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 08-22-2019 Revision 7.6
Quality Assurance Plan (QAP)
Attachment 2-3
Purging Procedures
The following equipment will be used for groundwater purging and sampling:
Page 44 of60
• Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These hailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
• Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
• Non -Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
• Field Parameter Meter: A meter used to measure groundwater quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:
~ Water temperature;
~ Specific conductivity;
~ Turbidity;
~ pH;
~ Redox potential (Eh);
~ Dissolved Oxygen ("DO")
• Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
• Generator: Mobile power supply to provide power for submersible pump.
• 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
"bladder" pumps.
Additional supplies for purging and sampling are as follows:
• IPad, tablet, Cell phone or Field Data Sheets
• 45 micron in-line filters (when metals and gross alpha analyses are required)
• Calculator
• Clock, stopwatch or other timing device
• Buckets
• Sampling containers (as provided by the Analytical Laboratory)
• Field preservation chemicals (as provided by the Analytical Laboratory)
• Disposable gloves
• Appropriate health and safety equipment
• Sample labels (as provided by the Analytical Laboratory)
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Pre-Purging/ Sampling Activities
Date: 08-22-2019 Revision 7.6
Page 45 of60
If a portable (non-dedicated) pump is to be used, prior to commencing the event's sampling
activities,
1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) and ice into a cooler that will
transport the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC)
samples throughout the monitoring event.
Well Purging
The purging techniques described below will be used for all groundwater sampling conducted
at the Mill unless otherwise stated in the program-specific QAPs for the chloroform and
nitrate investigations. The program-specific QAPs for the chloroform and nitrate
investigations are included as Appendix A and Appendix B respectively.
Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.
Turbidity measurement in the water should be _s 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.
A flow-cell needs to be used for field parameters.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
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Quality Assurance Plan (QAP) Page 46 of60
Procedure
a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)
b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;
c) Determine the casing volume (V) in gallons. When using the electronic data
collection module, input the depth to water in the appropriate location. The module
will calculate the casing volume. Proceed to purging. When the field data are
collected manually, calculate the casing volume where h is column height of the
water in the well (calculated by subtracting the depth to groundwater in the well from
the total depth of the well), V = 0.653*h, for a 4" casing volume and V = .367*h for
a 3" casing volume. Record the casing volume on the Field Data Worksheet;
If a portable (non-dedicated) pump is used:
• Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
• Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.
If a non-dedicated pump or dedicated pump is used:
(i) Commence pumping;
(ii) For a non-dedicated pump only, determine pump flow rate by using a
stopwatch or other timing device and a calibrated bucket by measuring the
number of seconds required to fill to the one-gallon mark. Record this in the
"pumping rate" section on the Field Data Worksheet or in the "flow rate"
section in the electronic field collection module;
(iii) Calculate the amount of time to evacuate two or three casing volumes;
(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);
(v) If two casing volumes will be purged:
Take measurements of field parameters (pH, specific conductance,
temperature, redox potential, turbidity, and DO) during well purging, using the
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Date: 08-22-2019 Revision 7.6
Page 47 of 60
Field Parameter Meter. These measurements will be recorded either
electronically or on the Field Data Worksheet. Purging is completed after two
casing volumes have been removed and the field parameters pH, temperature,
specific conductance, redox potential (Eh), turbidity, and DO have stabilized
to within 10% RPD over at least two consecutive measurements.
(vi)If three casing volumes will be purged:
Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential, turbidity, and DO) after three casing volumes
have been purged immediately prior to sample collection using the Field
Parameter Meter. Record these measurements either electronically or on the
Field Data Worksheet.
(vii) If the well is purged to dryness:
Record the number of gallons purged either electronically or on the Field Data
Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.
Upon arrival at the well after recovery or when sufficient water is available for
sampling measure depth to water and record either electronically or on the
Field Data Worksheet.
Take one set of measurements of field parameters for pH, specific
conductance and temperature only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific
conductance and temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.
Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Purging using a disposable bailer
Date: 08-22-2019 Revision 7.6
Page 48 of60
For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.
When a bailer is used, the following procedure will be followed:
(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.
(ii) Attach a disposable bailer to a rope and reel.
(iii)Lower the bailer into the well and listen for contact with the solution. Once
contact is made, allow the bailer to gradually sink in the well, being careful
not to allow the bailer to come in contact with the bottom sediment.
(iv)After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.
(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.
(vi)Take field measurements from the water in the buckets.
All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.
After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Attachment 2-4
Sample Collection Procedures
Sample Collection Order
Date: 08-22-2019 Revision 7.6
Page 49 of60
Regardless of the purging method employed samples will be collected in the order specified
below.
All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.
voes;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologies (general inorganics, TDS, anions, total cations and total anions);
and
Gross alpha and heavy metals (filtered).
Sample Filtering
When sampling for heavy metals and for gross alpha, the following procedure shall be
followed:
a) Obtain the specifically identified sample container for the type of sample to be
taken, as provided by the Analytical Laboratory;
b) Add the quantity of specified preservative provided by the Analytical Laboratory to
each sample container;
c) When using a pump to sample:
(i) Place a new 0.45 micron filter on the sample tubing;
(ii) Pump the sample through the filter, and into the sample container containing
the preservative;
(iii) The pump should be operated so that it does not produce samples that are
aerated in the return tube or upon discharge;
d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:
(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.
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Date: 08-22-2019 Revision 7.6
Page 50 of60
(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.
(iii) Place clean unused tubing in the peristaltic pump.
(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.
Procedures to Follow After Sampling
a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:
• Sample location
• Date and time of sample
• Any preservation method utilized
• Filtered or unfiltered
b) Immediately after sample collection, place each sample in an ice-packed cooler;
and
c) Before leaving the sampling location, thoroughly document the sampling event
either electronically or on the Field Data Worksheet, by recording all pertinent
data.
Upon returning to the office, the samples must be stored in a refrigerator at less than or equal
to 6° C. These samples shall be received by the Analytical Laboratory at less than or equal to
6° C. Samples will then be re-packed in the plastic ice-packed cooler and transported via
these sealed plastic containers by overnight delivery services to the Analytical Laboratory.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Field Duplicates
Attachment 2-5
Field QC Samples
Date: 08-22-2019 Revision 7.6
Page 51 of 60
Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.
Field duplicate samples should be as near to split samples as reasonably practicable.
Collection of field duplicates is completed as follows:
Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.
Field duplicate samples are labeled using a "false" well number such as MW-65 and MW-70.
Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non-
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples.
Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:
Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;
Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).
Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter "R" added (e.g. MW-llR).
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Appendix A
Date: 08-22-2019 Revision 7.6
Page 52 of60
Chloroform Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 08-22-2019 Revision 7 .6
Quality Assurance Plan (QAP)
Chloroform Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 53 of60
This document sets out the quality assurance plan to be used by EFRI for Chloroform
monitoring conducted pursuant to the Groundwater Corrective Action Plan ("GCAP") found
in Attachment 1, of the final Stipulation and Consent Order ("SCO") dated September 14,
2015. (UDEQ Docket No. UGW-20-01).
Specifically, the Mill will use the same sampling regimen for the Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
forth below:
1) Dedicated Purge Pump/Sampbng
Chloroform samples are collected by means of disposable bailer(s) the day following
the purging. The disposable bailer is used only for the collection of a sample from an
individual well and disposed subsequent to the sampling. The wells are purged prior
to sampling by means of a portable pump. Each quarterly purging event begins at the
location least affected by chloroform (based on the previous quarters sampling event)
and proceeds by affected concentration to the most affected location. Although
purging will generally follows this order, the sampling order may deviate slightly
from the generated list. This practice does not affect the samples for these reasons:
any wells sampled in slightly different order have either dedicated pumps or are
sampled via a disposable bailer. This practice does not affect the quality or usability
of the data as there will be no cross-contamination resulting from sampling order.
Decontamination of all sampling equipment will follow the decontamination
procedure outlined in Attachment 2-2 of the QAP.
2) Chloroform Inve tigation Sampling Frequency, Order and Locations
The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under SCA and GCAP. Chloroform wells shall be purged from the
least contaminated to the most contaminated as based on the most recent quarterly
results.
• MW-4 • TW4-22
• TW4-1 • TW4-23
• TW4-2 • TW4-24
• TW4-3 • TW4-25
• TW4-4 • TW4-26
• TW4-5 • TW4-27
Mill -Groundwater Discharge Permit Date: 08-22-2019 Revision 7 .6
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 54 of60
• TW4-6 • TW4-28
• TW4-7 • TW4-29
• TW4-8 • TW4-30
• TW4-9 • TW4-31
• TW4-10 • TW4-32
• TW4-11 • TW4-33
• TW4-12 • TW4-34
• TW4-13 • TW4-35
• TW4-14 • TW4-36
• MW-26 • TW4-37
• TW4-16 • TW4-38
• MW-32 • TW4-39
• TW4-18 • TW4-40
• TW4-19 • TW4-41
• TW4-20 • TW4-42
• TW4-21
Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform Program or
the Groundwater Discharge Permit Monitoring Program.
3) ChJoroform Sample Container · and CoJlection Volume
The chloroform sampling program requires a specific number of sampling containers
and the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
• For Inorganic Chloride, collect one sample into a 500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements
Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Analytical Analytical
Parameter Method
Nitrate & Nitrite E353.1 or
(as N) E353.2
Carbon SW8260B,
Tetrachloride SW8260C
or
SW8260D
Chloroform SW8260B,
SW8260C
or
SW8260D
Dichloromethane SW8260B,
(Methylene SW8260C
Chloride) or
SW8260D
Chloromethane SW8260B,
SW8260C
or
SW8260D
Inorganic A4500-Cl B
Chloride or A4500-Cl
E
or E300.0
5) Field Parameters
Date: 08-22-2019 Revision 7.6
Page 55 of60
Reporting Maximum Sample Sample
Limit Holding Preservation Temperature
Times Requirement Requirement
0.1 mg/L 28 days H2S04 to ::5 6°C
pH<2
1.0 µg/L 14 days HCl to pH<2 ::5 6°C
1.0 µg/L 14 days HCl to pH<2 ::5 6°C
1.0 µg/L 14 days HCl to pH<2 ::5 6°C
1.0 µg/L 14 days HCl to pH<2 ::5 6°C
1 mg/L 28 days None ::5 6°C
Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. However, if a pumping well has been out of service for
48 hours or more, EFRI shall follow the purging requirements outlined in Attachment
2-3 of the QAP before sample collection.
Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.
6) Chloroform Quarterly Reports
The Chloroform Quarterly Reports will include the information required by Part Ill of
the GCAP.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill's
QAP.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Appendix B
Date: 08-22-2019 Revision 7.6
Page 56 of60
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 08-22-2019 Revision 7.6
Quality Assurance Plan (QAP)
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 57 of60
This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Nitrate Corrective Action Monitoring ("Nitrate Program") conducted pursuant to the
Stipulation and Consent Order ("SCO"), Docket Number UGW12-04, which approved the
EFRI CAP, dated May 7, 2012.
Specifically, the Mill will use the same sampling regimen for the Nitrate program that is
utilized for groundwater sampling under its groundwater discharge permit, as set forth in the
attached groundwater discharge permit Quality Assurance Plan ("QAP"), except as set forth
below:
1) Purge Pump/Sampling
The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s). The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.
Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross-
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Nitrate Program Sampling Frequency. Order and.Locations
The Nitrate Program wells listed below are required to be monitored on a quarterly
basis as required by the SCO, Docket Number UGW12-04, which approved the EFRI
CAP, dated May 7, 2012. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 08-22-2019 Revision 7.6
Quality Assurance Plan (QAP) Page 58 of60
• TWN-1 • TWN-14**
• TWN-2 • TWN-16**
• TWN-3 • TWN-18
• TWN-4 • TWN-19**
• TWN-6** • Piezometer-01
• TWN-7 • Piezometer-02
• Piezometer-03A
**DeQth to water mea urement onJy.
7) Nitrate Program Sample Containers and Collection Volume
The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
• For Inorganic Chloride, collect one sample into a 500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laborat01y Requirements
Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Analytical Analytical Reporting Maximum Sample Sample
Parameter Method Limit Holding Preservation Temperature
Times Requirement Requirement
Nitrate & Nitrite E353.1 or 0.1 mg/L 28 days H2S04 to :5 6°C
(as N) E353.2 pH<2
Inorganic A4500-Cl B 1 mg/L 28 days None :5 6°C
Chloride or A4500-Cl
E
orE300.0
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
9) Field Parameter
Date: 08-22-2019 Revision 7.6
Page 59 of60
Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.
10) Nitrate Program lnve tigation Report
The Nitrate Program Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan
• Description of monitor wells
• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples
c) Data Interpretation
• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
• Interpretation of all analytical results for each well, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
• Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate mass
removed from each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Nitrate Program monitoring
conducted during the quarter.
f) Copies of EFRI field records, laboratory reports and chain of custody
forms.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-22-2019 Revision 7.6
Page 60 of60
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill's
QAP.
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
SEEPS AND SPRINGS
Revision 2
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
July 8, 2016
Table of Contents
1.0 Introduction and Objectives ................................................................................................................... 3
2.0 Seeps and Springs Sampling Locations ................................................................................................... 3
2.1 Timing of Sample Collection ............................................................................................................... 3
3.0 Field Sampling Procedures ...................................................................................................................... 4
3.1 Field Data ............................................................................................................................................ 5
3.3 Field QC ............................................................................................................................................... 5
3.4 Sample Handling ................................................................................................................................. 6
4.0 QA and Data Evaluation .......................................................................................................................... 6
5.0 Laboratory Analysis ................................................................................................................................. 6
5.1 Analytical Quality Control .............................................................................................................. 7
5.2 Evaluation of Analytical Data .............................................................................................................. 7
6.0 Reporting ........................................................................................................................................... 7
Attachments
Tab A Seeps and Springs Location Map
Tab B Bureau of Land Management Letter
Tab C Field Data Form
Tables
Table 1 Seeps and Springs Survey Information
1.0 Introduction and Objectives
This Sampling and Analysis Plan ("SAP") describes the procedures for sampling seeps and springs in the
vicinity of the Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Uranium Mill ("the Mill") in
Blanding, Utah as required by the State of Utah Groundwater Discharge Permit ("GWDP") No.
UGW370004.
The objective of the seeps and springs sampling program is to collect annual surface water samples from
the locations identified below as required by the GWDP. This SAP specifies the sample collection
requirements, procedures, analytical methodologies and associated quality control ("QC") checks, sample
handling protocols and reporting requirements for the annual seeps and springs sampling program.
2.0 Seeps and Springs Sampling Locations
The annual seeps and springs sampling locations correspond with those seeps and springs sampled for the
initial site characterization performed for the Environmental Assessment as shown on Plate 2.6-10 of the
Environmental Report (Dames & Moore, 1978), and additional sites located by EFRI, the Bureau of Land
Management ("BLM") and Ute Mountain Tribal representatives. The locations included in the annual
seeps and springs sampling event are:
• Cottonwood Seep
• Westwater Seep
• Ruin Spring
• Corral Canyon Seep
• Entrance Spring
• Corral Springs
The Permit Section I.F.7 (g) requires that survey data for the seeps and springs be submitted prior to the
collection of samples. The Division of Waste Management and Radiation Control ("DWMRC")
previously clarified the requirement to submit survey data only prior to the first sampling and not on an
annual basis. The survey data submitted with the first annual seeps and springs report in 2009 was
incorrect. In response to the incorrect data, EFRI completed another survey of the seeps and springs in
December 2009. Those survey data are included in Table 1 of this SAP and the locations are shown on
Figure 1 included in Tab A. The surveyed coordinates and elevations of the seeps and springs were within
1 foot of the highest point of the saturated seepage face on the day of the survey
2.1 Timing of Sample Collection
EFRI representatives conducted reconnaissance visits to the locations listed in Section 2.0 above in June
2008 in order to determine the status of the listed springs and seeps and to evaluate the feasibility of
physical development with hand tools in order to better accommodate sampling at dry locations. It was
observed at that time that water flow was available for sampling at Ruin Spring, Cottonwood Seep and
Entrance Spring. Alternatively, Westwater Seep, Corral Canyon Seep and Corral Springs were entirely
dry or exhibited only barely moist soil. Annual sampling events conducted from 2009 through 2016
noted that dry conditions continued at Westwater Seep, Corral Canyon Seep and Corral Springs with no
opportunity for sampling even with limited hand tool development. Based on the data collected to date
regarding the conditions at the six locations specified in Section 2.0 above, the following schedule for site
visits and possible sampling will be employed:
• Once per calendar quarter, the Westwater Seep, Corral Canyon Seep and Corral Springs will be
visited. If sufficient water is present, a sample will be collected and no further visits will be
completed for the year. If no sample is collected prior to the annual event, these locations will be
visited during the annual sampling event. If these locations are dry during the annual sampling
event, the calendar quarter checks will continue until either a sample is collected or 4 quarterly
checks ( one per calendar quarter) have been completed. NOTE: The annual report is due
December 1 of each year. The fourth quarter check will be limited to October and November to
meet the report deadline.
• Annually, between May 1 and July 15 of each year, a sample will be collected from Ruin Spring,
Cottonwood Seep and Entrance Spring. Should any of these locations be dry during the annual
event, quarterly checks (for the remaining calendar quarter) will be completed starting after the
annual event.
Should a visit reveal a change in conditions at any of these dry locations which may yield water sampling
opportunities, EFRI will proceed with limited hand tool excavation of the sampling location. The hand-
dug excavation will be left open for a maximum of 48 hours and allowed to fill with water. If water
collects in the excavation, it will be sampled. If the location is excavated with hand tools, it will be filled
after sampling has been completed, with the soil that was removed from it per the BLM request included
in Tab B.
EFRI will provide at least 15 days notice of the annual sampling event conducted between May 1 and July
15 in order to allow DWMRC to collect split water quality samples of the seeps and springs.
3.0 Field Sampling Procedures
The field sampling and data collection program will obtain samples to be analyzed for the groundwater
compliance parameters listed in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using the methods specified in the currently approved EFRI Quality Assurance Plan
for Groundwater sampling ("QAP"). Minimum detection limits or reporting limits for seeps and springs
analyses will be less than or equal to the Groundwater Quality Standards defined in Table 2 of the
GWDP. The minimum detection limits for total dissolved solids ("TDS"), sulfate, and chloride will be 10
mg/L, 1 mg/L, and 1 mg/L respectively.
Field activities include collecting samples, recording of field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling procedures employed at each location will be dependent on the site location and access.
Several sampling methodologies may be employed during one annual event based on access limitations
and flow rates of the seeps and springs that are sampled. Potential sampling methodologies are briefly
described below.
Direct Collection
Direct collection of the samples involves collecting the sample directly into the sample container from the
surface water feature or from spring out-flow. In instances where direct collection is employed the
parameters which require filtration will be collected by one of two methods. In the first method, the
peristaltic pump will be used to draw the sample from the out-flow and pump it through a 0.45 micron
filter directly into the appropriate sample container. The second method is used in situations with limited
access for the generator required to run the peristaltic pump. When the generator cannot be used, a large,
unused sample jug will be used to collect the sample. The peristaltic pump will then be used to transfer
the sample from the large sample jug to the sample bottles through a 0.45 micron filter. This filtration
and pumping will be completed at a location where there is access for the generator.
Peristaltic Pump
Sample collection with a peristaltic pump involves collecting the sample from the source or out-flow
using the peristaltic pump. The peristaltic pump is used to deliver the sample from the source or out-flow
to the sample bottles. Filtered parameters are pumped through a 0.45 micron filter prior to delivery to the
sample bottle.
Sample Ladle
Sample collection using a ladle involves dipping or filling a ladle made from an inert material into the
surface water source or out-flow and filling the ladle. The sample is transferred from the ladle to the
sample bottles. This process is repeated until the sample bottles are filled. Filtered parameters are
collected into a large, unused sample jug. The peristaltic pump is then used to transfer the sample from
the large sample jug to the sample bottles through a 0.45 micron filter.
3.1 Field Data
In addition to the analytical parameters noted above, field data will be recorded at the time of sample
collection. Field parameters required by the GWDP include pH, specific conductance and temperature.
Additional field parameters such as oxidation reduction potential ("REDOX") and turbidity may be
measured as available sample volume allows. Field data will be recorded on the Field Data Record
included in Tab C of this SAP.
The dates of the site visits, the availability of surface water for sampling, and the possibility for
development will be recorded on the field data sheets for inclusion in the annual report.
3.2 Decontamination
Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable
sampling equipment is used to collect samples. Decontamination procedures will be as described in the
approved QAP. Rinsate blanks will be collected daily after decontamination of sampling equipment. If
disposable or dedicated sampling equipment is used to collect samples then rinsate blanks will not be
collected.
3.3 Field QC
The field QC samples generated during the annual seeps and springs sampling event will include sample
duplicates, trip blanks, and rinsate blank samples as appropriate.
Sample Duplicate ·
Sample duplicates will be collected at a frequency of one duplicate per 20 field samples. Sample
duplicates will be collected by filling the sample container for a certain analytical parameter for the
duplicate immediately following the collection of the parent sample for that parameter.
Trip Blanks
Trip blank samples will be included in every shipment of samples that has field samples to be analyzed
for Volatile Organic Compounds ("VOCs"). Trip blank samples are VOC sample containers filled by the
analytical laboratory with laboratory grade deionized water and shipped to the site. Trip blank samples
are taken into the field with the sample containers, never opened, and kept with the field samples from
collection through shipment to the analytical laboratory for analysis. Trip blanks are analyzed to
determine if the sample concentration of VOCs have been effected by the "trip" from collection through
shipment.
Rinsate Blank Samples
Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated,
reusable sampling equipment is used to collect samples. If the sampling equipment has a disposable
component that comes in contact with the samples and the component is changed prior to sampling at
each location then a rinsate blank sample will not be collected. For example, if a peristaltic pump is used
to collect and filter seeps and springs samples and the tubing used in the peristaltic is changed at each
location and never reused for more than one sample, no rinsate blank sample would be required.
3.4 Sample Handling
Seeps and springs sampling events will be subject to the applicable sample handling requirements noted
in the approved QAP.
4.0 QA and Data Evaluation
The Permit requires that the annual seeps and springs sampling program be conducted in compliance with
the requirements specified in the Mill's approved QAP, the approved SAP and the Permit itself. To meet
this requirement, the data validation for the seeps and springs sampling program will utilize the
requirements outlined in the QAP, the Permit and the approved SAP as applicable. The Mill QA
Manager will perform a QA/QC review to confirm compliance of the monitoring program with
requirements of the Permit, QAP and SAP. As required in the QAP, data QA includes preparation and
analysis of field QC samples, review of field procedures, an analyte completeness review, and quality
control review of laboratory data methods and data.
The QAP and the Permit identify the data validation steps and data quality control checks required for the
seeps and springs monitoring program. Consistent with these requirements, the Mill QA Manager will
performed the following evaluations: a field data QA/QC evaluation, a receipt temperature check, a
holding time check, an analytical method check, a reporting limit check, a trip blank check, a QA/QC
evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each laboratory's
reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
Samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP
using the analytical methods and specified reporting limits contained in the approved QAP. Laboratories
used for the seeps and springs sampling program will be Utah certified as required by the GWDP Part
l.E.6 (c). Laboratory data will be validated as described in the approved QAP and as described in Section
4.0 above. Analytical QC is described below.
5.1 Analytical Quality Control
Analytical QC samples and protocols are described in the approved QAP. Laboratory QC procedures will
meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for
by the State of Utah.
The analytical QC samples included at least the following: a method blank, a laboratory control spike
("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where
applicable. It should be noted that:
• Laboratory fortified blanks are equivalent to LCSs.
• Laboratory reagent blanks are equivalent to method blanks.
• Post digestion spikes are equivalent to MSs.
• Post digestion spike duplicates are equivalent to MSDs.
• For method E900.l, used to determine gross alpha, a sample duplicate was used instead of a
MSD.
All qualifiers, and the corresponding explanations reported in the QA/QC Summary Reports for any of
the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager.
The effect on data usability will be discussed in the evaluation section of the annual report.
5.2 Evaluation of Analytical Data
An evaluation of the analytical data will be completed in the annual report. A discussion of the results
will be included which will summarize the data relative to any detections reported in the samples with
comparisons as appropriate to the Mill groundwater quality data.
6.0 Reporting
EFRI will collect seeps and springs samples annually as required by the GWDP Part 1.F.7. Each report
will: 1) document the sampling event by means of providing the field sheets recorded at the time of
sampling; 2) transmit copies of all field measurements and laboratory results; 3) provide a water table
contour map that includes water table elevation of all groundwater monitoring wells at the facility and the
elevations of the phreatic surfaces observed at each of the seeps and springs sampled; and 4) provide an
evaluation and interpretation of the groundwater quality data collected. Specific reporting requirements
for the seeps and springs sampling program will include but are not limited to:
• The annual seeps and springs monitoring report will be included with the 3rd quarter Routine
Groundwater Monitoring Report due on December 1, of each year.
• The seeps and springs water table contour map will include all water level data measurements
from all monitoring wells at the site from the 3rd quarter groundwater monitoring event for each
year.
• The seeps and springs water table contour map shall be at the map scale such that all seeps and
springs listed in this Plan and monitor wells at the site may be seen on one map.
Table 1
s eeps an 1prm2s urvey n orma ion dS . S It f
December 2009 Survey
Location Latitude (N) Longitude (W) Elevation
FROG POND 37°33'03.5358" 109°29'04.9552" 5589.56
CORRAL CANYON 37°33'07.1392" 109°29'12.3907" 5623.97
ENTRANCE SPRING 37°32'01 .6487" 109°29'33.7005" 5559.71
CORRAL SPRINGS 37°29'37.9192" 109°29'35.8201" 5383.35
RUIN SPRING 37°30'06.0448" 109°31 '23.4300" 5380.03
COTTONWOOD 37°3 l '21.7002" 109°32'14.7923" 5234.33
WESTWATER 37°3 l '58.5020" 109°31 '25.7345" 5468.23
Verification Survey July 2010
RUIN SPRING 37°30'06.0456" 109°31 '23.4181" 5380.01
COTTONWOOD 37°3 l '21.6987" 109°32'14.7927" 5234.27
WESTWATER 37°31'58.5013" 109°31 '25.7357" 5468.32
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--I --, -Denison Property Boundary --·---Ute Mtn. Ute ~eservation Boundary
• • Canyon Rim
ENERGY FUELS
White Mesa Mill
N :e: UT
09-11 I GM , Location:
12,11 I GM
SEEPS AND SPRINGS LOCATION MAP
Aulllor: HRR Dale: Nov. 3, 2003 I Drafted 8y: BM
Attachment B
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Monticello Field Office
IN REPLY REFER TO:
P.O. Box 7
Monticello, Utah 84535
http://www.blm.gov/utah/monticello
TAKE PRICE'
INAME.RICA
MAY o 3 2011
LOAs
UTY020
RECEIVED
I l
Jo Ann Tischler Fi-1'=======-
Denison Mines (USA) Corp.
Director, Compliance and Permitting
1050 17th Street, Suite 950
Denver, CO, US, 80265
Dear Ms. Tischler:
As per your phone conversation with Realty Specialist Maxine Deeter last week, this letter
authorizes Denison to do water sampling on public lands administered by the Bureau of Land
Management adjacent to the White Mesa Mill south of Blanding, Utah. We understand that the
sampling will consist of hand digging two cubic feet square holes at springs which do not contain
standing water and leaving the holes to fill with water so that it can be tested in compliance with
Department of Environmental Quality (DEQ) requirements. As Maxine stated on the phone, we
do not consider this to be "development" of these springs but rather meets the definition of
casual use of public lands. We would request that these test holes be filled again with the soil
that was removed from them.
If you have questions or concerns, please contact Maxine at 435-587-1522 or via email.
Sincerely,
Thomas A. Heinlein
Field Office Manager
Attachment C
Field Data Record-Seeps and Springs Sampling
Seep or Spring Location: ----------------------
Date For Initial Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Second Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Third Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Fourth Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Sampling Personnel:
Weather Conditions at Time of Sampling: _______________ _
Estimated Seep or Spring Flow Rate: ------------------
Field Parameter Measurements:
-pH
-Temperature (°C) ______________ _
-Conductivity µMHOC/cm ___________ _
-Turbidity (NTU) (if measured) __________ _
-Redox Potential Eh (m V) (if measured) ______ _
Analytical Parameters/Sample Collection Method:
Pairameter Sampl Taken Filtered Sa•i,lin2 M:ethed
voes o Yes D No o Yes oNo
Metals D Yes oNo o Yes DNo
Nutrients o Yes D No o Yes DNo
Other Non o Yes oNo o Yes DNo
Radiologies
Gross Alpha D Yes D No o Yes D No
QC Samples Associated with this Location:
D Rinsate Blank
o Duplicate
Dh:ect Peristaltk
Pu.n:ip
-
D D
D D
D D
D D
D D
Duplicate Sample Name: ___________ _
Ladl other
(~in
netes seem,~j
D D
D D
D D
D D
D D
Notes: ______________________________ _
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
October 14, 2019
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
?91~
t.1/!ERGYFUELS
Contents
1.0 OBJECTIVE ......................................................................................................................... 1
1 .1 Plan Organization ............................................................................................................. 1
2.0 RESPONSIBILITIES ............................................................................................................ 2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS ...................................................... 2
4.0 DESCRIPTION OF BASINS ................................................................................................. 2
4.1 Basin A1 ...................................................................................................................... 2
4.2 Basin A2 ...................................................................................................................... 2
4.3 Basin 81 ...................................................................................................................... 2
4.4 Basin 82 ...................................................................................................................... 3
4.5 Basin 83 ...................................................................................................................... 3
4.6 Basin C ........................................................................................................................ 3
4.7 Basin D ........................................................................................................................ 3
4.8 Basin E ........................................................................................................................ 3
4.9 Basin F ........................................................................................................................ 3
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT ........................... 3
5.1 Reagent Tanks (Tank list included in Table 2.0) .......................................................... 4
5.2 Ammonia ..................................................................................................................... 4
5.3 Ammonium Meta-Vanadate ......................................................................................... 4
5.4 Caustic Storage (Sodium Hydroxide) ........................................................................... 4
5.5 Sodium Carbonate (Soda Ash) .................................................................................... 4
5.6 Sodium Chlorate .......................................................................................................... 4
5.7 Sulfuric Acid ................................................................................................................. 5
5.8 Vanadium Pentoxide .................................................................................................... 5
5.9 Kerosene (Organic) ...................................................................................................... 5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT ............................................ 5
6.1 Petroleum Tanks .......................................................................................................... 6
6.1.1 Diesel ................................................................................................................... 6
6.2 Aboveground Fuel Pump Tanks ................................................................................... 6
6.2.1 Diesel ................................................................................................................... 6
6.2.2 Unleaded Gasoline ............................................................................................... 6
6.2.3 Pump Station ........................................................................................................ 6
6.3 Used/Waste Oil. ............................................................................................................... 6
6. 4 Truck Unloading .............................................................................................................. 7
7.0 SPILL DISCOVERY AND REMEDIAL ACTION ................................................................... 7
8.0 SPILL INCIDENT NOTIFICATION ....................................................................................... 8
8.1 External Notification ........................................................................................................ 8
8.2 Internal Notification ......................................................................................................... 8
9.0 RECORDS AND REPORTS ................................................................................................ 9
10.0 SPILL REPORTING REQUIREMENTS ............................................................................. 10
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES ............................. 10
11.1 Training Records ........................................................................................................ 10
11.2 Monitoring Reports ...................................................................................................... 1 O
12.0 REVISION ......................................................................................................................... 10
13.0 MILL MANAGER APPROVAL ........................................................................................... 11
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER ................................. 11
15.0 SUMMARY ........................................................................................................................ 12
WIDTE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN FOR
CHEMICALS AND PETROLEUM PRODUCTS
1.0 OBJECTIVE
The objective of the Spill Prevention, Control, and Countermeasures (SPCC) Plan is to serve
as a site-specific guideline for the prevention of and response to chemical and petroleum
spills. The plan outlines spill potentials, containment areas, and drainage characteristics of
the White Mesa Mill site. The plan addresses chemical spill prevention, spill potentials, spill
discovery, and spill notification procedures. Spills are reportable if the spill leaves the site.
Ammonia is the only chemical (as vapor) that has the potential to leave the site. In addition,
chemical and petroleum spills will be reported in accordance with applicable laws and
regulations.
1.1 Plan Organization
This SPCC is organized as follows:
Section 1.0 Objective
Section 2.0 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4.0 Description of Basins
Section 5.0 Potential Chemical Spill Sources and Spill Containment
Section 6.0 Potential Petroleum Spill Sources and Containment
Section 7 .0 Spill Discovery and Remedial Action
Section 8.0 Spill Incident Notification
Section 9.0 Records and Reports
Section 10.0 Spill Reporting Requirements
Section 11.0 Personnel Training and Spill Prevention Procedures
Section 12.0 Revision
Section 13.0 Mill Manager Approval
Section 14.0 Certification by Registered Professional Engineer
Section 15.0 Summary
Tables:
Table 1.0 is the Energy Fuels Resources (USA) Inc. (EFRI) personnel responsible for
implementing this SPCC.
Table 2.0 lists the reagent tanks and their respective capacities.
Table 3.0 lists the laboratory chemicals, their typical quantities in stock, and their reportable
quantities.
Table 4.0 lists the reagent yard and bulk chemical list.
Table 5.0 lists the petroleum products and solvents on site.
1
Figures:
Figure 1 shows the Mill Site Layout, shows the mill site including the locations of the
chemical tanks on-site.
Figure 2 shows the basins and drainage ditch areas for the Mill Site.
Figure 3 shows the organization chart for Mill Operations.
2.0 RESPONSIBILITIES
Personnel responsible for spill prevention and follow-up spill reporting are included on Table
1, which is included in the Tables Tab of this SPCC.
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS
The main drainage pathways are illustrated in Figure 2. The map shows drainage basin
boundaries, flow paths, constructed diversion ditches, tailing cells, the spillway between Cell
3 and 4A, dikes, berms, and other relevant features. The White Mesa Mill is a "zero"
discharge facility for process liquid wastes. The mill area has been designed to ensure that
all spills or leaks from tanks will drain toward the lined tailing management system.
The management system, in turn, is operated with sufficient freeboard (minimum freeboard
as required by the Groundwater Discharge Permit [GWDP]) to withstand 100% of the PMP
(Probable Maximum Precipitation). This allows for a maximum of 10 inches of rain at any
given time.
Precipitation and unexpected spills from the mill site are contained within their prospective
drainage basins. Overflow ultimately drains into the tailings management system.
4.0 DESCRIPTION OF BASINS
4.1 Basin Al
Basin Al is north of Cell 1 and Diversion Ditch No. 1. The basin contains 23 tributary acres,
all of which drain into Westwater Creek.
4.2BasinA2
Basin A2 contains all of Cell 1 including an area south of the Diversion Ditch No. 1 and a
portion of Cell 2. The basin covers 104.3 acres. Any overflow from this basin would be
contained within Cell 1.
4.3 Basin Bl
Basin B 1 is north of the mill area. The basin contains 45 .4 tributary acres.
Overflow from this basin drains into a flood retention area by flowing through Diversion
Ditch No. 2. Diversion Ditch No. 2 drains into Westwater Creek.
2
4.4 Basin B2
Basin B2 is northeast of the mill area and contains only 2.6 tributary acres. Overflow from
this basin would drain into Diversion Ditch No. 3. Diversion Ditch No. 3 ultimately drains
into Diversion Ditch No. 2.
4.5 Basin B3
Basin B3 contains most of the mill area, buildings, ore stockpiles, process storage tanks,
retention ponds, spill containment structures, pipelines, and roadways. The normal direction
of flow in this basin is from the northwest to the southwest. Any overflow from this basin
would drain into Cell 1. The basin contains 64 acres. This basin has sufficient freeboard to
withstand 100% of the PMP (Probable Maximum Precipitation). This allows 10 inches of
rain for any given storm event.
4.6 Basin C
Basin C contains a portion of Cell 2. The basin consists of 60.4 acres. Areas in this basin
also include earth stockpiles and the heavy equipment shop. The direction of flow in this
basin is to the south-southwest. All overflows in this basin is channeled along the southern
edge of the basin. Overflow then flows into Cell 3 along the length of the boundary between
Cell 2 and Cell 3.
4.7 Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including a portion of the
slopes of the topsoil stockpile and random stockpile. The basin contains all flows, including
those caused by the PMP.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4A.
4.9 Basin F
Basin F contains Cell 4B, and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4B.
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT
Routine monitoring is conducted of the reagent tanks and storage areas. Daily visual
monitoring of the reagent tanks and storage areas are conducted during the twice-daily shift
inspections. Weekly visual monitoring of the tank supports and foundations are conducted
by the Radiation Safety Officer ("RSO") or designee. The scope of the daily and weekly
visual monitoring includes an inspection for leaks or visual structural abnormalities. Any
issues identified during the routine visual monitoring would be noted as such on the
3
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
5.1 Reagent Tanks (Tank list included in Table 2.0)
5.2Ammonia
The ammonia storage tanks consist of two tanks with a capacity of 31,409 gallons each. The
tanks are located southeast of the Mill building.
Integrity inspections will be conducted to minimize the hazard associated with ammonia.
The reportable quantity for an ammonia spill is 7 gallons.
Ammonia spills should be treated as gaseous. Ammonia vapors will be monitored closely to
minimize the hazard associated with inhalation. If vapors are detected, efforts will be made
to stop or repair the leak expeditiously. Ammonia is the only chemical (as vapor) that has the
potential to leave the site.
5.3 Ammonium Meta-Vanadate
Ammonium meta-vanadate is present in the vanadium precipitation area of the Mill building
as the process solutions move through the circuit to produce the vanadium end product.
Spills would be contained in the process sump within the vanadium precipitation area. The
reportable spill quantity for ammonium meta-vanadate is 1,000 pounds.
5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner of the SX
building. The tank has a capacity of 19,904 gallons. The tank supports are mounted on a
concrete curbed catchment pad which directs spills into the sand filter sump in the northwest
corner of the SX building. The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located outside the
northeast corner of the SX building. Spills from the soda ash solution tank are contained in
the North SX impound and run to Cell 1. The smaller soda ash shift tank has a capacity of
8,530 gallons and is located in the SX building. Spills will be diverted into the boiler area,
and would ultimately drain into Cell 1. There is no reportable spill quantity associated with
sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of three fiberglass tanks located within a dike east of the SX
building. Tank maximum volumes of the three tanks are 16,075, 21,057 and 28,788 gallons.
Integrity inspections will be conducted to minimize the hazard associated with sodium
chlorate.
4
Sodium chlorate that has dried and solidified becomes even more of a safety hazard due to its
extremely flammable nature. The reportable spill quantity for sodium chlorate is 400
gallons.
5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of 1,600,000
gallons and one smaller tank with a capacity of 11,000 gallons.
The large tank is located in the northwest corner of mill area basin B3 and is primarily used
for acid storage and unloading. The tank support for the large tank is on a mound above a
depression which would contain a significant spill. All flows resulting would be channeled
to Cell 1. The tank is equipped with a high level audible alarm which sounds prior to tank
overflows. A concrete spill catchment with a sump in the back provides added containment
around the base of the tank. However, the catchment basin would not be able to handle a
major tank failure such as a tank rupture. The resulting overflow would flow towards Cell 1.
The smaller storage tank is located on the north side of the SX building. The tank is
equipped with a high level audible alarm.
The reportable spill quantity for sulfuric acid is 65 gallons.
5.8 Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the drying and fusing
circuits and is not present in the vanadium circuit until after the deammoniator. Efforts will
be made to minimize leaks or line breaks that may occur in processes in the circuit that
contain vanadium pentoxide. Special care will be taken in the transportation of this chemical.
The reportable spill quantity for vanadium pentoxide is 1000 pounds.
5.9 Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a combined capacity of
10,152 gallons in three tanks. Any overflow from these three tanks would flow around the
south side of the SX building and then into Cell 1. These tanks have drain valves which
remain locked unless personnel are supervising draining operations. The reportable spill
quantity for kerosene is 100 gallons.
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
Routine inspections are conducted of the petroleum containment, tanks, and storage areas.
Daily visual monitoring of the petroleum containment, tanks, and storage areas are conducted
during the twice-daily shift inspections. Weekly visual monitoring of the tank supports and
foundations are conducted by the RSO. The scope of the daily and weekly visual monitoring
includes an inspection for leaks or visual structural abnormalities. Any issues identified
during the routine visual monitoring would be noted as such on the associated
documentation. If no issues are noted, the system, tanks or storage area condition was
considered acceptable.
5
Annual visual inspections of the used/waste oil and fuels tanks will be completed as
discussed in the Discharge Minimization and Technology Monitoring Plan, Revision 12.4,
Section 4.3.
6.1 Petroleum Tanks
6.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The tanks have
capacities of 250 gallons each. One of the diesel tanks is for the emergency generator.
The other tank is located in the pumphouse on an elevated stand. Spillage from either
tank would ultimately flow into Cell 1. The reportable spill quantity for diesel is 100
gallons. The spill is also reportable if the spill has the potential for reaching any nearby
surface waters or ground waters.
6.2 Aboveground Fuel Pump Tanks
6.2.1 Diesel
The diesel tank is located on the east boundary of Basin B3 and has a capacity of 6,000
gallons. The tank is contained within a concrete catchment pad. The reportable spill
quantity for diesel is 100 gallons. A diesel spill is also reportable if the spill has the
potential for reaching any surface waters or ground waters.
6.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded gasoline tank
has a capacity of 3,000 gallons and is contained within the same containment system as
the diesel tank. Spills having the potential for reaching any surface waters or ground
waters will need to be reported. The reportable spill quantity for unleaded gasoline is 100
gallons.
6.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling company
vehicles used around the mill site. The pump station is equipped with an emergency
shut-off device in case of overflow during fueling. In addition, the station is also
equipped with a piston leak detector and emergency vent. Check valves are present along
with a tank monitor console with a leak detection system. The catchment is able to
handle a complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a temporary berm
would need to be constructed. Absorbent diapers or floor sweep would be used in an
effort to limit and contain the spill. The soil would have to be cleaned up and placed in
the Cell currently used for the disposal of solid Mill wastes.
6.3 Used/Waste Oil
Used/ Waste oil is located north of the maintenance shop in a tank and has a capacity of
5,000 gallons. The tank is contained within a concrete containment system. Used oil will be
disposed of on site or sent to an EPA permitted recycling facility. Any oil escaping the
6
concrete containment system will be cleaned up. Soil contaminated with used oil will be
excavated and disposed of in the Cell currently used for the disposal of solid Mill wastes.
6. 4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill area, proper
reporting and containment procedures will be followed when warranted, such as when oil or
diesel fuel is spilled. Proper clean-up procedures will be followed to minimize or limit the
spill. The spill may be temporarily bermed or localized with absorbent compounds. Any
soils contaminated with diesel fuel or oil will be cleaned up and placed in the Cell currently
used for the disposal of solid Mill wastes.
7.0 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take measures to
limit additional spillage and contain the spill that has already occurred. Chemical or
petroleum spills will be handled as follows:
• The Shift Foreman will direct efforts to shut down systems, if possible, to limit
further release.
• The Shift Foreman will also secure help if operators are requiring additional
assistance to contain the spill.
• The Shift Foreman is also obligated to initiate reporting procedures.
• Once control measures have begun and personal danger is minimized, the Shift
Foreman will notify the Production Superintendent, Maintenance Superintendent,
or Mill Manager.
• The Production or Maintenance Superintendent will notify the Mill Manager, who
in tum will notify the RSO and the Environmental Coordinator.
• The Mill Manager will assess the spill and related damage and direct remedial
actions. The corrective actions may include repairs, clean-up, disposal, and
company notifications. Government notifications may be necessary m some
cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
7
8.0 SPILL INCIDENT NOTIFICATION
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
1-800-424-8802
301-816-5100
801-538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission
2. State of Utah, Natural Resources
8.2 Internal Notification
301-816-5100
801-538-7200
Internal reporting requirements for incidents, spills, and significant spills are as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits operations or assesses
penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-product
8
In the event of a spill requiring reporting, the Mill Manager is required to call the RSO,
Quality Assurance Manager, the Chief Operating Officer, and/or the President and Chief
Executive Officer. The spill will first be reported to the Shift Foreman. The Shift Foreman
will then report the spill to the Mill Superintendent, Maintenance Superintendent, or Mill
Manager.
The Mill or Maintenance Superintendent will report to the Mill Manager. The RSO and the
Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Logan Shumway Mill Manager ( 435) 459-9878
Terry Slade RSO [phone]
Garrin Palmer Assistant RSO/Mill Environmental
Compliance [phone]
Coordinator
Thayne Holt Production Superintendent ( 435) 459-1783
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Mark Chalmers President and Chief Executive
Officer [phone]
Paul Goranson Chief Operating Officer [phone]
Scott Bakken Sr. Director, Regulatory Affairs [phone]
Kathy Weinel Quality Assurance Manager [phone]
In the event the next person in the chain-of-command cannot be reached, then proceed up the
chain-of-command to the next level. Figure 3.0 shows the organizational cha1t for the mill
site.
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the Environmental
or Maintenance Department for inspection and review for a minimum of five years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection
d. Quarterly Tailings Inspection
e. Daily Operating Foreman and weekly RSO inspection reports
9
2. Annual used/waste oil and fuel tank visual inspections
3. Tank thickness tests
4. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
5. Tank supports and foundation inspections
6. Spill Incident reports
7. Latest revision of SPCC plan
10.0 SPILL REPORTING REQUIREMENTS
1. Report to applicable government agency as required by laws and regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of spill
impacts
4. Report release of 5,000 pounds or more of any process material or waste product
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES
All new employees are instructed on spills at the time they are employed and trained. They
are briefed on chemical and petroleum spill prevention and control. They are informed that
leaks in piping, valves, and sudden discharges from tanks should be reported immediately.
Abnormal flows from ditches or impoundments are of immediate concern. In addition, a
safety meeting is presented annually by the Environmental Coordinator to review the SPCC
plan.
11.1 Training Records
Employee training records on chemical and petroleum spill prevention are maintained in the
general safety training files.
11.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
12.0 REVISION
This procedure is to be reviewed by the mill staff and a registered professional engineer at
least once every three years, and updated when circumstances warrant a revision.
10
13.0 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with the Standard
Operating Procedures currently in effect.
~umway
Mill Manager
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with good
engineering practices.
/ Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
11
15.0 SUMMARY
Chemical and petroleum spills will be reported in accordance with applicable laws and
regulations. Spills that leave the property need to be reported immediately. Each spill
will be assessed and reported as required by the applicable regulations. Reportable
quantities are shown in the attached tables.
12
TABLES
TABLE 1.0
RESPONSIBILITIES
Person in charge of facility responsible for SJ:till prevention:
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill r.ep·orting: -
Terry Slade
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
QUANTITY
2
2
3
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
TABLE2.0
REAGENT TANK LIST
REAGENT
AMMONIUM SULFATE
DIESEL
KEROSENE
USED/WASTE Oil.,
DIESEL
UNLEADED
PROPANE
LNG
AMMONIA
WEST SALT
SALT Dll.,UTION
SODIUM HYDROXIDE
SODA ASH SOLUTION
SODA ASH SHIFT
SODA ASH Sll.,O
SODIUM CHLORATE
SODIUM CHLORATE
SODIUM CHLORATE
SULFURIC ACID
SULFURIC ACID
CAPACITY (GAL)
24,366
250
10,152
5,000
6,000
3,000
30,000
30,000
31,409
17,635
9,451
19,904
16,921
8,530
22,841
16,075
21 ,057
28,788
1,600,000
11,000
TABLE3.0
LABO RA TORY CHEMICAL INVENTORY LIST1
:r
Chemical in Lab RQ2 Typical Quantity In Stock
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 Lor 571 gal.) lOL
Aluminum nitrate 5,000 lb (2,270 kg) 20kg
Ammonium carbonate 5,000 lb (2,270 kg) 2kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5L
Ferric chloride 1,000 lb (454 kg) 2kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) lL
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate O.lN 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb ( 454 kg) 1 kg
Chemical in Volatiles and RQ2,3 Typical Quantity in Stock Flammables Lockers (A,B,C)
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2L
Chloroform 10 lb ( 4.54 k_g) ( approx. 3.1 L) lL
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) lL
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2L
Toluene 1,000 lb (454 kg) (approx. 523 L) 12 L
Chemical in Outside Acid RQ2,3 Typical Quantity in Stock Conex
Hydrochloric acid 5,000 lbs (2,270 kg) (a_pprox. 1,894 Lor 501 gal.) 22L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 L
1. This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
The lab also stores small quantities of other materials that are not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117 .3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE4.0
REAGENT YARD AND BULK CHEMICALS L1ST1
Reagent RQz Typical Quantity In
Stock
Sulfuric acid 93 to 98% 1,000 lb ( 454 kg) 4,000,000 lb (aoorox. 247 L)
Ammonia -East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia -West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb ( 454 kg) 60,000 lb
in 50% solution
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb ( 454 kg) 50,000 lb
Y ellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
1. This list identifies the bulk chemicals and the chemicals in the reagent yard whether
or not they are regulated as hazardous substances under the Federal Water Pollution
Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117 .3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of
the Clean Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the
Reagent Yard itself, but are present in closed containers in the Mill Building and/or Mill
Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or
Utah regulations. These values are used by the Mill for conservatism as Best
Management Practices.
,:
TABLES.O
PETROLEUM PRODUCTS AND SOLVENTS LIST1
Reagent RQ2,3,4 Typical Quantity In Stock
-
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg) 50 gallons (approx. 13.9 gal)
Acetone 5,000 lb (2,270 kg) 55 gallons (362 lbs) (approx. 759 gal)
Methyl Ethyl Ketone 5,000 lb (2,270 kg) 55 gallons (369 lbs) (approx. 745 gal)
Toluene 1000 lbs ( 454 kg) 0 gallons (approx. 138 gal)
Varsol Solvent (2% trimethyl 100 gal* 0 gallons benzene in petroleum distillates)
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117 .3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound ( 100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
,,
\
\ /; / ~ .r-,
N
100 50 0 100 200
SCALE IN FEET
-
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
ergy Fuels Lakewood, CO 80228
REVISIONS
Date By ounty: San Juan
10-11 GM Location:
5-14 DLS
4-16 RE
WHITE MESA MILL
late: Utah
Figure 1
MILL SITE LAYOUT
cae: 1"=200' Date: May 12, 2000 Drafted By: D.Sledd
Mill Sile Layout 4.28.16 dwg Figure 11
DRAINAGE BASIN "F"
44.67 AC
PMF CONTAINED
WITHIN BASIN
Jr
' 1000 1000 2000
D~AGE
BASIN "Aj_'
104.27 AC.
DRAINAGE BASI
42.14 AC.
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
Project:
County: Sa n Juan
LocatTon:
HRR
MILL SITE
DRAINAGE BASINS
FIGURE2
Date: 2005 Drafted By:
Figure 3
Energy Fuels Resources (USA) Inc.
Mill Management Organization Chart
President & CEO
I
Chief Operating CFO, General
Counsel, Corp
I
Mill Operations
Personnel
I
Radiation Safety
Technician{s)
Officer
I
Mill Manager
MillRSO
Environmental
Technician(s)
Secretary
I I
I I I I I
Senior Dir.
Regulatory Affairs
I
Safety Coordinator
~ -,
--i
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
October 14, 2019
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
TABLE OF CONTENTS
Best Management Practices Plan
Revision 1.6: October 2019
1.0 INTRODUCTION/PURPOSE ........................................................................................... 2
2.0 SCOPE ............................................................................................................................... 3
3.0 RESPONSIBILITY ............................................................................................................ 4
4.0 BEST MANAGEMENT PRACTICES .............................................................................. 5
4.1 General Management Practices Applicable to All Areas ....................................... 5
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: ........ 5
4.1.2 Keep Potential Pollutants from Contact with Precipitation ............................ 5
4.1.3 Keep Paved Areas from Becoming Pollutant Sources ..................................... 5
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels
within the Process and Reagent Storage Area ............................................................... 5
4.1.5 Recycle Fluids Whenever Possible: .................................................................... 5
4.2 Management Practices for Process and Laboratory Areas ................................... 6
4.2.1 Clean Up Spills Properly .................................................................................... 6
4.2.2 Protect Materials Stored Outdoors .................................................................... 6
4.2.3 Management ........................................................................................................ 6
4.2.4 Materials Management ....................................................................................... 6
4.3 Management Practices for Maintenance Activities ................................................ 7
4.3.1 Keep a Clean Dry Shop ....................................................................................... 7
4.3.2 Manage Vehicle Fluids ........................................................................................ 7
4.3.3 Use Controls During Paint Removal ................................................................. 7
4.3.4 Use Controls During Paint Application and Cleanup ...................................... 7
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment.. ...... 7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas ................................... 7
4.4.2 Manage Stockpiles to Prevent Wind borne Contamination ............................. 8
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources ................... 8
Figures
Figure 1: White Mesa Mill Site Layout
Figure 2: White Mesa Mill Site Drainage Basins
Figure 3: Energy Fuels Resources (USA) Inc.-White Mesa Mill Management Organization Chart
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP
TABLE 2.0: REAGENT YARD LIST
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST
TABLE 4.0: REAGENT YARD AND BULK CHEMICALS LIST
TABLE 5.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Page 1
1.0 INTRODUCTION/PURPOSE
Best Management Practices Plan
Revision 1.6: October 2019
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Uranium Mill (the "Mill")
in Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect
to water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to EFRI on March 8,
2005. As a part of compliance with the Permit, EFRI is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Director of the Division of Waste Management and
Radiation Control ("DWMRC"), Utah Department of Environmental Quality. This BMPP
presents operational and management practices to minimize or prevent spills of chemicals or
hazardous materials, which could result in contaminated surface water effluents potentially
impacting surface waters or ground waters through runoff or discharge connections to stormwater
or surface water drainage routes. Although the Mill, by design, cannot directly impact
stormwater, surface water, or groundwater, the Mill implements these practices in a good faith
effort to minimize all sources of pollution at the site.
Page 2
2.0 SCOPE
Best Management Practices Plan
Revision 1.6: October 2019
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surf ace runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris ( except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings management impoundments in accordance with the
Mill's Radioactive Materials License ("RML") #UT1900479 conditions. All of the process and
laboratory building sinks, sumps, and floor drains are tied to the transfer lines to the tailings
impoundments. A site map of the Mill is provided in Figure 1. A sketch of the site drainage
basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by RML to manage some spills via draining or wash down
to the process sewers, and ultimately the tailings management system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of stormwater, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
EFRI White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP"), and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs").
Page 3
3.0 RESPONSIBILITY
Best Management Practices Plan
Revision 1.6: October 2019
All Mill personnel are responsible for implementation of the practices in this BMPP. EFRI White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The EFRI Corporate Management and Mill Management Organization is presented in Figure 3.
An updated spill prevention and control notification list is provided in Table 1.
Page 4
Best Management Practices Plan
Revision 1.6: October 2019
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to AH Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
the RML. Areas requiring maintenance or repair, such as excessive vegetative growth,
channel erosion or pooling of surf ace water runoff, will be reported to site management
and maintenance departments for necessary action to repair damage or perform
reconstruction in order for the control feature to perform as intended. Status of
maintenance or repairs will be documented during follow up inspections and additional
action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings management system for disposal.
Page 5
Best Management Practices Plan
Revision 1.6: October 2019
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D. l O.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPB") near the areas where they may be needed for spill response.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 6
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windbome contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings management system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings management system.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
Page 7
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and decontamination pads).
• At the decontamination pads, make sure the water collection and recycling system is working
before turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep smfaces moist but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
TABLES
TABLE 1.0
RESPONSIBILITIES
Pel'son in char.ge of facility res_p:onsible (or ~pill prevention:
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of fo)low-11p spill reporting: --
Terry Slade
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
QUANTITY
2
2
3
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
TABLE2.0
REAGENT TANK LIST
REAGENT
AMMONIUM SULFATE
DIESEL
KEROSENE
USED/WASTE OIL
DIESEL
UNLEADED
PROPANE
LNG
AMMONIA
WEST SALT
SALT DILUTION
SODIUM HYDROXIDE
SODA ASH SOLUTION
SODA ASH SHIFT
SODA ASH SILO
SODIUM CHLORATE
SODIUM CHLORATE
SODIUM CHLORATE
SULFURIC ACID
SULFURIC ACID
CAPAClTY (GAL)
24,366
250
10,152
5,000
6,000
3,000
30,000
30,000
31,409
17,635
9,451
19,904
16,921
8,530
22,841
16,075
21,057
28,788
1,600,000
11,000
TABLE3.0
LABORATORY CHEMICAL INVENTORY LIST1
I.~. i '
Chemical in Lab RQ2 Typical Quantity In Stock
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 Lor 571 gal.) lOL
Aluminum nitrate 5,000 lb (2,270 kg) 20kg
Ammonium carbonate 5,000 lb (2,270 kg) 2kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) SL
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) SL
Ferric chloride 1,000 lb ( 454 kg) 2kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) lL
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) llb
Potassium Permanganate O. lN 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 kg) 1 kg -
Chemical in Volatiles and RQ2,3 Typical Quantity in Stock Flammables Lockers (A,B,C)
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) lL
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) IL
Nitro benzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2L
Toluene 1,000 lb (454 kg) (approx. 523 L) 12 L --
Chemical in Outside Acid RQ2,3 Typical Quantity in Stock Conex -· -
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 Lor 501 gal.) 22L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 L
1. This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
The lab also stores small quantities of other materials that are not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE4.0
REAGENT YARD AND BULK CHEMICALS L1ST1
..Reagent RQ2 Typical Quantity In
-Stock
Sulfuric acid 93 to 98% 1,000 lb (454 kg) 4,000,000 lb (annrox. 247 L)
Ammonia -East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia -West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb ( 454 kg) 60,000 lb
in 50% solution
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
1. This list identifies the bulk chemicals and the chemicals in the reagent yard whether
or not they are regulated as hazardous substances under the Federal Water Pollution
Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117 .3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of
the Clean Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the
Reagent Yard itself, but are present in closed containers in the Mill Building and/or Mill
Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or
Utah regulations. These values are used by the Mill for conservatism as Best
Management Practices.
TABLE5.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
Reagent RQi,3,4 Typical Quantity In S'to.ck
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg) 50 gallons (approx. 13.9 gal)
Acetone 5,000 lb (2,270 kg) 55 gallons (362 lbs) (approx. 759 gal)
Methyl Ethyl Ketone 5,000 lb (2,270 kg) 55 gallons (369 lbs) (approx. 745 gal)
Toluene 1000 lbs ( 454 kg) 0 gallons (approx. 138 gal)
Varsol Solvent (2% trimethyl 100 gal* 0 gallons benzene in petroleum distillates)
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117 .3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
N
100 50 0 100 200
SCALE IN FEET
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
ergy Fuels Lakewood, CO 80228
REVISIONS WHITE MESA MILL
late: Utah
Figure 1
MILL SITE LAYOUT
care: 1 ":200' Date: May 12, 2000 Drafted By: D.Sledd
Mill Sile Layout 4.28, 16.dwg Figure 11
.,..--1
DRAINAGE BASIN'"F"
44.67 AC.
PMF CONTAINED
WITHIN BASIN
~
' 1000 o 1000
I,
2000
... \j
\ ~
DRAINAGE BASI
42.14AC.
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
' eF Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
ENEllGY FUELS Lakewood, CO 80228
REVISIONS ,-rojeOl: White Mesa Mill
Date By I County; San Juan I :>late: UT
10/24/07 BM
5/16/08 BM
6/11/08 BM MILL SITE
1219/08 DLS DRAINAGE BASINS
1(7/09 BM FIGURE2
11 /15/11 GM
5/29/19 SH Author: HRR I Date: 2005 I Drafted By:
Figure 3
Energy Fuels Resources (USA) Inc.
Mill Management Organization Chart
President & CEO
I
Chief Operating CFO, General
Counsel, Corp --,
I
Mill Operations
Personnel
I
Radiation Safety
Technician(s)
Officer
I
Mill Manager
MillRSO
I
Environmental
Technician(s)
Secretary
i I I I I
Senior Dir. --l Regulatory Affairs
-·-·------·-----------------
I
Safety Coordinator
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
THE TAILINGS MANAGEMENT SYSTEM, LEAK
DETECTION SYSTEMS AND SLIMES DRAINS
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
July 8, 2016
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3 .0
July 8, 2016
Contents
1.0 Introduction ............................................................................................................................... 3
2.0 Sampling Frequency and Monitoring Requirements ................................................................ 3
3.0 Field Sampling Procedures .............................................................. · .......................................... 3
3.1 Cell Solution Sampling ...................................................................................................... , .. 4
3.1.1 Sampling with a Peristaltic Pump .................................................................................. 4
3.1.2 Sampling with a Ladle ................................................................................................... 5
3.1.3 Sampling with a Bailer .................................................................................................... 5
3.2 LOS Sampling ....................................................................................................................... 5
3.2.1 Cells 1, 2 and 3 LOS ....................................................................................................... 5
3.2.2 Cells 4A and 4B LOS .................................................................................................... 5
3.3 Slimes Drain Sampling ......................................................................................................... 5
3.4 Decontamination ................................................................................................................. ~. 6
3.5 Field QC ........................................................................................ , ....................................... 6
3.5.1 Sample Duplicates ......................................................................................................... 6
3.5.2 Trip Blanks ..................................................................................................................... 6
3.5.3 Rinsate Blank Samples .................................................................................................. 6
4.0 QA and Data Evaluation ........................................................................................................... 7
5.0 Laboratory Analysis .................................................................................................................. 7
5.1 Analytical Quality Control ............................................................................................... 7
6.0 Reporting ......................................................................................................................... _ ........... 8
7.0 Agency Notification ................................................................................................................. 8
2
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
1.0 Introduction
This Sampling and Analysis Plan ("SAP") describes the procedures for sampling solutions in the tailings
management system, Leak Detection Systems ("LDS") and slimes drains at the White Mesa Mill in
Blanding, Utah as required under Part I.E. IO of the Groundwater Discharge Permit ("GWDP") No.
UGW370004.
The objective of the sampling is to collect annual samples from the locations identified below as required
by the GWDP. This SAP specifies the sample collection requirements, procedures, analytical
methodologies, and associated Quality Control ("QC") checks, sample handling protocols and reporting
requirements for the annual cell solution, LDS and slimes drain sampling program.
2.0 Sampling Frequency and Monitoring Requirements
The sampling frequency and sample monitoring requirements for the cell solutions, LDS and slimes
drains are as specified in the GWDP. Sampling is required to be conducted on an annual basis in August
of each year for the solutions in Cells 1, 3, 4A, and 4B, the solutions in the slimes drains in Cells 2, 3, 4A,
and 4B (for Cells 3, 4A, and 4B after the commencement of dewatering), the solutions in the LDS in
Cells 4A and 4B and any detected solutions in the LDS in Cells 1, 2, and 3 at the time of the August
sampling event. Sampling locations are shown in Attachment 1.
3.0 Field SampJing Procedures
The field sampling and data collection program will obtain samples to be analyzed for the groundwater
compliance parameters listed in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using methods specified in the currently approved Energy Fuels Resources (USA) Inc.
("EFRI") Quality Assurance Plan ("QAP") for Groundwater. Additionally per the GWDP requirements,
cell solutions, LDS and slimes drain samples will be collected and analyzed for Semivolatile Organic
Compounds ("SVOCs"). Per the GWDP, the SVOCs wi11 be analyzed by Environmental Protection
Agency ("EPA") Method 8270D. Minimum detection limits or reporting limits for cell solutions, LDS
and slimes drain samples for those analytes which have Groundwater Quality Standards (GWQSs")
defined in Table 2 of the GWDP, will be less than or equal to the GWQS. The minimum detection or
reporting limits for total dissolved solids ("TDS") sulfate, chloride and SVOCs are specified in the
GWDP and are:
• TDS will be less than or equal to 1,000 mg/L,
• Sulfate will be less than or equal to 1,000 mg/L,
• Chloride will be less than or equal to 1 mg/L, and
• SVOCs will have reporting limits less than or equal to the lower limit of quantitation for
groundwater listed in Table 2 of BP A Method 8270D Revision 4, dated February 2007.
Field activities include collecting samples, recording field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling information will be recorded on the Tailings Management System and Slimes Drain Field
Sheet, (or its equivalent), included in Attachment 2.
3
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
Sample handling and preservation requirements for cell solutions, LDS and slimes drain samples are as
specified in the QAP, except for SVOCs which are not routinely collected for any other Mill sampling
program. SVOCs do not require any chemical preservation per EPA Method 8270D; however, SVOCs
are required to be chilled. Receipt temperatures, for all analytes except SVOCs, are as specified in the
QAP. The receipt temperature requirement for SVOCs is less than or equal to 6°C.
Sample collection procedures for cell solutions, LDS and slimes drain samples are as described below.
Where more than one sampling method is described, field personnel will choose a sampling method based
on field conditions and safety considerations at the time of sampling.
The gross alpha and metals sample aliquots of the cell solutions, LDSs and slimes drains will not be field
filtered or field preserved due to safety concerns associated with the filtering apparatus and the
backpressure created by the increased viscosity of these samples. The gross alpha and metals aliquots
will be filtered and preserved by the analytical laboratory within 24 hours of receipt. Field preservation of
the gross alpha and metals sample aliquots may interfere with the laboratory's ability to filter the samples
upon receipt. It is important to note that field preservation of the samples is to preclude biological growth
and prevent the inorganic analytes from precipitating. Based on the previous field data, the cell solutions,
LDS and slimes drain samples were at a pH of 3.0 or less at the time of collection without additional
preservative. The addition of preservatives in the field would add minimal if any protection from
biological growth or precipitation. The VOC sample aliquots will be preserved in the field.
Clean sample containers utilized for this sampling effort will be provided by the analytical laboratory.
3.1 Cell Solution Sampling
As noted in Section 2.0, sampling is required to be conducted on an annual basis in August of each year
for the solutions in Cells l, 3, 4A, and 4B.
Cell solution samples may be collected using a ladle, a peristaltic pump or a bailer. The procedures for
each sampling method are described below. In all instances the sampling equipment will be either
disposable or dedicated and decontamination procedures and rinsate blanks will not be required.
Sampling equipment will be inert and non-reactive.
3.1.1 Sampling with a Peristaltic Pump
Cell solution samples may be collected using a peristaltic pump. Samples collected with the peristaltic
pump will be collected by extending collection tubing approximately 6 ft. from the edge of the sampling
station. The tubing will be attached to a horizontal rod with sufficient tubing attached to lower the
suction end of the tubing to approximately 2 feet below the surface. The collection tubing will be attached
to a peristaltic pump. The tubing will be replaced prior to each use to preclude cross contamination and to
eliminate the need for decontamination of sampling equipment. Due to the nature of the peristaltic pump,
sample fluids do not come in contact with any surface other than the interior of the tubing, and
decontamination of the pump or rinsate blanks is therefore not required. The sample containers will be
filled directly from the peristaltic pump outflow. Field filtering and field preservation of the gross alpha
and metals sample aliquots will not be required, as noted in Section 3.0.
4
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
3.1.2 Sampling with a Ladle
Cell solution samples may be collected using a ladle. Samples collected with the ladle will be collected
by dipping the ladle directly into the solution. Sample bottles will be filled directly from the ladle. Ladles
used for sampling will be dedicated to each location or will be disposed after each use to preclude cross
contamination and to eliminate the need for decontamination of sampling equipment. Field filtering and
field preservation of the gross alpha and metals sample aliquots will not be completed as noted in Section
3.0.
3.1.3 Sampling with a Bailer
Cell solution samples may be collected using a disposable bailer. Samples collected with the bailer will
be collected by submerging the bailer into the solution and allowing it to fill, taking care not to allow the
bailer to contact the bottom of the cell. The bailer will withdrawn from the solution and the sample bottles
will be filled directly from the bailer. Bailers used for sampling will be disposed after each use to
preclude cross contamination and to eliminate the need for decontamination of sampling equipment.
Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as
noted in Section 3.0.
3.2 LDS Sampling
The LDS systems will be sampled as noted below.
3.2.1 Cells 1, 2 and 3 LDS
The Cells 1, 2 and 3 LDSs will only be sampled if there is fluid present during the August sampling
event. If fluids are present during the annual August sampling event, samples will be collected using the
dedicated pumps installed in the riser pipe. Fluid level will be measured using the electronic pressure
transducers currently installed in the LDS systems in the cells. Samples will be collected directly from
the pump outflow lines into the sample containers. Field filtering and field preservation of the gross alpha
and metals sample aliquots will not be required as noted in Section 3.0.
3.2.2 Cells 4A and 4B LDS
Solution from the Cell 4A and 4B LDS will be collected into a dedicated stainless steel bucket. Sample
bottles will be filled from the stainless steel bucket using either the peristaltic pump or a ladle. If the
peristaltic pump is used to transfer the solution to the sample bottles, the tubing in the pump will be
disposed of and not reused, thereby eliminating the need for decontamination of equipment or rinsate
blanks. If a ladle is used to transfer the solution to the sample bottles, the ladle will be either disposed of
or will be dedicated to that location thereby eliminating the need for decontamination or rinsate blanks.
Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as
noted in Section 3.0.
3.3 Slimes Drain Sampling
Once a tailings cell has started de-watering procedures, a sample should be collected from the slimes
drain system. At this time Cell 2 is the only slimes drain that should be sampled. The location of the
slime drain for Cell 2 is depicted on Attachment 1. While Cell 3, Cell 4A and 4B are each equipped with
5
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
a slimes drain sample access location, these Cells have not started dewatering and the slimes drain will
not be sampled until dewatering operations are underway. Because dewatering in Cell 2 is ongoing, this
cell will be included in the annual sampling effort. The Cell 2 slimes drain will be sampled using a
disposable bailer.
A disposable bailer will be used to collect Cell 2 slimes drain samples and will be used to fill clean
sample containers. The bailer will be disposed of and not reused, thereby eliminating the need for
decontamination of equipment or rinsate blanks.
3.4 Decontamination
Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable
sampling equipment is used to collect samples. Decontamination procedures will be as described in the
approved QAP. Rinsate blanks will be collected daily after decontamination of sampling equipment. If
disposable or dedicated sampling equipment is used to collect samples, then rinsate blanks will not be
collected.
3.5 Field QC
The field QC samples generated during the annual cell solution, LOS and slimes drain sampling event
will include sample duplicates, trip blanks, and rinsate blank samples as appropriate.
3.5.1 Sample Duplicates
Sample duplicates will be collected at a frequency of one duplicate per 20 field samples. Sample
duplicates will be collected by filling the sample container for a certain analytical parameter for the
duplicate immediately following the collection of the parent sample for that parameter.
3.5.2 Trip Blanks
Trip blank samples will be included in every shipment of samples that has field samples to be analyzed
for Volatile Organic Compounds ("VOCs"). Trip blank samples are VOC sample containers filled by the
analytical laboratory with laboratory grade deionized water and shipped to the site. Trip blank samples
are taken into the field with the sample containers, never opened, and kept with the field samples from
collection through shipment to the analytical laboratory for analysis. Trip blanks are analyzed to
determine if the sample concentration of VOCs have been effected by the "trip" from collection through
shipment.
3.5.3 Rinsate Blank Samples
Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated,
reusable sampling equipment is used to collect samples. If the sampling equipment has a disposable
component that comes in contact with the samples and the component is changed prior to sampling at
each location then a rinsate blank sample will not be collected. For example, if a peristaltic pump is used
to collect and filter tailings, LOS and slimes drain samples and the tubing used in the peristaltic pump is
changed at each location and never reused for more than one sample, no rinsate blank sample would be
required.
6
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
4.0 QA and Data Evaluation
The Permit requires that the annual sampling program be conducted in compliance with the requirements
specified in the Mill's approved QAP, the approved SAP and the Permit itself. To meet this requirement,
the data validation for the sampling program will utilize the requirements outlined in the QAP, the Permit
and the approved SAP as applicable. The Mill QA Manager will perform a QNQC review to confirm
compliance of the monitoring program with requirements of the Permit, QAP and SAP. As required in
the QAP, data QA includes preparation and analysis of field QC samples, review of field procedures, an
analyte completeness review, and quality control review of laboratory data methods and data.
The QAP and the Permit identify the data validation steps and data quality control checks required for the
tailings cell LDS and slimes drain monitoring program. Consistent with these requirements, the Mill QA
Manager will performed the following evaluations: a field data QNQC evaluation, a receipt temperature
check, a holding time check, an analytical method check, a reporting limit check, a trip blank check, a
QNQC evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each
laboratory's reported QNQC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
As previously stated, samples will be analyzed for the groundwater compliance parameters listed in Table
2 of the GWDP and SVOCs using the analytical methods specified in the approved QAP and EPA
Method 8270D for SVOCs. The Laboratories used for the sampling program will be Utah certified as
required by the GWDP Part l.E.6 (c). Laboratory data will be validated as described in the approved QAP
and as described in Section 4.0 above. Analytical QC is described below.
5.1 Analytical Quality Control
Analytical QC samples and protocols are described in the approved QAP. Laboratory QC procedures will
meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for
by the State of Utah.
The analytical QC samples included at least the following: a method blank, a laboratory control spike
("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where
applicable. It should be noted that:
• Laboratory fortified blanks are equivalent to LCSs.
• Laboratory reagent blanks are equivalent to method blanks.
• Post digestion spikes are equivalent to MSs.
• Post digestion spike duplicates are equivalent to MSDs.
• For method E900.l, used to determine gross alpha, a sample duplicate was used instead of a
MSD.
7
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
All qualifiers, and the corresponding explanations reported in the QNQC Summary Reports for any of
the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager.
The effect on data usability will be discussed in the evaluation section of the annual report.
6.0 Reporting
An annual Tailings System Wastewater Sampling Report will be included with the 3rd Quarter
Groundwater Monitoring Report, due each year on December 181•
Each Tailings System Wastewater Sampling Report will include the following information:
• Introduction,
• A description of sampling methodology, equipment and decontamination
procedures identify all quality assurance samples, e.g. trip blanks, equipment
blanks, duplicate samples,
• Analytical data interpretation for each tailing cell, slimes drain, and leak detection system
sample,
• A written summary and conclusions of analytical results,
• A table summarizing historic analytical results,
• A QA evaluation,
• All field data sheets accompanying the sampling event,
• Copies of the laboratory reports, and
• A "Tailings and Slime Drains System Sample Locations Map".
7.0 Agency Notification
At least 30 days advanced notice will be given to Division of Waste Management and Radiation Control
("DWMRC") prior to sampling activities described in this Tailings Management System, Leak
Detections System and Slimes Drain SAP in order to allow DWMRC to collect split samples of all
samples.
8
Attachment 1
9
~ a, 0 c..
.,
·-·· ..... ...... ~&. •
32
MW-G3 •
II
II {/
~
CELL 1
MW-17 •
MW-27 •
CELL 2
33
PIEZ,,2 •
PIEZ-3 •
.. I I 1• ........... . ---
OTW4•1fbTW4-11 OTW4-13
1W4-~
PIEZ-4 •
PIEZ-S •
OTW4•1
OTW4-40TW4-14
01W4-8
,§ 1---------------------------------------------
·5
/ :t 0 ~ :i ~ :::E 2 :c ~ 1 :,
~ cii
0 500'
SCALE: 1' • 1,000'
1,CIOD'
'i?IJI' Energy Fuels Resources (USA) Inc.
Aulhor: ----
White Mesa MIii
e: Utah
Annual Tailings System,
Cell Solution
Sample Locations
la: 11/24/15
~ w 0::
IX)
" Cl 0 a..
Cl 3: "O .;
1:' :,
Cl u::
t 0 a. (I) 0::
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0 :,
C :: C
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Cl 0 C 0 ::::.
en Cl :§ ·o
/ en a. " ::::. -;;
:i 0 .,
Q) ::::. 2 :;::: ;;:: ~ :::, / (I) ~ :, 0 Cl) ,:-:
Cl)
MW-2 •
32
MW-03 •
600" 0 500"
SCALE: 1" = 1,000'
1,000'
CELL 1
LEAK
DETECTION
SAMPLE
LOCATION
MW-17 •
CELL 2
33
PIEZ•2
PIEZ-3 •
•
T\.'V4-.i:O OTW,i-o
M •261W4.1cfl'IW.U
O OTW4-3 CTW4-12
OTW4•1foTW4-11 OTW4-13
1W4-~-8
OTW4-1
OTW4~4-14
OTW4-6
PIEZ-4 •
PIEZ-5 •
~ Energy Fuels Resources (USA) Inc.
11 .2• 15 RE
roJec:t White Mesa Mill
Alllhor.
Annual Tailings System
Slimes and Leak Detection
Sample Locations
ale: 11/24/15
Attachment 2
10
Field Data Record-Tailings Solutions, LDS and Slimes Drain Sampling
Location: _________ Sampling Personnel: ________ _
Is this a Slimes Drain? D Yes D No
If this is a Slimes Drain, measure depth to wastewater immediately before sampling.
DTW immediately before sampling (slimes only): __________ _
Weather Conditions at Time of Sampling: ________________ _
Analytical Parameters/Sample Collection Method:
' -• -.f -f' =-~:. --:---.---:.--, ;• -, 1 1 -~--;-:;;,-,T.:..=--... , l , :,,.,,',•,, .J , :, JI•_;,. ,'.1'J1:· ·'·(:•,:,·s•.,'_11 ~.!•_'.':c;_,r':-:1
·---------___ ;1_ ----~J ---~ ~ -
voes o Yes DNo o Yes DNo
Metals o Yes DNo D Yes oNo
Nutrients o Yes oNo D Yes oNo
Other Non D Yes oNo o Yes oNo
Radiologies
Gross Alpha o Yes oNo o Yes DNo
SVOCs o Yes oNo D Yes DNo
pH/Conductivity o Yes oNo o Yes oNo
QC Samples Associated with this Location:
o Rinsate Blank
D Duplicate
I' --~r:::,-,-_-..:-~-:-::-:-_r;;-.. ~. ---. .:-::-· --------,r · r;""..,r l I _ _:_ ',.'-1_.,.J~1J: .. :.~~-l ~ •".J. _l • )_'..._ -__ ,,JI _U1_~ I
j :'l • ~ ' r ,-• j 7-,..,:, ' • ,·•-. • • I'•-•, i --, ,~--....-. • ! I !;. • • J. I./::Y ::,:,:_: ~'.-,t~J :1 J 1 :·"~L'.-l.;~'____.-_L!:,t.l!!J~·_JL1:\_Ll.1J_(_~'__
D D D
D D D
D D D
D D D
D D D
D D D
D D D
Duplicate Sample Name: ___________ _
Notes: _______________________________ _
ENERGY FUELS
Energy Fuels Resources (USA) inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DRC -2020 -0t198 1
www.energyfuels.com
Div of Waste !V,itagerr'nt
June 25, 2020
SENT VIA E-MAIL AND EXPEDITED DELIVERY
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 84116
and Radiation Controi
JUN 2 9 2020
COPY
Re: Receipt and Processing of Ores from Chemours at the Energy Fuels Resources (USA) Inc. ("EFRI")
White Mesa Mill
Dear Mr. Howard:
This letter is to advise the Utah Division of Waste Management and Radiation Control ("DWMRC") of EFRI's
plan to receive and process at the White Mesa Mill (the "Mill") natural uranium ores in the form of monazite
sands (the "Ore") from The Chemours Company's ("Chemours') Mineral Sand Separation Plant in Offerman,
Georgia, for the recovery of uranium, as well as the production of a commercial rare earth element ("REE")
concentrate. Because the Ore is natural ore, EFRI intends to receive and process the Ore under the Mill's
current Radioactive Materials License No. 1900479 (the "License"), subject to finalization of commercial
arrangements with Chemours.
Chemours operates the Mission Mine in Charlton County Georgia and the Amelia Mine in Wayne County,
Georgia and has mining operations in Clay, Bradford, Baker and Duval counties in Florida (collectively, the
"Mines"). Currently, EFRI intends to receive and process Ore from Chemours' Mission Mine, which is
separated from other mined sands at Chemours' Offerman mineral separation plant ("MSP") in Pierce County,
Georgia. The Mill may also take similar Ore from Chemours' other Mines in the future.
Chemours anticipates shipping approximately 3,000 to 5,000 tons of Ore per year to the Mill from the Mines,
for an indefinite period of time.
We are providing this letter to you because the source of the Ore is somewhat different from other mined ores
typically received and processed at the Mill, and we want to make sure you are kept advised of all Mill
activities.
I. Background
The Ore is from natural sands mined by Chemours at the Mines which are separated into mineral sand fractions
at Chemours' Offerman MSP in Pierce County, GA. The Ore is high in rare earth elements as well as uranium.
Chemours refers to the Ore, from which other mineral fractions have been removed, as rare earth mineral sands
product ("REMS product") because it is currently being sold by Chemours to third parties for processing, but
it is also a natural uranium ore with a uranium content higher than most Colorado Plateau uranium ores.
Letter to Ty L. Howard
June 25, 2020
Page 2 of 10
Although the Ore is separated from other mined sands, through a number of mechanical, magnetic and
electrostatic steps, it is not changed or altered in any way from its natural or native state. It is in the same
natural or native state it was in prior to separation from the other sands and prior to mining. Photographs of
the Ore as it will be received at the Mill are included as Attachment A to this letter.
Chemours currently sells the Ore to facilities in China for the recovery of uranium and production of REEs in
China.
A description of the Ore, mode of transportation, storage at the Mill after receipt, processing at the Mill, and
disposal of the byproduct residuals are discussed below.
2. Mining
The following description is from the Mission Mine. Mining at the other Mines is performed in substantially
the same manner.
At the Mission Mine, excavation proceeds as follows.
(a) An excavator digs from the surface down to approximately 20', dumping each bucket of sand into
an off-road haul truck;
(b) Pumps are installed to remove groundwater from the open excavation;
(c) Haul trucks carry the sand to a screener, which rejects roots, stumps and boulders of cemented sand;
(d) Loose sand that passes through the screen is mixed with water and pumped to the Wet Concentrator
Plant;
(e) After the water is exposed to the sand, the dirty water is flocculated with a polymer to separate the
organics (humate) from the water, and the organics are then pumped to previously excavated mine
pits. The organics and flocculant are associated solely with mine water treatment and are not part of
the sand product and eventual Ore;
(f) Sand is distributed among hundreds of separatory spirals to reject a portion of the quartz sand from
the mineral sand;
(g) The separated quartz sand is returned to previously excavated mine pits;
(h) The remaining sands are pumped to an attrition cell where weak sodium hydroxide (weak caustic) is
added to the water carrying the sands, and the mixture is agitated to wear away organic coatings on
the surface of the sands. The organic coating consists of naturally occurring film of biological
residual, which is washed away to leave a clean mineral sand. The use of a weak caustic or similar
agent to remove the organic and leave clean mineral sand is typical at mineral sand mining
operations. The organic material and caustic solution remain at the mine site and are not part of the
sand product and eventual Ore. Chemours also refers to the clean mineral sand as clean mineral
concentrate ("CMC"), because the sands have been washed and the tree stumps, rock lumps, weeds
and debris have been removed, resulting in a clean sand mass;
(i) The CMC is rinsed, then piled up and allowed to air dry for at least three days; and
(j) Heavy equipment then loads over-the-road haul trucks with the CMC, which is hauled to the MSP.
A schematic drawing of mining steps is provided in Attachment B. The schematic is typical of any of
Chemours' Mines.
3. Separation
The CMC from the Mine is trucked to the Offerman MSP to be sorted into sand fractions by mechanical
separation. All separation or sorting steps used at the Offerman MSP are physical separations, including wet
Letter to Ty L. Howard
June 25, 2020
Page 3 of 10
or dry size screening, electrostatic and magnetic separations, spiral separators, and shaker tables. No
flocculants, precipitants, surfactants, flotation agents, or chemical additives of any kind are used in the MSP.
No reactions or chemical changes occur in the separation steps, and each sorted fraction remains in its natural
sand form. While it is not untypical for wet separations at other sands sorting sites to use additives to enhance
separation of certain fractions, none of which alter the natural form of the sands, no such additives are used at
the Offerman facility.
The CMC arrives at the MSP from the Mine in the form of natural sands as described above. The CMC is a
natural combination of quartz sand, kyanite sand, staurolite sand, ilmenite sand, leucoxene sand, rutile sand,
zircon sand, and rare earth mineral sand which are sorted in the MSP. Each of these sorted fractions remains
in the form of natural sand. The sorting sequence is described below:
(a) Quartz sand is separated and rejected from the sands using an upward current classifier;
(b) The remaining sands are then dried and heated;
(c) The sands pass through an electrostatic field, and conductive minerals are separated into ilmenite and
rutile titanium sand products;
(d) The remaining sands are separated by density (spiral separators, wet shaking tables, upward current
classifiers), dried, then magnetic and electrostatic separators are used to produce a staurolite sand
product;
(e) The remaining low density mineral-bearing sands are removed using spiral separators, wet shaking
tables, and upward current classifiers;
(f) The remaining high density sands are dried, and a non-magnetic zircon sand product is produced
using electrostatic and magnet separators; and
(g) The remaining high density, magnetic sands are separated with density, electrostatic, and magnetic
separators resulting in the rare earth mineral sand ("REMS"), also called monazite sand, which
comprises the Ore to be shipped to the Mill.
The MSP was designed as a zero-discharge facility. Wash water from wet steps are recycled to the maximum
extent possible. Quartz sand and sands of non-marketable minerals are returned to the previously excavated
pits at the mine site.
Offerman currently receives CMC from the Mission Mine and separates it into Ore. Offerman plans to receive
(monazite-containing) washed natural CMC sands from the Amelia Mine in Wayne County, GA beginning in
August 2020, for the separation of Ore. The Amelia Mine uses the same mining and washing steps as the
Mission Mine, and at the Offerman MSP the sands will undergo the same physical separations as CMC sands
from the Mission Mine.
Offerman also plans to receive sand hauled from Chemours' Starke MSP in Clay County, FL. Those sands
were accumulated over the past decades from mining in Clay, Bradford, Baker and Duval counties in Florida,
which had previously undergone steps 3(a) through (f) above at the Starke MSP, but not step 3(g), which is
not available at that facility. Those stockpiles will be moved to Offerman and undergo the same density,
electrostatic, and magnetic physical separations under step 3(g) above as other CMC sand at Offerman to yield
Ore.
A schematic drawing of the sorting sequence at the Offerman MSP is provided in Attachment C.
4. Composition and Grade of the Ore
The Ores to be shipped to the Mill:
• are in their natural unconsolidated sand form;
Letter to Ty L. Howard
June 25, 2020
Page 4 of 10
• contain no additives or chemicals; and
• are unchanged chemically or structurally from their natural or native state.
A summary of the mineral composition of a typical Ore produced in 2019 is provided in Attachment D.
The Ore has a uranium grade consistent with natural uranium ores routinely received and processed at the Mill,
with a content of approximately 0.26% U308 This is comparable to a high-grade Colorado Plateau uranium
ore. By comparison, the average grade of ore at the Company's La Sal mine in Utah, is 0.169% U308, so the
Ore grade is over 50% greater than the averages at La Sal.
The Mill is designed to process approximately 2,000 tons of ore per day, so 3,000 to 5,000 tons of Ore per year
will represent a very small percentage of the Mill's operational capacity (less than three days out of 365 days
per year of capacity utilization). Based on the approximate quantity of 5,000 tons of Ore per year, processing
of the Ore is expected to result in the production of approximately 12.5 tons of yellowcake per year. The
recovery of this amount of yellowcake will not cause the Mill to exceed its License production limit of 4,380
tons of yellowcake per year. If the quantity of Ore increases by even four or five times that quantity, it will
still be insignificant compared to the Mill's operational and licensed capacity.
5 Transportation to the Mill
The Ore will be transported to the Mill in 4400-pound Supersacks. The Supersacks will be loaded into
covered intermodal containers ("IMCs). The IMCs will be either:
• transported by rail to one of the existing rail transfer yards in Utah (e.g., Green River), followed by
transfer to intermodal truck tractors from the railhead to the Mill, or
• transported by multi-unit truck tractors over public highways to the Mill.
The number of trucks associated with transporting the Ore from the MSP or the railhead to the Mill will be
approximately the same as the number of trucks required to transport the quantity of a Colorado Plateau
ore needed to produce the same mass of yellowcake. Based on the estimated quantity of 5,000 tons of
Ore, transport may require up to 10 trucks per day over a period of 25 days.
The number of trucks required to transport the resulting separated, precipitated, dried and packaged
yellowcake from the Mill would be the same as required to transport yellowcake produced from processing
any other conventional ore at the Mill.
6. Processing at the Mill
6.1. Storage at the Mill, Pending Processing
The Ore will be transported to the Mill in Supersacks as described above in covered transport containers.
Upon arrival at the Mill, the Supersacks will be unloaded from the transport containers, and the transport
containers will be decontaminated, scanned and released from the site.
Because the Ore is a fine-grained sand, it will be stored in the Supersacks on the Mill's ore storage pad
pending processing in order to avoid any potential windblown dust issues. In order to ensure no potential
UV degradation of the Supersacks while stored, the Mill will regularly inspect the Supersacks and will ensure
that no Ore is stored on the ore pad for longer than 365 days before it is processed unless other appropriate
precautions are taken. If any of the Supersacks are breached as a result of unloading or otherwise, an
appropriate cover will be placed over the breached Supersacks to prevent any windblown dust from the Ore.
Letter to Ty L. Howard
June 25, 2020
Page 5 of 1 0
6.2. Mill Process
Using primarily existing Mill facilities and equipment, with no significant changes at this time, the Mill will
recover the uranium from the Ore and will attempt to produce a commercial REE concentrate that can be sold
to an REE separation facility for the production of REE oxides. If the Mill is not able to produce a commercial
REE concentrate, then the Ore will either be processed solely for its uranium content, or will be sold to another
licensed facility, likely outside of the United States, for processing.
The Mill has used both sulfuric acid leach and alkaline leach in the past for the recovery of uranium, depending
on the ore source. The Mill is currently evaluating which of those two methods will allow for the best recovery
of uranium as well as the REE concentrate.
How the Ore will be fed to the process will depend on the leaching method used. If sulfuric acid leaching is
used, the Ore will likely be fed directly into a leach tank and slurried with concentrated sulfuric acid. The
slurry will likely be heated to 1 00-1 50°C during the leaching process. After the leach is complete, water will
be added to the slurry and the solids will be washed.
If alkaline leaching is used, the Ore will likely be fed to the SAG mill and ground, and then dry caustic will be
added to the ground Ore sluny in a leach tank. The slurry will likely be heated to 1 00- 1 50°C while leaching.
The leached solids will be washed with water and then re-leached with sulfuric acid.
Regardless of which leaching method is used, the subsequent process steps will be nearly identical. The solids
will be washed (CCD) and the pregnant solution will be fed to solvent extraction for uranium and thorium
removal, with the uranium going to the existing precipitation, drying and packaging circuits for the production
of a commercial yellowcake product and the thorium going directly to the Mill's tailings management system
for disposal. The natural thorium concentration in the Ore is somewhat higher than other mined ores typically
processed at the Mill, but well within the range of concentrations contemplated by existing Mill radiation
protection and other procedures, and well within the concentrations of other materials approved for processing
at the Mill. The remaining solution will then be precipitated with a base, probably sodium carbonate, to
produce a rare earth carbonate precipitate that will be washed with water and then dried (not calcined) to
remove water content. The rare earth carbonate will be packaged and sold as an intermediate product to one
or more REE separation facilities for the production of REE oxides.
The Mill currently expects to be able to process the Ore for the recovery of uranium and produce a
commercially salable REE concentrate product with minimal changes to Mill processes and without the need
for any significant capital modifications, other than potentially the addition of some smaller tanks and a small
vacuum dryer that will not have any air emissions. Those types of process adjustments are routine at the Mill
and not of the nature that would require any permit amendments. Once the Mill has demonstrated that it can
produce a commercial REE concentrate along with the uranium, it will evaluate possible equipment and
process adjustments to optimize the process. Although we do not believe any such adjustments would require
any permit modifications, we will evaluate whether any such permit modifications may be required at that
time, depending on the nature of the adjustments.
6.3. Disposal
Once the Mill has recovered the uranium content, and potentially the REE concentrate, from the Ores as
described above, the remaining tailings will be disposed of in the Mill's tailings management system, in the
same way as tailings from other ores.
fetter to Ty L. Howard
June 25, 2020
Page 6 of 10
7. Other Considerations
As the Ore is a natural ore (i.e., native rock) it can be received and processed at the Mill under its existing
License. It is not an alternate feed material that would require a License amendment under License condition
10.1C.
The Ore is not an "Alternate Feed Material" as defined in UC 59-24-102, and in NRC's "Interim Position and
Guidance on the Use of Uranium Mill Feed Material Other than Natural Ores", RIS 00-023: Recent Changes
to Uranium Recovery Policy, November 30, 2000 (the "Mternate Feed Guidance"), because the Ore is a
natural ore. The Alternate Feed Guidance, states that "[i]n reviewing licensee requests to process alternate
feed material (material other than natural ore) in uranium mills, the Nuclear Regulatory Commission staff
will follow the guidance presented below." (emphasis added).
Further, in its May 13, 1992 Federal Register Notice accompanying the original Alternate Feed Guidance,
NRC refers to an alternate feed material as "feed material that was not natural (native, raw uranium ore)" Fed.
Reg. Vol 57, No. 93, May 13, 1992, Page 20531, and other ores as "natural uranium-bearing rock (i.e., ore)"
and as "native rock." Fed. Reg. Vol 57, No. 93, May 13, 1992 Page 20532.
Since the Ore is natural, native sand (i.e. rock) it is not an alternate feed material, and an amendment to the
Mill's License is not required or appropriate.
If successful in recovering an REE concentrate along with the uranium from the Ore, the Mill intends to pursue
other natural monazite sand ores having similar characteristics as the Ore, from other mines in the U.S. and
elsewhere, for the recovery of uranium and REE concentrates under the current License.
If you should have any questions regarding this letter, or you disagree with any of our conclusions, please
contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
David C. Frydenlund
Chief Financial Officer, General Counsel and Corporate Secretary
cc: Scott Bakken
Mark Chalmers
Paul Goranson
Logan Shumway
Terry Slade
Kathy Weinel
Jo Ann Tischler
ATTACHMENT A
Photographs of the Ore as it will be Received at the Mill
(the metal object is one leg of a standard one-inch paper clip, for size comparison)
Sand
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with A:70W tt
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rr bled wrt h wa ter sP par a tors &
piirnpPri way rf
dralConcentrave
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organrc surface
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(loan
Mineral
cencentratE
ATTACHMENT B
Mining Schematic
Figure 1: Mineral Sand Mining Schematic
C Chemours-
( lean
Mineral
Concentrate
Qdartr Rejecters use,/
uCCOIMMTV
Sesaratiorl
Eiectrostatir R.
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Electrostatic, and
[-1 Magna, tic Physical
Separations
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Minerals
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ATTACHMENT C
Separation Schematic
Figure 2: Offerman Mineral Sand Separation Schematic
Chemours-
ATTACHMENT D
Typical Ore Composition Data
Mineral Concentration (%)
SiO2 5.22
ZrO2 9.19
P205 18.33
U3O8 0.26
ThO2 2.59
HfO2 0.34
Other oxides 2.11
Other minerals 8.18
CeO2 25.10
Dy2O3 0.56
Er2O3 0.13
Eu2O3 0.14
Gd203 1.19
Ho2O3 0.07
La2O3 10.58
Lu2O3 0.00
Nd2O3 9.24
Pr6011 2.69
Sc2O3 0.01
Sm2O3 1.69
Th4o, 0.17
Y203 2.12
Yb2O3 0.10
SUM 100%
I
Department of
Environmental Quality
L. Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
FILE COPY
GARY R. HERBERT
Governor
SPENCER J COX
Lieutenant Governor
July 28, 2020
David Frydenlund
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
RE: Accepting and Processing Uranium Ore and Equivalent Feed from the Japan Atomic Energy
Agency (JAEA) at the White Mesa Mill, Radioactive Material License Number UT 1900479.
Dear Mr. Frydenlund:
In a letter dated May 19, 2020, Energy Fuels Resources (USA) Inc. (EFRI) sent a letter to the Division
of Waste Management and Radiation Control (DWMRC), informing the DWMRC of their intent to
accept and process uranium ore samples and equivalent feed from two facilities run by the Japan Atomic
Energy Agency. According to the letter approximately 136 tons of naturally occurring ore and
equivalent feed would be sent to the Mill for processing. Based on the information provided, the
DWMRC concurs that this material is naturally occurring ore and equivalent feed and no additional
licensing would be required for the Mill to accept and process this material.
The DWMRC will inspect compliance aspects of this project during future inspections at the White
Mesa Mill. If you have any questions please contact Ryan Johnson, at 801-536-4255.
Sincerely,
Ty L Howard, Director
Division of Waste Management and Radiation Control
TLH/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Plant Manager, White Mesa Uranium Mill
DRC-2020-011442 195 North 1950 West • Salt Lake City, UT
Mailing Address P 0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Div of Waste Management and Radiation Control
MAY 2 7 2020
..............-0 - COPY
.1

D R C - ZOZ 0 - O I 0 s 70
Energy Fuels Resources (USA) inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
May 19, 2020
SENT VIA E-MAIL AND EXPEDITED DELIVERY
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 84116
Re: Receipt and Processing of Ores and Equivalent Feed Materials from Japan Atomic Energy Agency
("JAEA") at the Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Mill
Dear Mr. Howard:
This letter is to advise the Utah Division of Waste Management and Radiation Control ("DWMRC") of EFRI' s plan
to receive and process at the White Mesa Mill (the "Mill") a small quantity (approximately 136 tons) of natural
uranium ores and equivalent feed materials (collectively, the "Materials") from two JAEA uranium test centers,
for the recovery of uranium. Because these materials are natural ores and equivalent feed materials, EFRI plans to
receive and process these materials under the Mill's current Radioactive Materials License ("RML") No. 1900479.
Under the proposed transaction, EFRI would receive the Materials from the following two JAEA uranium recovery
and fuel cycle test facilities in Honshu, Japan:
• JAEA Ningyo-toge Environmental Engineering Center (the "Ningyo Center" or "Ningyo"), and
• JAEA Tono Geoscience Center (the "Tono Center" or "Tono").
1. Background
The Ningyo Center, located in central Honshu island, researched uranium mining and recovery technologies,
including recovery and conversion of off-spec yellowcake ("scrapped uranium"), recovery of UF6 trapped in gas
containers prior to enrichment ("hold-up uranium"), and technologies to improve reclamation of uranium mines and
former uranium fuel cycle facilities. The Tono Center, located in southwestern Honshu island, conducted research
to establish techniques for investigation, analysis and assessment of the deep geological environment related to
radioactive material disposal, and develop uranium mining technologies. JAEA plans to ship only:
• unprocessed natural ores and ore-bearing natural media from storage and testing of natural uranium ores,
• equivalent feed materials in the form of uranium-loaded resin ("ULR") and associated uranium-loaded filter
bed sands, from uranium recovery testing of natural uranium ores, and
• equivalent feed materials in the form of uranium-loaded carbon from natural uranium ore dewatering
treatment testing.
The Materials do not include material from testing of any other downstream step of the uranium fuel cycle; that is,
Letter to Ty L. Howard
May 19, 2020
Page 2 of 10
JAEA will not ship any chemically converted, enriched, or depleted forms of uranium.
The quantities of Materials from the two JAEA test centers are listed in Tables A-1 and A-2 in Attachment A. The
values in Tables A-1 and A-2 are approximate. Changes in moisture content and inconsistencies in measurement
accuracy may cause the measured weights of loaded containers to vary appreciably.
A description of each of the types of Materials, modes of transportation, storage at the Mill after receipt, and disposal
of the byproduct residuals are discussed below.
2. Natural Ores
JAEA tested uranium ores from 33 countries, primarily Canada, Niger and Japan, including natural ores from Japan's
Ningyo-toge and Togo uranium mines, which are currently undergoing reclamation. The other source locations of
the ores may have included U.S. and non-U.S. locations from which the Mill has previously received and processed
ores.
The natural ores to be shipped from JAEA include raw uranium ores in bulk, containerized uranium ore samples,
cores, test hole samples, and spilled ore material/soil scrapings of natural uranium ore mixed with native rock and/or
soil, totaling approximately 85.4 tons (or approximately three typical ore trucks). The Mill has historically received
natural uranium ore and ore-containing natural materials including rock, drill core, ore samples, soil cuttings, and
spilled ore material/soil scrapings, from EFRI' s own as well as other conventional mines under its existing RML.
All the natural ores have uranium grades consistent with natural uranium ores routinely received and processed at
the Mill, ranging from less than 0.05% to 3.0% natural uranium (3.53% U308), with an average of approximately
0.29% U308, which is comparable to Colorado Plateau uranium ores. Based on the approximate quantities of natural
ores in Table A-1, processing of the ore is expected to result in the production of approximately 0.24 tons of
yellowcake. The recovery of this amount of yellowcake will not cause the Mill to exceed its RML production limit
of 4380 tons of yellowcake per year.
3. Equivalent Feed Materials
3.1. Uranium Loaded Resins and associated Filter Bed Sands
EFRI is proposing to accept the ULR and associated filter bed sands as equivalent feed material, totaling
approximately 40.5 tons, in accordance with the Nuclear Regulatory Commission ("NRC") Regulatory Issue
Summary ("RIS") 2012-06. The NRC RIS 2012-06, dated April 16, 2013, entitled NRC Policy Regarding
Submittal of Amendments for Processing of Equivalent Feed at Licensed Uranium Recovery Facilities, describes
the NRC's position and licensee requirements for acceptance of ULR as eqUivalent feed materials. For ease
of review the NRC RIS 2012-06 is included as Attachment B to this letter.
The RIS states:
"In situ recovery (ISR), conventional mills, or heap leach facilities with NRC or Agreement
State licensed resin processing plants, may accept equivalent feed, as defined in the regulatory
issue summary, without a license amendment."
Enclosure 2 of the RIS specifies that the licensee should document that the ULRs meet the equivalent feed
criteria by meeting the three criteria below. A summary of how the JAEA ULR meets the criteria is presented
below each of the following NRC- specified criteria (which are shown in italics):
Letter to Ty L. Howard
May 19, 2020
Page 3 of 10
(a) Chemically and physically essentially the same as the resins processed at thefacility;
The Mill has previously used ion exchange resins and technology to recover uranium from low-grade uranium
bearing acidic solutions. The Mill utilized DOWEX 21K XLT anion exchange resin.
Both the Tono and Ningyo Centers experimented on the effectiveness of multiple uranium recovery
IX resins, and uranium water treatment resins. The resins included in the material to be shipped to the Mill
are as follows:
• Dowex XSF-43116-2
• Diaion PA-316, PA-318, and CR-50
• SA-11A
A comparison of the JAEA resins to the Mill resin follows:
• All are strong base, type 1, anion exchange resins;
• The composition of each is a trimethyl or tetramethyl amine functionalized chloromethylated copolymer of
styrene and vinylic monomer backbone;
• Both the JAEA and Mill resins are in the form of resin beads with essentially the same weight;
• The bead sizes range from 0.3 to 1.3 mm. This range includes the size of the DOWEX 21K XLT; and
• Each product is selective for uranium.
The Mill could use any of the JAEA resins for future recovery of uranium from low-grade uranium bearing acidic
solutions in the future, in the same manner as it has used the DOWEX 21K SLT anion exchange resin in the past.
Also included with the ULR is a small quantity (approximately 4.73 tons, or less than the amount of ore shipped in
one quarter of a typical ore truck) of filter bed sands placed just upstream of the IX columns. These filter bed sands
are natural particulate sand loaded with the same solutions as the ULR.1 These sands are sometimes referred to as
"process materials" or "process solids" in some translations of the documents supplied by JAEA. The sand matrix
of these filter bed sands is as benign as the natural rock, soil or sand matrix from the natural uranium ores routinely
processed at the Mill.
(b) Using existing equipment, will be processed in the same way as the resins processed at the facility; and
The Mill has previously processed ULR through the main circuit by contacting loaded resins with a separate
solution to remove the uranium; a process referred to as stripping. The stripped solution, which contains the
uranium is pumped to the solvent extraction ("SX") feed tank. The solutions are then handled in the same
manner as solutions from all other feeds processed at the Mill. The equivalent feed ULR would be handled in
the same manner utilizing the same stripping followed by delivery to the SX feed tank and the rest of the existing
Mill facilities and processes.
Although we are considering the filter bed sands to be part of the ULR equivalent feed stream because they are merely
natural sands contaminated with the same solutions as found in the ULR equivalent feed and are an associated component of
that equivalent feed, the filter bed sands could also be considered equivalent feed in and of themselves, for the same reasons
the activated carbon below should be considered equivalent feed materials. This is because the filter bed sands can also be considered a media that is used for natural uranium recovery processing or water treatment, and which consequently become
loaded with uranium, as contemplated by the RIS, as discussed in more detail in Section 3.2 below.
Letter to Ty L. Howard
May 19, 2020
Page 4 of 10
The filter bed sands will be processed in the same way as natural ores, by acid or alkaline leaching of the uranium
minerals alone or in combination with other ores. The sands will travel through the Mill process in the same way,
and be disposed of in the tailings management system in the same way, as rock or sand components of natural ores.
The filter bed sands could alternatively simply be washed, as they are merely naturally sands coated with the same
solutions as the ULR, with the wash solutions processed along with the ULR. However, given the small quantity of
filter bed sands, it would be easier to merely include them in the next conventional ore run at the Mill.
(c) Processing the equivalent feed material does not exceed the uranium production limits in the license and
stays within the existing safety and environmental review envelopefor the facility.
The processing of the ULR and associated filter bed sands, which will result in approximately 0.24 tons of
yellowcake, will not cause the Mill to exceed the RML production limit of 4380 tons of yellowcake per year.
Processing the ULR and associated filter bed sands does not:
• require any additional chemicals beyond those already in use at the Mill
• produce any process conditions (pH, temperature) outside the range of those managed elsewhere in the
Mill or previously at the Mill,
• generate increased levels of radionuclides in any part of the process beyond those produced in the previous
process configurations, or
• generate any additional or increased quantities of air emissions.
3.2. Uranium-Loaded Carbon from Mine Water Treatment
In addition to the ULR and associated filter bed sands, the Company intends to receive and process a small quantity,
(approximately 10.3 tons or less than the amount of ore shipped in one half of a typical ore truck), of activated
carbon from testing of uranium mine water treatment at Ningyo. Activated carbon is another type of water treatment
media, which we believe meets the criteria in the RIS and should be considered an equivalent feed material.
The RIS states:
"Consequently, in this guidance, the staff is defining the term "Equivalent feed" to apply to those
circumstances where the feed material is essentially the same chemically and physically as the
source material that is primarily processed at a uranium recovery facility. Such material should not
be considered as alternative feed requiring license amendments as described in RIS-00-23 if it
meets the equivalent feed criteria articulated in this RIS. Equivalent feed can originate at a CWS
or mine dewatering operation. In addition, equivalent feed can also include ULR originating from
another licensed uranium recovery facility."
In the three types of operations identified by NRC in the foregoing excerpt, although not stated explicitly, IX resins
are not the only media that are used for natural uranium recovery processing or water treatment, and which
consequently become loaded with uranium. For example, depending on the water quality and discharge
requirements, uranium mine water treatment media may include granular or powdered activated carbon in adsorption
columns or beds.
EFRI believes that the application of the RIS to the activated carbon Material is appropriate. Even though these
Materials are not IX resins, they are a material used for binding or holdup of uranium. The activated carbon was in
contact with the same types of uranium solutions (uranium process solutions in contact with filter sands or mine
water in contact with carbon) that would be in contact with IX as anticipated in the RIS.
Letter to Ty L. Howard
May 1 9, 2020
Page 5 of 1 0
Enclosure 2 of the RIS specifies that the licensee should document that the materials meet the equivalent feed
criteria by meeting the three criteria below. A summary of how the activated carbon Material meets the criteria is
presented below each of the following NRC- specified criteria (which are shown in italics):
(a) Chemically and physically essentially the same as the materials processed at thefacility;
Activated carbon, used in water treatment, is prepared by reducing natural carbon-containing organic materials such
as walnut shell fiber or coconut shell fiber to elemental carbon, or by purifying naturally occurring sources (coal) to
elemental carbon. Regardless of source, treatment-grade activated carbon is elemental carbon varying only in
particle size and geometry and/or pore size and geometry.
Carbon is a natural element that is more inert than IX resin, more chemically stable, binds a wider range of particle
sizes regardless of ionic charge, binds constituents more strongly than ion exchange resins, and in fact is selected
for some applications for these reasons. As a treatment medium, carbon differs from sand, from which uranium and
other constituents may sometimes be mechanically "knocked" loose from the media pores by back-washing in place,
or ion exchange resin, from which constituents can be removed by replacement with other ions from sources such
as salts. Carbon cannot be freed of bound constituents, that is, it cannot be recovered, by processes or conditions
available at a mine water treatment location. Constituents can only be removed from carbon by thermal regeneration
in a low oxygen furnace, or by digestion of the constituents and/or carbon in strong acids such as in the Mill process.
The carbon itself is as environmentally benign as the rock or sand matrices of natural ores, and more inert and more
benign than IX resins.
(b) Using existing equipment, will be processed in the same way as other uranium-bearing solids processed at
the facility; and
The activated carbon will be processed in the same way as natural ores, by acid or alkaline leaching of the uranium
minerals alone or in combination with other ores. The carbon will travel through the Mill circuits in the same way,
and be disposed of in the tailings management system in the same way, as rock or sand or other non-uranium
components of natural ores.
(c) Processing the equivalent feed material does not exceed the uranium production limits in the license and
stays within the existing safety and environmental review envelope for the facility.
The processing of the uranium-loaded carbon, which will result in approximately O. 1 tons of yellowcake, will not
cause the Mill to exceed the RIVIL production limit of 4380 tons of yellowcake per year.
Processing the uranium-loaded carbon does not:
• require any additional chemicals beyond those already in use at the Mill,
• produce any process conditions (pH, temperature) outside the range of those managed elsewhere in the
Mill or previously at the Mill,
• generate increased levels of radionuclides in any part of the process beyond those produced in the previous
process configurations, or
• generate any additional or increased quantities of air emissions.
(d) Is the material from a water treatment facility?
The activated carbon resulted from the mine water treatment testing facility at Ningyo, which evaluated
Letter to Ty L. Howard
May 19, 2020
Page 6 of 10
technologies for treating mine water to meet discharge standards. The carbon was only in contact with raw mine
water or pre-treated mine water as component technology of a test scale water treatment unit.
4. Other Considerations
4.1. Transport
The bulk ores will be transported to the Mill in 100, 200 or 300 liter (30, 55, or 80 gallon) sealed metal drums.
Smaller ore, soil and core samples will be sealed in 15 kg (approximately 5 gallon) metal containers. The resins
will be transported to the Mill in 200 or 300 liter (55 or 80 gallon) sealed metal drums. The filter bed sands will
be transported to the Mill in 300 liter (80 gallon) sealed metal drums. The activated carbon will be transported to
the Mill in 200 liter (55 gallon) sealed metal drums. The resins, filter bed sands and activated carbon will be
transported by the same route and equipment, and potentially in the same shipment, as the ores.
The Materials, in their various drums and metal containers, will be loaded into closed cargo containers, such as
Container Express ("Conex"), Sea Boxes, Intermodal Containers ("IMCs") or the equivalent and transported by
truck to a port of departure in Japan. The containers will be transferred to a container ship and will be transported
by sea from Japan to a port of arrival, potentially in one seaborne shipment. The closed cargo containers will be
transferred either to:
• intermodal rail cars at the port of entry and transported by rail to one of the existing rail transfer yards in
Utah (e.g., Green River), followed by transfer to intermodal truck tractors from the railhead to the Mill, or
• multi-unit truck tractors at the port of entry and transported by truck over public highways from the port of
entry to the Mill.
The number of trucks associated with transporting the Material from the port of entry or the railhead to the Mill
will be approximately the same as the number of trucks required to transport the quantity of ore needed to
produce the same mass of yellowcake. The number of trucks required to transport the resulting separated,
precipitated, dried and packaged yellowcake to and from the Mill would be the same as required to transport
yellowcake produced from processing natural ores or any other feed at the Mill.
4.2. Storage at the Mill, Pending Processing
The Materials will be transported to the Mill in sealed drums of various sizes as described above in closed transport
containers. Upon arrival at the Mill, the drums will be unloaded from the transport containers, and the transport
containers will be decontaminated, scanned and released from the site, or retained on site for use in Mill operations.
To the extent any of the Materials are not fed directly into the Mill process upon receipt, they will be stored in their
sealed drums on the Mill's ore storage pad, pending processing.
4.3. Disposal
The RIS states
"Following elution of the ULR equivalent feed (i.e., removal of the uranium from the treatment
resin), the resulting stripped resin can take two paths. Since the NRC is allowing equivalent feed
to be processed at uranium recovery facilities, the wastes associated with processing equivalent
feed (i.e. stripped resin) can be considered byproduct material, as defined in Title 10 of the Code
of Federal Regulations Part 40. Therefore, these wastes could be disposed of at an NRC-licensed
facility without further documentation."
Letter to Ty L. Howard
May 19, 2020
Page 7 of 10
In addition to disposing of the ore tailings in the Mill's tailings management system, in accordance with the RIS,
EFRI plans to dispose of the resin from processing of the equivalent feed ULR, residuals from processing of the
loaded sands and residuals from processing of loaded activated carbon in the Mill's tailings management system.
Once EFRI has recovered uranium from the URL, EFRI plans to return the eluted resins to their shipping containers,
or other closed drums, for disposal in the beach area of the selected tailings cell. Tailings generated from the other
Materials will be in the form of wet tailings sands, and will comprise a part of the normal tailings slurries piped to
the tailings management system.
4.4. Import License not Required
The Material may be imported into the United States as "source material" under 10 CFR 110.20(a), because it is
covered by the NRC general license described in 10 CFR 110.27(a), and because the Uranium Material:
• is not in the form of irradiated fuel, as contemplated by 10 CFR 110.27(b); and
• is not a radioactive waste, as contemplated by 10 CFR 110.27(c). As an ore or equivalent feed material, the
Material will not be a radioactive waste as defined in 10 CFR 110.2 because (A) the Material will be
processed for its source material content, and will therefore be imported solely for the purposes of
yellowcake production and not for waste management or disposal, and (B) there is a market for the produced
yellowcake.
In its November 1998 approval of Amendment 9 to the Mill's Source Material License SUA-1358, White Mesa
Uranium Mill — Approval to Process Materials from Cameco Corporation's Facilities in Ontario, Canada," which
are alternate feed materials from Canada, the NRC came to the same conclusion with respect to an alternate feed
material ore that was being processed for its source material content at the Mill:
"Finally, import of radioactive materials from Canada required a license from NRC. As discussed
above, the staff has determined that these uranium-bearing materials from Cameco's Blind River
and Port Hope facilities will be processed for their source-material content. Therefore, with the
staff s approval of IUC' s request to process these materials, IUC also is authorized to import them
under the general license at 10 CFR 110.27."
Because the import of the Material into the United States is covered by the general license in 10 CFR Part 110.27(a),
a specific import license is not required.
If you should have any questions regarding this submittal, please contact me.
Yours very truly,
ifii-L-----
ENERGY FUELS RESOURCES (USA) INC.
David C. Frydenlund
Chief Financial Officer, General Counsel and Corporate Secretary
cc: Scott Bakken
Letter to Ty L. Howard
May 19, 2020
Page 8 of 10
Mark Chalmers
Paul Goranson
Logan Shumway
Terry Slade
Kathy Weinel
Harold R. Roberts
Jo Ann Tischler
ATTACHMENT A
JAEA FEED QUANTITY DATA
Table A-1
Natural Ores
Ores
(metric
tons)
Ores
(tons)
Total
(tons)
Ores Total
(tons)
Ningyo Canada 10.6 11.7
Niger 0.7 0.8
Central Africa 0.2 0.22
Brazil 0.3 0.33
Gabon 0.1 0.11
Various 8.3 9.1 22.2 Total Ningyo
Tono Various 0.5 0.55
Canada 0.4 0.44
Niger 1.3 1.43
Japan 6.3 6.9
Various 0.5 0.55
Calibration Ores 41.9 46.1
Ore Cores 4.4 4.84
Ore soils 2.1 2.31 63.1 Total Tono
77.6 85.4 85.4 Total Ores
Table A-2
Equivalent Feed Materials
Equivalent
Feed
(metric
tons)
Equivalent
Feed
(tons)
Total
(tons)
Equivalent Feed
Total (tons)
Ningyo Loaded Resin 30.6 33.7
Loaded Carbon 9.4 10.3 44.0 Total Ningyo
Tono Loaded Sands 4.3 4.73
Loaded Resin 1.9 2.09 6.8 Total Tono
46.2 50.82 50.8 Total Equivalent
Feeds
ATTACHMENT B
NRC RIS 2012-06
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF FEDERAL AND STATE MATERIALS
AND ENVIRONMENTAL MANAGEMENT PROGRAMS
WASHINGTON, D.C. 20555
April 16, 2012
NRC REGULATORY ISSUE SUMMARY 2012-06
NRC POLICY REGARDING SUBMITTAL OF AMENDMENTS FOR
PROCESSING OF EQUIVALENT FEED
AT LICENSED URANIUM RECOVERY FACILITIES
ADDRESSEES
U.S. Nuclear Regulatory Commission (NRC) licensed uranium recovery facilities; all holders of
NRC operating licenses for water treatment; all companies that have submitted applications to
construct all types of new uranium recovery facilities (conventional mills, heap leach facilities,
and in situ recovery (ISR) facilities); and all Radiation Control Program Directors and State
Liaison Officers.
INTENT
In 2000, the NRC developed Regulatory Issue Summary (RIS) 00-23, "Recent Changes to
Uranium Recovery Policy," (ADAMS Accession No. ML003773008) to address issues related to
uranium recovery. These issues include jurisdictional responsibilities of NRC and
Environmental Protection Agency (EPA) with respect to processing of alternate feed and tailings
and waste at uranium recovery sites. The NRC is issuing this RIS to provide guidance on the
impact the processing of alternative feed may have for individual licensees. Specifically, this
guidance addresses how to determine if the processing of certain alternative feed materials
requires a license amendment from NRC. This guidance describes the agency's policy that
receipt and processing, of "equivalent feed° (ion exchange resin media) at an NRC-licensed
uranium recovery facility, whether conventional, heap leach, or ISR, does not require a license
amendment when the resin is chemically and physically essentially the same as that which is
currently processed, would be processed using the facility's existing equipment, does not
exceed the license's uranium production limit and stays within the facility's environmental and
safety review envelope. It is not the intent of this RIS to change the policy expressed in RIS 00-
23 or redefine the definition of alternate feed. Rather, this guidance addresses one aspect of
how the alternative feed guidance in RIS-00-23 may be reflected in making a determination of
the need for a license amendment for individual licensees.
1 For the purposes of this RIS, equivalent feed is ion exchange (IX) resin that is loaded with uranium at
facilities licensed for source material (i.e. water treatment plants or mine dewatering operations) or licensed uranium recovery facilities whether conventional, heap leach, or ISR facilities.
ML110470571
RIS 2012-06
Page 2 of 7
BACKGROUND
As stated above, the NRC is issuing this RIS to clarify the NRC's policy regarding alternate
feed. In SECY-99-012, "Use of Uranium Mill Tailings Impoundments for the Disposal of Other
Than lle.(2)2 Byproduct Materials, and Reviews of Applications to Process Material Other Than
Natural Uranium Ores," (available at http://www.nrc.gov/reading-rm/doc-
collections/commission/secys/1999/) the staff defined alternate feed as material other than
natural uranium ores. Alternate feed can, therefore, be certain wastes, including sludges or
soils, from other sites that contains recoverable amounts of uranium. The RIS 00-23 provided
guidance on evaluating requests for a license amendment for a uranium recovery facility (i.e.,
conventional mill) to accept this material, recover the uranium, and dispose of the tailings (i.e.,
waste material) as byproduct material in the mill tailings impoundment. In contrast to a
conventional uranium recovery mill, in the ISR method, ore is not extracted from the ground for
processing at a mill. Rather, the ore is processed in-situ with the resulting uranium-bearing
fluids being passed through columns containing IX resins located on the surface. The uranium
ions in the fluids adhere to the IX resin (which is referred to as uranium loaded resin (ULR)).
The ULR is considered source material under NRC regulations and processed to remove the
uranium. Typically, the processed (stripped) resin is reused in ion exchange circuits until the
resin can no longer capture uranium ions (spent resin). The spent resin is considered lle.(2)
byproduct material under the Atomic Energy Act (AEA) and must be disposed of according to
NRC regulations.
The NRC staff's analyses have concluded the resin from certain source material operations,
such as community water treatment facilities and mine dewatering operations, are essentially
the same as the resin being used at licensed uranium recovery facilities (e.g. ISRs or
conventional mills/heap leach facilities using ion exchange circuits). The NRC staff based this
finding on the fact that the resins are chemically and physically essentially the same, and would
be processed in the same way, as resins used in normal uranium recovery operations at these
facilities.
Small Community Water Systems (CWSs) are required to remove uranium from drinking water
to meet EPA drinking water standards. The transport, treatment, and disposal of treatment
residuals (e.g., ULR resulting from the water treatment) can be a significant cost. It has been
noted by the EPA that for small-scale CWSs, handling of treatment residuals such as ULR may
account for 50 percent of their total operating budget3.
Similarly, mine dewatering operations involve the extraction of water from surface or
underground mines and, when necessary, the treatment of extracted water to remove pollutants
prior to discharge. Mine dewatering is often necessary to allow miners to safely extract ore. In
2 The Atomic Energy Act, as revised in 1978 and in 2005 by the Energy Policy Act, defines byproduct
material in Section lle(2) as "the tailings or wastes produced by the extraction or concentration of
uranium or thorium from any ore processed primarily for its source material content".
3 The EPA currently defines uranium-loaded resin generated by drinking water treatment to remove the
uranium as a Technically-Enhanced Naturally-Occurring Radioactive Material (TENORM) that requires
disposal at a facility permitted under Subtitle C or D of the Resource Conservation and Recovery Act.
RIS 2012-06
Page 3 of 7
the case of uranium mine dewatering, extracted water is often treated by IX resin to remove
uranium prior to discharge. These IX resins must either be disposed in a landfill or could be
eluted at a uranium recovery facility. It should be noted that in the past, mine dewatering resins
have been treated as alternate feed at conventional mills (57 FR 20532). These license
amendments were required because at that time, the staff considered the mine dewatering
resins to be processed or refined ore distinct from natural ore normally processed at a
conventional mill.
As a result, the NRC staff has been queried by representatives of the uranium recovery industry
and uranium water treatment suppliers/operators about the potential for licensed uranium
recovery facilities to accept and process ULR generated by drinking water treatment facilities
because the ULR can be processed in an ISR operator's existing ion exchange recovery circuit.
However, in the absence of the clarification provided by this RIS, the ISR uranium recovery
facility would be required to submit, and have the NRC approve, an amendment to its NRC
license prior to receiving and processing such resins. An amendment would be required
because without this clarification these resins would be considered an alternate feed, despite
the fact that such resins are chemically and physically essentially the same as those resins
currently used at ISR facilities during uranium recovery operations.
SUMMARY OF ISSUE
Currently, the only options for the disposition of ULR generated from operations other than
licensed uranium recovery operations (i.e., treating drinking water sources and mine
dewatering) are processing as alternate feed at a mill or disposal in landfills permitted under
the Resource Conservation and Recovery Act (RCRA) or licensed by the NRC or an
Agreement State. Under past interpretations of RIS 00-23, a license amendment would be
required for an NRC-licensed uranium recovery facility to accept ULR resulting from
treatment of community water supplies. The staff has determined that this interpretation
lacks technical integrity, does not reflect present day operating practices in the uranium
recovery industry and is not consistent with the Commission's intent in issuing RIS 00-23.
In particular, the NRC staff has determined that NRC and Agreement State-licensed
uranium recovery facilities should be permitted to accept these ULR as equivalent feed
without the need for a license amendment so long as the receiving facility can demonstrate
the ULR meets the equivalent feed criteria (i.e., it is physically and chemically essentially the
same as the resin being processed at the facility, can be processed on the current
equipment at the facility, processing the equivalent feed is within the facilities' existing safety
and environmental review envelope, and the processing does not exceed the license's
uranium production limit).
The basis for the staffs position relates to the original intent of RIS 00-23. The RIS 00-23 and
the underlying Commission decision was intended to address a concern that without restrictions
on the processing of material other than natural ore, a conventional uranium recovery mill could
process any material containing uranium and dispose the waste in the "tailings pile." Thus,
4 See page A2 of SECY-99-011, Draft Rulemaking Plan: Domestic Licensing of Uranium and Thorium
Recovery Facilities-Proposed New 10 CFR Part 41, and SECY-09-012, Use of Uranium Mill Tailings
Impoundments for the Disposal of Waste Other than 11e.(2) Byproduct Material and Reviews of
RIS 2012-06
Page 4 of 7
material very dissimilar to the material normally processed at a conventional mill would be
processed largely to allow disposal as lle.(2) byproduct material. In the case of ULR, the
concern addressed in RIS 00-23 is not at issue. For example, ULRs are physically and
chemically essentially the same as resins used to extract uranium at an in-situ recovery facility
and the resulting processing and waste products would be the same as those associated with
normal in-situ uranium recovery operations. Also similar to ISR resin, ULR from the CWS water
treatment, mine dewatering, and other uranium recovery facilities is designed to only capture
uranium and not other hazardous constituents.
Consequently, in this guidance, the staff is defining the term "equivalent feed" to apply to those
circumstances where the feed material is essentially the same chemically and physically as the
source material that is normally processed at a uranium recovery facility. Such material should
not to be considered as alternative feed requiring license amendments as described in
RIS 00-23 if it meets the equivalent feed criteria articulated in this RIS. Equivalent feed can
originate at a CWS or mine dewatering operation. In addition, equivalent feed can also include
ULR originating from another licensed uranium recovery facility. However, it should be noted
that processing of these ULRs for source material would need to occur before any waste would
be considered as 1le.(2) byproduct material.
To constitute equivalent feed, the ULR must be chemically and physically essentially the same
to that which is currently used at the licensed uranium recovery facility and must not result in
additional waste streams or risks not assessed during the process of licensing the receiving
uranium recovery facility. For example, a typical uranium treatment resin for drinking water (Z-
92e) is produced by Lanxess (also known as Sybron Chemicals). The Z-92® resin is
essentially the same in composition and function to the Dow 21K resin, the typical ion exchange
resin used at most uranium recovery facilities. A comparison of the product information of Z-
92® resin to that of Dow 21K resin indicates the following:
Both are a strong-base, Type I anion exchange resin;
The composition of both is divinylbenzene (dvb) styrene;
The functional group of both is a quarternary amine;
The physical form of both is resin beads with essentially the same bulk weight, color,
and amine odor;
The Z-92® resin is available in a similar bead-size range to that of Dow 21K;
Water Remediation Technologies, Inc. identifies the Z-92® resin as selective for
uranium; the Dow 21K resin is also selective for uranium.
The primary difference between the Z-920 and the typical uranium recovery IX resin is that the
water treatment resin is marked and packaged specifically for use in potable water systems and,
therefore, undergoes an additional step of the Water Quality Association testing for certification
to ANSI/NSF Standard 61.
Applications to process Materials Other than Natural Uranium Ores, available at
htto://www.nrc.bov/readinb-rm/doc-collections/commission/secys/1999/)
RIS 2012-06
Page 5 of 7
An example for mine dewatering would be Kennecott Uranium Company. Upon staff inquiry,
Kennecott Uranium Company stated that its mine dewatering resin is the Dow 21K resin that is
discussed above, which is the same resin used at ISR facilities. Therefore, the staff determined
that mine dewatering resins, like loaded resins from CWSs, can be more appropriately classified
as equivalent feed when they are sent for processing at a uranium recovery facility.
Given that ULRs from a CWS and resins from mine dewatering processes are physically and
chemically essentially the same as those resins processed at a uranium recovery facility; the
staff sees no basis for requiring that uranium recovery operators with a NRC or Agreement
State licensed resin processing plant obtain a license amendment to process this essentially
same material. The same process is also used for eluting or recovering uranium from water
treatment and resins used in the uranium recovery industry. Therefore, the NRC staff
determined that water treatment resins and resins from mine dewatering processes should be
defined as equivalent feed if the ULR from these sources meet the equivalent feed criteria.
Thus, the processing of equivalent feed at a licensed facility will not require an amendment to
an existing license so long as the existing license uranium production limits are not exceeded,
the processing is within the existing safety and environmental review envelope, and the ULR
would be processed using existing equipment at the receiving facility. This analysis would also
be applicable to any other sources of ULR not specifically addressed in this RIS, as long as the
resins meet all the equivalent feed criteria.
In a similar fashion to ULRs originating from a CWS or mine dewatering operation, ULRs from
another licensed uranium recovery facility can also be treated as equivalent feed if it meets the
above mentioned criteria. As such, processing of this equivalent feed will not require an
amendment to an existing NRC license so long as the existing limits on production of uranium in
the license are not exceeded, the processing is within the existing safety and environmental
review envelope, and the ULR would be processed using existing equipment at the facility.
After processing the equivalent feed, the spent resin can be disposed as byproduct material in
the same manner as the resin used in the primary uranium recovery activity. Disposal sites
could either be existing mill tailings impoundments or other disposal facilities licensed by the
NRC or Agreement States. No additional disposal requirements are necessary. This approach
benefits our National interest by recovering a valuable resource and the environment by
providing additional options such as recycling and reuse instead of disposal for this material.
Alternately, the stripped resin may be disposed as byproduct material or returned to the water
treatment facility, a mine dewatering facility, or a licensed uranium recovery facility for reuse.
Reuse of IX resin is a standard uranium recovery industry practice that reduces operating
expenses as well as the volume of waste sent to disposal. Therefore, the reuse of IX resin by
water treatment or mine dewatering facilities is consistent with current Commission policies and
industry practices. This provides an economic benefit to the treatment facilities (particularly
CWSs) by reducing operating costs and the amount of resin requiring disposal.
Enclosure 1 to this RIS offers additional information, which addressees may find useful, about
uranium recovery processing of equivalent feed. Enclosure 2 contains procedures which the
NRC finds satisfactory for accepting equivalent feed.
RIS 2012-06
Page 6 of 7
BACKFIT DISCUSSION
This RIS requires no action or written response. Any action that addressees take to implement
changes or procedures in accordance with the information contained in this RIS ensures
compliance with current regulations, is strictly voluntary, and, therefore, is not a backfit under
any of the backfitting provisions contained in Title 10 of the Code of Federal Regulations
(10 CFR) 50.109, 70.76, 72.62, 76.76, or the issue finality provision of 10 CFR Part 52.
Consequently, the staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was published in the Federal Register
(76 FR 60942) on September 30, 2011, for a 30 day comment period. Comments were
received and considered in finalizing this RIS.
CONGRESSIONAL REVIEW ACT
This RIS is a rule as designated in the Congressional Review Act (5 U.S.C. 801-808).
The Office of Management and Budget has determined that this RIS is not a major rule.
RELATED GENERIC COMMUNICATIONS
RIS 00-23, "Recent Changes to Uranium Recovery Policy."
PAPERWORK REDUCTION ACT STATEMENT
This RIS references information collection requirements that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collection requirements
were approved by the Office of Management and Budget, approval numbers 3150-0020.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number.
RIS 2012-06
Page 7 of 7
CONTACT
This RIS requires no specific action or written response. If you have any questions about this
summary, please contact the technical contact listed below.
/RA/
Larry W. Camper, Director
Division of Waste Management
and Environmental Protection
Office of Federal and State Materials
and Environmental Management Programs
Technical Contact: Ted Carter, DWMEP/MDB
[phone]
E-mail: [e-mail]
Enclosures:
1. Uranium Recovery Processing of
Equivalent Feed: Additional Information
2. Procedure for Accepting Equivalent Feed
3. Responses to Comments on the Policy
Regarding Submittal of Amendments for
Processing of Equivalent Feed at
Licensed Uranium Recovery Facilities
4. FSME Recently Issued Generic Communications
RIS 2012-06
Page 7 of 7
CONTACT
This RIS requires no specific action or written response. If you have any questions about this
summary, please contact the technical contact listed below.
/RA/
Larry W. Camper, Director
Division of Waste Management
and Environmental Protection
Office of Federal and State Materials
and Environmental Management Programs
Technical Contact: Ted Carter, DWMEP/MDB
[phone]
E-mail: [e-mail]
Enclosures:
1. Uranium Recovery Processing of
Equivalent Feed: Additional Information
2. Procedure for Accepting Equivalent Feed
3. Responses to Comments on the Policy
Regarding Submittal of Amendments for
Processing of Equivalent Feed at
Licensed Uranium Recovery Facilities
4. FSME Recently Issued Generic Communications
ML120890102
Office DWMEP FSME OGC DWMEP DWMEP
Name TCarter AMcIntosh JOImstead SAchten PMichalak
Date 02/3/12 02/10/12 03/29/12 03/29/12 03/30/12
Office DWMEP OIS OE DWMEP
Name KMcConnell TDonnell NHilton LCamper
Date 4/03 /12 4/09 /12 4 /16 /12 04/16 /12
OFFICIAL RECORD COPY
RIS 2012-06
Enclosure 1
Uranium Recovery Processing of Equivalent Feed: Additional Information
Processing as equivalent feed, the uranium loaded resins (URL) from water treatment plants,
mine dewatering operations or other uranium recovery facilities (e.g. in-situ recovery (ISR) or
conventional mills/heap leach facilities with ion exchange circuits) results in a lower overall
environmental impact and is the preferred option when compared to disposal of these resins in
a Resource Conservation & Recovery Act (RCRA)-permitted landfill or NRC and Agreement
State licensed landfill. Transportation impacts for the facility producing the URL are similar
since in either option, the resin is trucked to an isolated location away from population centers
(RCRA-permitted or NRC/Agreement State licensed landfill or a uranium recovery facility).
Although disposal of equivalent feed in a lined RCRA-permitted landfill or NRC/Agreement State
licensed landfill provides short term isolation of the URL, the long term environmental and
financial liability associated with potential landfill failure coupled with the societal benefit of
putting the uranium into the nuclear fuel cycle results in uranium recovery facility processing of
equivalent feed, such as uranium-loaded water treatment and mine dewatering resin, as the
preferred environmental option.
Processing water treatment resins as equivalent feed provides a significant cost benefit to small
Community Water Systems. For these small water treatment operators, disposal at RCRA-
permitted or NRC/Agreement State licensed landfills is cost prohibitive. Although, at this time, it
is not possible to know the exact financial arrangements between the water treatment and
uranium recovery facilities with respect to the processing of equivalent feed, it is reasonable to
assume that the financial arrangements would be significantly more beneficial to the small water
treatment operators than landfill disposal.
RIS 2012-06
Enclosure 2
Procedures for Accepting Equivalent Feed
In situ recovery (ISR), conventional mills, or heap leach facilities with NRC or Agreement State
licensed resin processing plants, may accept equivalent feed, as defined in this regulatory issue
summary, without a license amendment. The licensee should document that the received
uranium loaded resins (ULRs) meet the equivalent feed criteria by being: (1) chemically and
physically essentially the same as the resins processed at the facility; (2) using existing
equipment, processed the same way as the resins processed at the facility; and (3) processing
the equivalent feed material does not exceed the uranium production limits in the license and
stays within the existing safety and environmental review envelope for the facility. The NRC
inspectors will review this documentation during the inspection process to verify that the
received ULR meet the equivalent feed criteria such that the licensee's processing of the
material can be considered consistent with their license.
Following elution of the ULR equivalent feed (i.e., removal of the uranium from the treatment
resin), the resulting stripped resin can take two paths. Since the NRC is allowing equivalent
feed to be processed at uranium recovery facilities, the wastes associated with processing
equivalent feed (i.e., stripped resin) can be considered byproduct material, as defined in Title
10 of the Code of Federal Regulations Part 40. Therefore, these wastes could be disposed of at
an NRC-licensed facility without further documentation. Alternatively, the stripped resin may be
returned to a water treatment facility, a mine dewatering facility or a licensed uranium recovery
facility for reuse. Reuse of IX resin is a standard uranium recovery industry practice that
reduces operating expenses as well as the volume of waste sent to disposal. Therefore, the
reuse of IX resin by water treatment or mine dewatering facilities is consistent with current
Commission policies and industry practices. Spent resin that can no longer be re-used in the
IX process is considered lle.(2) byproduct material and must be disposed in accordance with
NRC regulations.
Department of
Environmental Quality
L Scott Baird
Executive Director
FILE COPy
State of Utah
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
May 26, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
RE: Processing Uranium Precipitate from Uranium Resources Inc.' s Kingsville Dome,
Texas Uranium In-Situ Recovery Facility at the White Mesa Mill
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
In a letter dated April 30, 2020, Energy Fuels Resources (USA) Inc. (EFRI) informed the Division of
Waste Management and Radiation Control (DWMRC) of EFRI's intent to transfer a uranium precipitate
material from the Uranium Resources Inc.' s (URI) Kingsville Dome, Texas Uranium In-Situ Recovery
Facility to the White Mesa Uranium Mill, located just south of Blanding, Utah. EFRI indicated that the
uranium precipitate material could be transferred between the Kingsville Dome facility and the White
Mesa Mill because both facilities are authorized to receive and transfer the licensed source material
(U308). EFRI asserted that this would be a legal transfer of licensed source material in accordance with
10 CFR 40.51(a)(5) [equivalent to UAC R313-19-41(2)(d)]. The purpose of this transfer is so the
uranium precipitate can be processed to remove impurities, dried and then packaged as a useable
yellowcake product at the White Mesa Mill. In the letter, EFRI explains that the uranium precipitate
comes from an intermediate step in the Kingsville Dome facility's process. Due to the impurities that
are present in the uranium precipitate, the Kingsville Dome facility is unable to make it into usable
yellowcake. The White Mesa Uranium Mill however, can remove the impurities. Thus, the request to
transfer the uranium precipitate to complete the process of making usable yellowcake.
(Over)
DRC-2020-010068 195 North 1950 West • Salt Lake City, UT
Mailing Address P.0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
anow.deq.utah.gov
Printed on 100% recycled paper
The DWMRC has evaluated the information provided by EFRI regarding this request. Based on the
Nuclear Regulatory Commission's (NRC) conclusions that milling processes may occur at locations
other than a uranium mill and that milling processes are not completed until the conversion process
begins (SECY-02-0095), and on the Utah Radiation Control Rules, DWMRC staff agree that the
Kingsville Dome uranium precipitate is still in the milling process and that the yellowcake material from
the Kingsville Dome facility can be transferred to EFRI's White Mesa Uranium Mill under the
provisions in R313-19-41(2)(d). Therefore, no amendment is necessary to EFRI's license for the
transfer of URI's yellowcake material. The following provisions apply to the DWMRC's concurrence
for the transfer of the yellowcake material from URI's Kingsville Dome, Texas Uranium In-Situ
Recovery Facility to the White Mesa Uranium Mill:
• This concurrence for transfer of materials is exclusively for the uranium precipitate material
from the URI' s Kingsville Dome, Texas Uranium In-Situ Recovery Facility and does nbt apply
to other future projects. Any additional uranium precipitate material from other facilities will
require Director approval.
• The yellowcake produced from this project must be counted toward the yellowcake production
limits in EFRI's RML License Condition 10.1.A.
• Transportation of the uranium precipitate material in Supersaks® shall be within an enclosed
transport conveyance to provide secondary containment for possible leakage.
• The Supersakse containing the uranium precipitate shall be stored on the concrete near the
White Mesa Uranium Mill's grizzly and inspected weekly for degradation and holes. If
degradation or holes are identified, the Supersakst shall be repackaged.
• The White Mesa Mill has 365 days to process the uranium precipitate from the date of receipt. If
the material is not processed within 365 days, it shall be put into the tailing impoundment as
1le.(2) disposal.
The DWMRC will inspect compliance aspects of this project during future inspections at the White
Mesa Mill. If you have any questions, please contact Ryan Johnson, at 801-536-4255.
Sincerely,
Ty L Howard, Director
Division of Waste Management and Radiation Control
TLH/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, Manager, White Mesa Uranium Mill
ENERGy Funs
April 30, 2020
VIA EMAIL AND EXPEDITED DELIVERY
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 84114-4880
Re: URI Kingsville Uranium Precipitate Product
Dear Mr. Howard:
Div of Waste Management
and Radiation Control
MAY - 6 2020
Please be advised that Energy Fuels Resources (USA) Inc. ("EFRI") intends to receive uranium precipitate
product ("Uranium Precipitate"), an intermediate form of yellowcake from Uranium Resources Inc.' s ("MI's")
Kingsville Dome, Texas uranium in-situ recovery ("ISR") facility (the "Site"), at the White Mesa Mill (the
"Mill"), as a "licensee-to-licensee" transfer of source material under 10 CFR 40.51(5). The Mill will then
concentrate and purify the Uranium Precipitate for the recovery of commercially salable yellowcake as a
continuation of the milling process begun at the URI facility. As the Uranium Precipitate is currently classified
as 11 e.(2) byproduct material from an ISR facility, the Mill is licensed to receive the Uranium Precipitate under
Condition 10.5 of the Mill's Radioactive Materials License (the "Mill License") as 1 1 e.(2) byproduct for direct
disposal in the Mill' s tailings system. However, because the Uranium Precipitate is an intermediate form of
yellowcake, with significant recoverable uranium value, EFRI intends to process the material for the purification
and concentration of the contained uranium rather than dispose of it directly.
Historic URI and EFRI Management of the Uranium Precipitate
URI' s ISR process extracts uranium solutions directly from the sandstone formation which hosts the uranium ore
body, without excavation and digestion of the host ore rock. This part of the ISR process performs the same
function for in-situ sandstone ores as the leach, CCD, and clarification steps of the Mill perform for excavated
hard rock ores. At the Site, the extracted uranium solutions are processed for recovery of the uranium values in
the central processing plant in which the subsequent sequence of steps or circuits is comparable, or in some cases
identical, to the concentration, precipitation, and drying steps of a conventional uranium mill. Materials removed
from the backwashing and flushing of filters, resin beds, and process lines in the ISR plant are similar to materials
removed from these types of equipment in the Mill. In the Mill, solids and slurries generated from backwashing
and flushing of equipment can be returned to any number of points in the circuit, such as acid or alkaline re-
digestion, counter-current decantation ("CCD"), or clarification steps, for additional removal of metal impurities
and recovery of the contained uranium values. However, unlike the Mill, ISR facilities do not operate acid or
alkaline digestion circuits or CCD circuits. Hence, when ISR facilities like the Site withdraw and collect uranium-
bearing solids that require re-digestion, or re-purification to remove metal impurities, they cannot sufficiently re-
condition the withdrawn product.
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140 0 13 C - 20 2, 0 - 0 o , 7 19 www.energyfuels.cona
Letter to Mr. Ty L. Howard
April 30, 2020
Page 2
Over the past 27 years of operation, such solids accumulated at the Site in the filtration, ion exchange, and
membrane equipment from backwashing and rinsing. This material contained recoverable uranium, as well as
elevated levels of iron and impurities, remaining from the ore source. Due to its uranium content, the material
recovered froth the backwashing of the filtration and concentration operations (the "Pond Material") was
segregated from other streams and stored in two on-site ponds (the north and south ponds). Since the Pond
Material contained a significant amount of uranium, URI made extensive efforts to isolate the Pond Material for
the potential future continuation of the milling process and conversion of the Pond Material into a commercially
salable uranium product.
From 2008-2013, URI shipped a portion of the Pond Material to the Mill for direct disposal in the Mill's tailings
system as 1 le.(2) byproduct Material.
In 2013, URI attempted to continue the milling process and conversion of a portion of the Pond Material into a
commercially salable uranium product, and produced approximately 38,000 pounds of Uranium Precipitate,
which is a sodium diuranate wet yellowcake material. URI used the same type of alkaline precipitation with
sodium ions to produce the Uranium Precipitate, as the alkaline precipitation with ammonium ions conducted at
the Mill to produce the Mill' s ammonium diuranate wet yellowcake, which is fed to the Mill' s dryers. However,
the alkaline precipitation which recovered the Uranium Precipitate from the Pond Material precipitated not only
the uranium, but the iron as well. As a result, the Uranium Precipitate, or sodium diuranate wet yellowcake,
contains iron at levels in excess of commercially acceptable yellowcake product. Because the Site does not
contain circuits capable of removing the iron from the Uranium Precipitate, URI has been unable to condition the
Uranium Precipitate to meet commercial limits for iron content.
The Mill, with its existing process equipment, is able to remove iron before the uranium is re-concentrated in the
Mill's precipitation circuit, in the same way the Mill re-processes its own off-spec product to remove excess metal
impurities, as discussed below. In other words, the Uranium Precipitate is the same type of intermediate
yellowcake product the Mill deals with on a routine basis when it re-processes its own off-spec product to remove
excess metal impurities. The Mill is able to take this intermediate product and run it through its existing circuits
to continue the milling process by concentrating and purifying this intermediate Uranium Precipitate product into
commercially salable yellowcake.
Proposed Reprocessing of the Uranium Precipitate
Under the proposed transaction, URI will transfer the Uranium Precipitate to the Mill under 10 CFR 40.51 and
the Mill will receive the Uranium Precipitate under the existing Mill License, as a "licensee-to-licensee" transfer
of source material.
The Uranium Precipitate will be shipped to the Mill in the same type of Supersaks®, and in the same type of
transport vehicles as has been used to date for the direct disposal of 1 le.(2) byproduct material from the Site. The
Uranium Precipitate will then be removed from the Supersaks® and introduced into one of the Mill's existing
circuits, to be concentrated and purified into a yellowcake product that meets commercial specifications for
introduction into a conversion facility. As discussed above, the Uranium Precipitate consists of an intermediate
uranium product, a form of yellowcakel, which requires removal of iron impurities, dewatering, and drying, to
Uranium milling produces a number of different uranium oxide products any of which, or combinations of which,
comprise wet or dry "yellowcake". Depending on the precipitation agent, and/or the extent of drying, yellowcake products
may be in the chemical form of sodium diuranate, ammonium diuranate, uranium dioxide, uranium trioxide, and triuranium
octoxide, or others. (Hausen 1998, Kent and Riegel 2007)
Letter to Mr. Ty L. Howard
April 30, 2020
Page 3
meet the ASTM standards for commercial yellowcake product. The Uranium Precipitate may be ground in the
SAG mill and fed to the leach circuit, fed directly to the CCD circuit, or fed to the alternate feed circuit to reenter
the main Mill at the SX circuit. Solution leaving the CCD circuit or alternate feed circuit will be clarified and
thickened, fed to the SX circuit, and will proceed through the remainder of the Mill process in the same manner
as solutions leached from ores and other feeds. The Mill's processing of the Uranium Precipitate will result in a
concentrated and purified form of yellowcake that meets all of the commercial specifications for yellowcake.
The resulting tailings, including the emptied Supersaks®, will be disposed of in the Mill's tailings cells as 1 le.(2)
byproduct material. The steps and processes involved in putting the material into solution, and precipitating,
drying and packaging the yellowcake, will be no different from the steps that would be taken by the Mill to
recirculate and recondition any other off-spec product generated at the Mill. The process of emptying the
Supersaks®, will be no different from the process of introducing into the Mill any other feed delivered in
Supersaks®.
Our ongoing discussions with URI confirm that neither the Pond Material nor the Uranium Precipitate has been
combined with, nor contains, any other materials or constituents. Indeed, since URI viewed the Pond Material as
recoverable product, throughout the life cycle of the material they have taken steps to ensure that it was not
contaminated with any other plant materials, so it could potentially be processed into commercially salable
uranium oxide product at a later date. The details provided below confirm that the Pond Material and Uranium
Precipitate has not been commingled with any other material or constituents.
URI proposes to ship approximately 38,000 wet pounds of Uranium Precipitate (approximately 60% moisture,
40% solids) containing approximately 2,000 dry pounds of U308.2 Based on the information below, EFRI
believes that the Uranium Precipitate can be concentrated and purified into commercially salable yellowcake in
the Mill's existing process circuits. The Supersaks® would then be disposed of in the Mill's tailings cells in the
same manner as Supersaks® currently received with 1 le.(2) byproduct materials.
EFRI believes it is preferable to remove the uranium content from the Uranium Precipitate prior to disposal in
the Mill' s tailings impoundments because this additional step will:
1. reduce the total radioactivity contributed to the tailings by removal of the uranium activity; and
2. recover an economically valuable uranium resource.
Because URI is unable to concentrate and purify the Uranium Precipitate into commercially salable yellowcake
product at the Site, it has agreed that all of the concentrated and purified yellowcake from the Uranium Precipitate
will be for the sole account of EFRI. In consideration, EFRI has agreed to receive the Uranium Precipitate, which
would otherwise need to be disposed of directly as 1 le(2) byproduct material at the Mill if not concentrated and
purified into commercially salable yellowcake product, without the need for URI to pay the normal 1 le.(2)
byproduct material disposal fee for that volume of material.
2 While these are our best estimates of quantities at this time, it would not be unreasonable to expect that these quantities
could increase by up to 50%. Therefore, for purposes of this letter, we assume that the quantities are up to approximately
57,000 wet pounds of Uranium Precipitate and approximately 3,000 dry pounds of contained U308.
Letter to Mr. Ty L. Howard
April 30, 2020
Page 4
Characterization Data
URI performed sampling and characterization of the Pond Material and Uranium Precipitate over a period of
several years as indicated in the summary below:
Sampling Date Number of Samples Analyses
April 2012 1 TCLP metals; TCLP Base-Neutral
Extractables (SVOCs); radionuclides. This
is a sample of the Pond Material.
May 2013 1 TCLP metals; TCLP Base-Neutral
Extractables (SVOCs). This is a sample of
the Uranium Precipitate
April 2014 2 TCLP Base-Neutral Extractables (SVOCs).
This is a sample of the Uranium Precipitate.
April 2015 2 Total Metals; Total VOCs; Total SVOCs.
This is a sample of the Uranium Precipitate.
The data, which resulted from multiple samples collected over a four-year period, are sufficiently representative
of the composition of the Pond Material and the Uranium Precipitate. Laboratory Reports for the above sampling
events are provided in Attachment 1. Data from the analyses are discussed below.
The data demonstrate that the Uranium Precipitate product contains elevated levels of impurities that make it
inconsistent with the ASTM standard for acceptable ranges of impurities in commercial yellowcake product. The
Table in Attachment 1 compares each of the analytical results for total metals from the 2015 sampling to the
ASTM C967-08 Standard Specification for Uranium Ore Concentrate.
The data also indicate that the Uranium Precipitate:
• consists of natural uranium concentrates (yellowcake);
• contains no volatile organic (VOC) or semi-volatile organic constituents (SVOCs);
• contains no constituents other than those associated with recovery of natural uranium from the host ore
body; and
• does not exhibit the RCRA toxicity characteristic (its constituents are not leachable by the RCRA test
methods).
The data also demonstrate the consistency and stability over time of the Pond Material and resulting Uranium
Precipitate. As would be expected in an ISR plant setting, the data confirm that over the four-year period during
which the various test samples were collected, no hazardous organic constituents or organic wastes of any type
were added to the Pond Material or Uranium Precipitate. The components of the Uranium Precipitate which are
not specified in Table 1 or the analytical data reports are sediments (muds and sands) from the URI uranium
purification process which were entrained in the Pond Material when it was first transferred to the ponds.
Letter to Mr. Ty L. Howard
April 30, 2020
Page 5
Regulatory Considerations
EFRI has considered the following in making its determination and conclusions.
Transport
USDOT regulations and existing procedures already regulate the shipment of 1 le.(2) byproduct material between
the Site and the Mill. Pond Material has already been shipped to the Mill from the Site for direct disposal as
1 1 e.(2) byproduct material, and if not further concentrated and purified at the Mill, the Uranium Precipitate would
be disposed of directly at the Mill as 1 le.(2) byproduct material. The number of trucks associated with
transporting the Uranium Precipitate to the Mill will be the same whether the material is transported to the Mill
for direct disposal as 1 le.(2) byproduct material or for concentration and purification into commercially salable
yellowcake product.
Receipt
The first paragraph and Conditions 6, 7, and 8 of the Mill License allow EFRI to "transfer, receive, possess and
use" "natural uranium" "in any form" with "no maximum quantity limit". Receipt of the Uranium Precipitate
Material would be a licensee-to-licensee transfer of source material to the Mill under 10 CFR 40.5 1 (5), because
the Mill is "authorized to receive such source or byproduct material" under the terms of the Mill License, which
is "a specific license or a general license or their equivalents issued by the Commission or an Agreement State,"
as required by that regulation.
Composition of the Transferred Source Material
As discussed above, the Uranium Precipitate consists solely of precipitated uranium product from the Site's
uranium filtration and uranium concentration area cleanout steps. Neither the Uranium Precipitate nor the
Supersaks® contain any constituent that is not present and handled routinely at the Mill. The Uranium Precipitate
is a further refined version of the Pond Material that has previously been shipped to the Mill for direct disposal
in the Mill's tailings system as 1 le.(2) byproduct material.
The detailed analysis of the Uranium Precipitate is discussed above. The,Supersaks® to be used for shipment are
the same type of conveyance received at the Mill and disposed of in the tailings system on a regular basis from
other feed materials. In fact, as discussed above, the Pond Material prior to precipitation, and the Supersaks® in
which it was transported, have been disposed of directly in the Mill's tailings system as 1 1 e.(2) byproduct material
since 2008.
Concentration and Purification of the Uranium Precipitate
The Uranium Precipitate does not meet the specifications required for acceptance at a uranium conversion facility
due to its moisture content, its elevated iron content, and the presence of other impurities indicated in the
analytical data. It therefore requires further concentration and purification at the Mill in order to produce
yellowcake that meets commercial specifications. It should be emphasized that all of the impurities are typical
of uranium ores and are well within the concentrations of the constituents that are present in and removed from
ores, reprocessed yellowcake, and alternate feed materials at the Mill. The Table in Attachment 2 compares the
levels of impurities in the Uranium Precipitate to those of other feeds historically processed at the Mill.
Letter to Mr. Ty L. Howard
April 30, 2020
Page 6
The United States Nuclear Regulatory Commission ("NRC") has concluded that concentrating and purifying
yellowcake in these circumstances is uranium milling and that the resulting wastes are 1 1 e.(2) byproduct material.
In Staff Requirements — SECY-02-0095 — Applicability of Section 1 1 e.(2) of the Atomic Energy Act to Material
at the Sequoyah Fuels Corporation Uranium Conversion Facility, NRC concluded that wastes generated at the
front end of the Sequoyah Fuels Corporation conversion facility ("SFC") that resulted from the further
concentration and purification of yellowcake that it had received from uranium mills can be classified as 1 le.(2)
byproduct material. In that decision, the Commission accepted NRC Staff s position that "The staff has not found
it necessary to label the feed for each step of the milling process as "ore" as the basis for classifying the waste
from that step as 1 le.(2) byproduct material. When yellowcake underwent additional concentration at the front
end of SFC, it was a continuation of uranium milling, i.e., another step of the milling process. Thus, that part of
the processing at a conversion facility fulfills the "extraction or concentration" terms of 1 le.(2) byproduct
material."3 Unlike SFC, the Site does not have a front-end concentration and purification stage, and therefore
must send the Uranium Precipitate to the Mill to perform this final stage of uranium milling. As indicated by
NRC Staff, and adopted by the Commission, "[the Office of the General Counsel] has advised the staff that the
definitions of uranium milling and 1 le.(2) byproduct material are process-related definitions and not restricted to
a particular location of activity nor the physical characteristic of a material."' In fact, NRC Staff noted a number
of circumstances where uranium mills in the past each performed a part only of the uranium milling process and
then shipped the resulting produced material or concentrates to another licensed facility for further milling. NRC
Staff noted that "[e]ach of these mills and several others accomplished only a portion of the milling process at
dispersed locations but were all licensed operations at one time."'
Concentrating and purifying the Uranium Precipitate at the Mill is therefore another step of the uranium milling
process, and all wastes associated with such milling are classified as 1 le.(2) byproduct material and can be
disposed of in the Mill's tailings cells.
Disposal
As determined by NRC in Sequoyah, all wastes associated with further concentration and purification of
yellowcake can be classified as 1 le.(2) byproduct material. Since the concentration and purification of the
Uranium Precipitate at the Mill involves the same steps in the milling process as for other uranium product, the
purification to be performed at the Mill is a continuation of the milling process begun at the Site, and all wastes
associated with the milling will be the same as wastes associated with concentration and purification of
yellowcake at the Mill. The same can be said for the Supersaks®. The Mill routinely disposes of Supersaks@
from the various sources listed above as 1 le.(2) byproduct material in its tailings cells. Since there are no new
or additional constituents in the Uranium Precipitate and associated Supersaks@, there will be no human health,
environmental, or worker safety impacts due to new or additional constituents above those already managed at
the Mill.
The Uranium Precipitate is Source Material and not an Alternate Feed Material
The Uranium Precipitate is source material that is being transferred to the Mill under 10 CFR 40.5 1 and the Mill
License and will be further concentrated and purified as a step in the uranium milling process. It is not an "ore"
and hence is not an alternate feed material. In fact, in its recommendation to the Commission in the Sequoyah
3 Policy Issue (Notation Vote) SECY-02-0095, page 3.
Policy Issue (Notation Vote) SECY-02-0095, footnote 2.
5 Policy Issue (Notation Vote) SECY-02-0095, Attachment 5: Uranium Milling Activities at Sequoyah Fuels Corporation,
page 2
Letter to Mr. Ty L. Howard
April 30, 2020
Page 7
decision, NRC Staff noted that "[w]hether the incoming source material to SFC meets the definition of "ore" is
not relevant to the argument of waste classification. Declaring an incoming feed for individual milling-process
stages as "ore," throughout the continuum of milling, is an artificial and unnecessary distinction. When milling
is done at one site, the feed for each stage is not considered when making 1 1 e.(2) byproduct material
determinations for the classification of wastes for each stage. Similarly, uranium milling has, and does, occur at
different locations under regulatory oversight without the construct of individual processing feeds meeting the
definition of "ore." Thus, there is no need to consider the feed at SFC as ore, because the front-end process at
SFC was simply the last step in the milling activity." This issue was discussed in detail in EFRI's submittal to
Utah DRC on July 26, 2013, which addressed the Mill's proposed receipt as source material of a similar off-spec
yellowcake product from Honeywell, Inc.
Conclusion
The Uranium Precipitate can be received at the Mill as a licensee-to-licensee transfer of source material under 1 0
CFR 40.5 1 (5) and the Mill License. The Uranium Precipitate can be further concentrated and purified at the Mill
as a step in the uranium milling process in order to produce yellowcake that meets commercial specifications.
All wastes from such concentration and purification can be disposed of in the Mill's tailings cells as 1 1 e.(2)
byproduct material. As the Uranium Precipitate is not an "ore" it is not an alternate feed material, and hence an
amendment to the Mill License is not required.
Further, there are no additional environmental, health, or safety concerns associated with the receipt of the
Uranium Precipitate, or the concentration, purification, precipitation, drying and packaging of the Uranium
Precipitate and the disposal of the SuperSaks® in the Mill's tailings cells. The Uranium Precipitate has the same
chemical composition as other intermediate streams produced in the Mill, and the associated SuperSaks® are the
same type of conveyance received and disposed of at the Mill on a regular basis. No additional or new chemicals
or reagents will be used in the process. The concentration and purification of the Uranium Precipitate will result
in the recycling of uranium values that would otherwise be disposed of in the Mill's tailings system, and will
reduce the radionuclide content of the 1 1 e.(2) byproduct material to be disposed of after the recovery of the
uranium values in the Mill.
Please advise us as soon as possible whether you concur with EFRI' s determinations as described in this letter.
If you should have any questions regarding the above information, please contact me at 303-3 89-4 1 30.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
David C. Frydenlund
Senior Vice President, General Counsel, and Corporate Secretary
cc: Phillip Goble (DWMRC)
Scott Bakken
Mark Chalmers
Paul Goranson
Logan Shumway
Jo Ann Tischler (TCS)
Kathy Weinel
Letter to Mr. Ty L. Howard April 30, 2020
Page 8
REFERENCES
Hausen 1998. D. M. Hausen. Characterizing and Classifying Uranium Yellowcakes, A Background. Journal
of the Minerals, Metals and Materials Society, Volume 50 Issue 12, pp45-47
Kent and Riegel 2007. James A. Kent and Emil Riegel Kent and Riegel's Handbook of Industrial Chemistry
and Biotechnology, Eleventh Edition. Springer Science and Business Media, New York 2007.
ATTACHMENT 1
Characterization Data
Page 1 of 26
04 ACCoft
(.)
REPAD.01.06.05.02
• ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs. CO 80487 (800) 334- 9
Analytical
Report

May 17, 2012
Report to:
Joshua Holland
Uranium Resources Inc.
405 State Highway 121 Bypass A110
Lewisville, TX 75067
cc: Jim Kegebein
Bill to:
Terry Blaszak
Uranium Resources Inc.
405 State Highway 121 Bypass A110
Lewisville, TX 75067
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
Joshua Holland:
Enclosed are the analytical results for sample(s) submitted to ACZ Laboratories, Inc. (ACZ) on April 20, 2012.
This project has been assigned to ACZ's project number, L94161. Please reference this number in all future
inquiries.
All analyses were performed according to ACZ's Quality Assurance Plan. The enclosed results relate only to
the samples received under L94161. Each section of this report has been reviewed and approved by the
appropriate Laboratory Supervisor, or a qualified substitute.
Except as noted, the test results for the methods and parameters listed on ACZ's current NELAC certificate
letter (#ACZ) meet all requirements of NELAC.
This report shall be used or copied only in its entirety. ACZ is not responsible for the consequences arising
from the use of a partial report.
All samples and sub-samples associated with this project will be disposed of after June 17, 2012;If the
samples are determined to be hazardous, additional charges apply for disposal (typically $11/sample). If you
would like the samples to be held longer than ACZ's stated policy or to be returned, please contact your Project
Manager or Customer Service Representative for further details and associated costs. ACZ retains analytical
raw data reports for ten years.
If you have any questions or other needs, please contact your Project Manager.
Sue Webber has reviewed and approved this report
•
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Case
Narrative

Uranium Resources Inc. May 17, 2012
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
Sample Receipt
ACZ Laboratories, Inc. (ACZ) received 1 sediment sample from Uranium Resources Inc. on April 20, 2012. The sample was
received in good condition. Upon receipt, the sample custodian removed the sample from the cooler, inspected the
contents, and logged the sample into ACZ's computerized Laboratory Information Management System (LIMS). The sarnple
was assigned ACZ LIMS project number L94161. The custodian verified the sample information entered into the computer
against the chain of custody (COC) forms and sample bottle labels.
Holding Times
All analyses were performed within EPA recommended holding times except for the BNA analysis flagged with an "HC" and
an "Nl". The initial analysis was performed within the hold time but due to a QC failure, the sample was rerun outside of the
hold time. The re-analysis confirmed the original values.
Sample Analysis
This sample was analyzed for inorganic, organic, radiochemistry parameters. The individual methods are referenced on
both, the ACZ invoice and the analytical reports. The following anomalies required further explanation not provided by the
Extended Qualifier Report:
1. The sample was received outside of the recommended temperature range of 0 to 6 degrees C.
2. For the Isotopic Uranium values flagged with an "Nl", the PBS was over the control limits. The samples were approved
since they were at least ten times the PBS value.
3. For the Isotopic Uranium values flagged with an "N1A", the sample had a very low tracer yield due to very high uranium
content. The peaks had very good shape so the data was flagged and accepted.
REPAD.03.06.05.01 Page 2 of 26
ACZ Laboratories, Inc. Inorganic Analytical
Results 2773 Downhill Drive Steamboat Springs. CO 80487 [phone]

Uranium Resources Inc. ACZ Sample ID: L94161-01
Project ID: KVD Pond Sediment Date Sampled: 04/19/12 11:30
Sample ID: POND SED DIGESTED Date Received: 04/20/12
Sample Matrix: Sediment
Inorganic Prep
Parameter
Total Hot Plate Digestion
Metals Analysis
M3010A ICP
111.1.11011•111101111M1
05/03/12 16:19 aeb
Paramete EPA Methocl Result Qual xo Units MDL POL Date Analyst
Arsenic (TCLP) M60108 ICP 0,57 mg/L 0.06 0.3 05/04/12 15:31 aeb
Barium (TCLP) M6010B ICP 0.109 mg/L 0.003 0.02 05/07/12 10:22 JJc
Cadmium (1CLP) M6010(3 ICP 0.008 mg/L 0.005 0.02 05/04/12 15:31 eel)
Chromium (TCLP) M60106 ICP • mg/L 0.01 0.05 05/04/12 15:31 aeb
Lead (TCLP) M6010B ICP mg/L 0.04 0.2 05/04/12 15:31 aeb
Mercury (TCLP) M7470CVAA • mg/L 0.0002 0.001 05/07/12 22:21 erf
Selenium (TCLP) M60106 ICP 0.08 mg/L 0.06 0,3 05/04/12 15:31 aeb
Silver (TCLP) M6010B ICP mg/L 0.01 0.03 05/04/12 15:31 aeb
Soil Analysis
Parameter EPA M hod Result Dual XO Units MDL PQL Dat
Solids, Percent CLPSOW390, PART F, 0-98 35.4 0.1 0.5 04/27/12 14:00 cra
Soil Preparation
Pa meter EPA Method Result Qual XO Units MEM POL Date Analyst
Air Dry at 34 Degrees USDA No. 1, 1972 04/25/12 10:00 cra
TCLP Metal Extraction M1311 04/26/12 19:40 ndi/bsu
REPIN.02.06 05 01 • Please refer to Qualifier Reports for details.
Page 3 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Inorganic
Reference

Rpport Header Explanations 11111111111111111111111111111111
Batch
Found
Limit
Lower
MDL
PCN/SCN
PQL
QC
Rec
RPD
tipper
Sarnple
A distinct set of samples analyzed at a specific time
Value of the QC Typo of interest
Upper limit for RPD, in %.
Lower Recovery Limit. in % (except for LCSS. mg/Kg)
Method Detection Limit. Same as Minimum Reporting Limit, Allows for instrument and annual fluctuations.
A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
Practical Quantitation Limit, typically 5 times the MDL.
True Value of the Control Sample or the amount added to the Spike
Amount of the true value or spike added recovered: in % (except for LCSS. mg/Kg)
Relative Percent Difference, calculation used for Duplicate QC Types
Upper Recovery Limit, in % (except for LOSS, mg/Kg)
Value of the Sample of interest
AS
ASD
GCB
CC V
DUP
/CB
/CV
ICSAB
LCSS
LCSSO
LCSW
Analytical Spike (Post Digestion)
Analytical Spike (Post Digestion) Duplicate
Continuing Calibration Blank
Continuing Calibration Verification standard
Sample Duplicate
Initial Calibration Blank
Initial Calibration Verification standard
inter-element Correction Standard - A plus B solutions
Laboratory Control Sample - Soil
Laboratory Control Sample • Soil Duplicate
Laboratory Control Sample - Water
LCSWD
LFB
LFM
LFMD
LRB
MS
MSD
PBS
PBW
PQV
SDL
Laboratory Control Sample - Water Duplicate
Lahoratory Fortified Blank
Laboratory Fortified Matrix
Laboratory Fortified Matrix Duplicate
Laboratory Reagent Blank
Matrix Spike
Matrix Spike Duplicate
Prep Blank - Soil
Prep Blank • Water
Practical Quantitation Verification standard
Serial Dilution
QC Sample Type Explanations
Blanks
Control Samples
Duplicates
Spikes/Fortified Matrix
Standard
Verifies that there is no or minimal contamination in the prep method or calibration procedure.
Verifies the accuracy of the method, including the prep procedure
Verifies the precision of the instrument and/or method.
Determines sample matrix interferences, if any.
Verifies the validity of the calibration.
ACZ Qualifiers (Qual)
Analyte concentration detected at a value between MDL and PQL. The associated value is an estimated quant ty
Analysis exceeded rnethod hold time, pH is a field test with an immediate hold time.
Target analyte response was below the laboratory defined negative threshold.
Ll The material was analyzed for, but was not detected above the level of the associated value
The associatod value is either the sample quantitation limit or the sample detection limit.
Method References 41111111111•1116
(1) EPA 600/4-83-020. Methods for Chemical Analysis of Water and Wastes, March 1993.
(2) EPA 600/R-93-100. Methods for the Determination of inorganic Substances in Environmental Samples, August 1993.
(3) EPA 600/R-94-111, Methods for the Determination of Metals in Environmental Samples - Supplement I, May 1994.
(4) EPA SW-846. Test Methods for Evaluating Solid Waste, Third Edition with Update III, December 1996,
(5) Standard Methods for the Examination of Water and Wastewater, 19th edition, 1995 & 20th ecittion (1998).
Comments
(1) QC results calculated from raw data. Results rnay vary slightly if the rounded values are used in the calculations.
(2) Soil, Sludge, and Plant matrices for Inorganic analyses are reported on a dry weight basis.
(3) Animal matrices for Inorganic analyses are reported on an "as received" basis.
(4) An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification qualifier
associated with the result.
For a complete list of ACZ's Extended Qualifiers: Please click: bilp://www, z.conVpublierextou Istjkif
REP1N11.10.10,01r Page 4 of 26
• • ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Inorganic QC
Summary

Uranium Resources inc. ACZ Project ID: L94161
Project ID: KVD Pond Sediment
Arsenic (TCLP) M6010B ICP
WG322177
WG3221771CV !CV 05/04/12 14:51 11120430-5 4 4.037 mg/L 100.9 90 110
WG3221771C8 ICB 05/04/12 14:54 U mg/L -0.18 0.18
W0321499P8S PBS 05/04/12 15:06 U mg/L -0.18 0.18
WG3214991.FB LFB 0504/12 1509 IITCLPSPIK 1 1.096 mg/L 109.6 85 115
WG321726P8S PBS 05/04/12 15:25 U mg/L -0.18 0.18
WG321726LFB LFB 05/04/12 15:28 1ITCLPSP IK 1 1.102 rng/L 110.2 85 115
L94161.01MS MS 05/04/12 15:35 IITCLPSPIK 1 .57 1.684 rng/L 111.4 75 125
L94161.01MSD MSD 05/04/12 15:44 IITCLPSPIK 1 .57 1.728 rng/L. 115.8 75 125 2.58 20
L94161 01DUP DUP 05/04/12 15:48 .57 .536 mg/I. 6.1 20 RA
WG321891P8S PBS 05/04112 16:04 U mg/L -0.18 0.18
W0321891 LFB LFB 05/04/12 16:07 IITCLPSPIK 1 1.073 rng/L 107.3 85 115
Barium (TCLP) M60106 ICP
WG322216
W03222161CV ICV 05/07/12 10:00 11120430-5 2 1.955 mg/L 97.8 90 110
WG3222161GB ICB 05/07/12 10:03 U mg/L -0.009 0.009
WG321726PBS PBS 05/07/12 10:16 .0073 mg1L. -0.009 0.009
WG321726LF3 LFB 05/07/12 10:19 IITCLPSPIK 20.5 19.27 mg/L 94 85 115
L94161-01MS MS 05/07/12 10:25 IITCLPSPIK 20,5 .109 4.052 mg/L 19.2 75 125 M2
L94161-01MSD MS0 05/07/12 10:29 11TCLPSPIK 20.5 _109 3.331 mgA. 15.7 75 125 19.53 20 M2
L.94181-01OUP DUP 05/07/12 10:32 .109 .1133 mg/L 3.9 20
Cadmium (TCLP) M6010B ICP
ACZ ID Type Analyzed PCN.SCN OC Sarnp e Found Units Rec Lower Upper RFD Llmil Oual
WG322177
WG3221771CV ICV 05/04/12 14:51 11120430-5 2 1.9 mgil. 95 90 110
WG3221771C8 1CB 05/04/12 14:54 U mg/L -0.015 0.015
WG321499P135 PBS 05/04/12 15:06 U rng/L -0.015 0.015
WG321499LF8 LFB 05/04/12 15:09 IITCLPSPIK .5 .5099 mg/ 102 85 115
WG321726PBS PBS 05/04/12 15:25 U mg/L -0.015 0.015
WG321726LFB LFB 05/04/12 15:28 IITCLPSPIK .5 .511 rng/L 102,2 as 115
L94161-01MS MS 05/04/12 15:35 IITCLPSPIK .5 .01 .4954 mg/L 97.5 75 125
L94161-01MSD MSD 05/04/12 15:44 IITCLPSPIK .5 .01 .4957 mg/L 97.5 75 125 0.06 20
L94161-01DUP DUP 05/04/12 15:48 .01 .0091 mg/L 12,9 20 RA ZG
WG321891PBS PBS 05/04/12 16:04 U mg/L -0.015 0.015
WG321891LFB LFB 05/04/12 16:07 11TCLPSPIK .5 ,4999 mg/L 100 85 115
REPIN.01.06.05.01 Page 5 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Uranium Resources Inc. ACZ Project ID: L94161
Project ID: KVD Pond Sediment
Chromium (TCLP) M60108 ICP
ACZ ID Analyzed PCN, CN OC Sample Found Units Roc Loeer Upper RPD Umit Qua!
WG322177
W63221771CV ICV 05/04/12 14:51 11120430-5 2 1.946 mg/L 97 3 90 110
W6322177ICB ICB 05/04/12 14:54 U mg/L .0.03 0.03
WG321499P135 PBS 05/04/12 15:06 U mg/ -0.03 0.03
WG321499LF9 LFB 05/04/12 15:09 IITCLPSPIK .5 .511 mg/ 102.2 85 115
WG321726P8S PBS 05/04/12 15:25 U mg/L -0.03 0.03
WG321726LF8 L FB 05/04/12 15:28 IITCLPSPIK .5 .515 mg/L 103 85 115
L94161-01MS MS 05/04/12 15:35 IITCLPSPIK .5 U .505 nig/ 101 75 125
L94161-01MSD MSD 05/04/12 15:44 IITCLPSPIK .5 U 508 mg/L 101.6 75 125 0 59 20
L94161-01DUP DUP 05/04/12 15.48 U U mg/L 0 20 RA
WG321891PBS PBS 05/04/12 16:04 U rrigt -0.03 0.03
WG32189 I LFB LFB 05/04/12 16:07 IITCLPSPIK .5 .505 mg/L 101 85 115
Lead (TCLP) M60108 ICP
ACZID Type An3lyzed PCN SCN OC Sarnple Found Unils Rec Low r Upper Flpt Quel
WG322177
WG3221771CV ICV 05/04/12 14:51 11120430-5 4 3.911 mg/L 97.8 90 110
WG322177ICB 1CB 05/04/12 14:54 U mg/ -0.12 0.12
WG321499PB5 PBS 05/04/12 15:06 U mg/L. -0.12 0.12
WG321499LFB LFB 05/04/12 15:09 IITCLPSPIK l 1.047 mg/L 104.7 85 115
WG321726PBS PBS 05/04/12 15:25 U mg/L -0.12 0.12
WG321726LFB LFB 05/04/12 15:28 IITCLPSPIK 1 1.054 mg/L 105.4 85 115
L94161-01MS MS 05/04/12 15:35 IITCLPSPIK 1 U .995 mg/L 99.5 75 125
L94161.01MSD MSD 05/04/12 15:44 IITCLPSPIK 1 U 991 mg/L 99,1 75 125 0.4 20
L94161-01DUP DUP 05/04/12 15:48 U U mg/L 0 20 RA
WG321891PBS PBS 05/04/12 16:04 U rng/L -0.12 0.12
WG321891LFB LFB 05/04/12 16:07 IITCLPSPIK 1 1.022 mg/L 102.2 85 115
Mercury (TCLP) M7470CVAA
A Z ID Type Analyzed PCISCN QC Sam te Fou d Units Rec Lower Upper F1PD Limit Oual
WG322251
W03222511CV CV 05/07/12 20:37 11120425-5 .005015 .00521 mg/L. 103.9 90 110
WG3222511CB ICS 05/07/12 20:40 U mg/L -0 0006 0.0006
WG322128
WG322128P8W PBW 05/07/12 22:00 U mg/L -0.00044 0.00044
WG321499LFB LFB 05/07/12 22:04 11120507-5 .002002 ,00201 rng/L 100.4 85 115
WG321726P8S PBS 05/07/12 22:17 U mg/Kg .0.0006 0.0006
WG321726LF8 LFB 05/07/12 22:19 11120507-5 02002 .00194 rngll. 96.9 85 115
L94161-01MS MS 05/07/12 22:29 11120507-5 .002002 U .0019 mg/l 94.9 85 115
L94161-01MSD MSD 05/07/12 22:31 11120507-5 .002002 U .00176 mg/L 87.9 85 115 7.65 20
L94161-01DUP DUP 05/07/12 22:33 U U mg/L 0 20 F1A
WG321891LF13 LFB 05/07/12 22:58 11120507-5 .002002 .00203 m9/1. 101.4 85 115
REPIN.01 06.05.01 Page 6 of 26
• ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Spangs, CO 80487 [phone]

Inorganic QC
Summary

Uranium Resources Inc. ACZ Project ID: L94161
Project ID: KVD Pond Sedirnent
Selenium (TCLP) M60108 ICP
ACZ ID Trpe Andlyzed PCN SCINI QC Sample Found Units Rec Lower Upper RP!) Limit Qua
WG322177
WG322177ICV ICV 05/04/12 14:51 11120430-5 4 3.956 mg/L 98.9 90 110
WG322177ICB ICB 05/04/12 14:54 U mg/L -0.18 0.18
WG321499PBS PBS 05/04/12 15:06 U mg/L -0.18 0.18
WG321499LFB LFB 05/04/12 15:09 IITCLPSPIK 1 1.08 mg/L 108 85 115
WG321726PBS PBS 05/04/12 1525 U rngt -0.18 0.18
WG321726LFB LFB 05/04/12 15:28 IITCLPSPIK 1 1.089 mg/L 108.9 85 115
L94161-01MS MS 05/04/12 15:35 IITCLPSPIK 1 .08 1 122 mg/L 104.2 75 125
L94161-01MSD MSD 05/04/12 15:44 IITCLPSPIK 1 .08 1.161 mg/L 108.1 75 125 3.42 20
L94161-01DUP DUP 05/04/12 15:48 .08 U mg/L 200 20 RA
WG321891PBS PBS 05/04/12 16:04 U mg/L -0.18 0.18
WG321891LFB LFB 05/04/12 16:07 IITCLPSPIK 1 1.057 mg/L 105.7 85 115
Sliver (TCLP) M60108 ICP
ACZ ID Type Anlyzed PG1iŠCN QC Sampte Found Units Ûac Lowrl Uppar RFT) it dual
WG322177
WG3221771CV ICV 05/04/12 14;51 11120430-5 1.003 .971 mg/L 96.8 90 110
WG322177ICB ICB 05/04/12 14.54 U mg/L -0.03 0.03
W0321499PBS PBS 05/04/12 15:06 U mg/L -0.03 0.03
WG321499LFB LFB 05/04/12 15:09 IITCLPSPIK .5 .473 mg/L 94.6 85 115
WG321726P8S PBS 05/04/12 15:25 U mg/L -0.03 0.03
WG321726LF8 LFB 05/04/12 15:28 11TCLPSPIK .5 .473 mg/L 94.6 85 115
L94161-01MS MS 05/04/12 15:35 IITCLPSPIK .5 U .486 mg/L 97.2 75 125
L94161-01MSD MSD 05/04/12 15:44 IITCLPSPIK .5 U .495 mg/L 99 75 125 1.83 20
L94161-01DUP DUP 05/04/12 15:48 U U mg/t. 0 20 RA
WG321891P8S PBS 05/04/12 16:04 U mg/L -0.03 0.03
WG321891LFB LFB 05/04/12 16:07 IITCLPSPIK .5 .469 mg/L 93.8 85 115
Solids, Percent CLPSOW390, PART F. D-98
ACZ ID Type Analyzed CNISCN mple Found Units Roc Lower Upper RPD Liil Qual
WG321771
WG321771PBS PBS 04/27/12 9:15 99.9 100.1
L94225-01DUP DUP 04/27/12 21:07 95 94.82 % 02 20
REPIN.01.06.05 01 Page 7 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs. CO 80487 [phone]

Inorganic Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: 1_94161

ACZ IO WORKNtJM PARAMETER METHOD CNA DESCRIPTION
RA Relative Percent Difference (11PD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL),
M2 Matrix spike recovery was low, the recovery of the
associated control sample (LCS or LF13) was acceptable.
RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
ZG The ICP Serial Dilution was not used for data validation
because the sarnple concentration was less than 50 times
the MOL.
RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL),
RA Relative Percent Difference (RPD) was not used for data validation because the sample concentration is too low for
accurate evaluation (< 10x MOL),
RA Relative Percent Difference (RPO) was not used for data validation because the sample concentration is too IOW for accurate evaluation (< I Ox MOL).
RA Relative Percent Difference (RPD) was not used for data validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for accurate evaluation (< 10x MDL).
L94161-01 WG322177 Arsenic (-MLR) M60108 CP
WG322216 Barium (TCLP) M6010B ICP
WG322177 Cadmium (TCLP) M601013 ICP
M60108 ICP
Chromkim (TCLP) M601013 ICP
Lead (TCLP) M601013 ICP
WG322128 Mercury (TCLP) M7470CVAA
WG322177 Selenium (TCLP) M60108 1CP
Silver (TCLP) M60108 ICP
REPAD.15.06.05.01
Page 8 of 26
• ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic Analytic I
Results

Uranium Resources Inc. ACZ Sample ID: L94161-01
Project ID: KVD Pond Sediment Date Sampled: 04/19/12 11:30
Sample ID: POND SED DIGESTED Date Received: 04/20/12
Sample Matrix: Sediment
Base Neutral Acid Extractables by GC/MS
Analysis Method: M8270C GC/MS
Extract Method: M3540
Work rou : WG322392
Analyst: itk
Extract Date: 05/07/12 20:39
Analysis Date: 05/09/12 22:30
Compound CAS Result QUAL Mt MCIL
1.2,4-Trichlombenzene 120-82-1 UN 1000 • ug/Kg 2000 10000
1,2-Dichlorobenzene 95-50-1 UH 1000 • ug/Kg 2000 10000
1.3-Dichlorobenzene 541-73-1 UH 1000 * ug/Kg 2000 10000
1,4-Dichlorobenzene 106-46-7 UH 1000 * ug/Kg 2000 10000
2,4,5-Trichlorophenol 95-95-4 UH 1000 • ug/Kg 10000 50000
2,4,6-Trichlorophenol 88-06-2 UH 1000 * ug/Kg 2000 10000
2,4-Dichlorophenol 120-83-2 UH 1000 * ug/Kg 2000 10000
2,4-Dimethylphenol 105-67-9 UH 1000 * ug/Kg 4000 20000
2,4-Dinitrophenol 51-28-5 UH 1000 ug/Kg 20000 50000
2,4-Dinitrotoluone 121-14-2 UH 1000 * ug/Kg 2000 10000
2,6-Dinitrotoluene 606-20-8 UN 1000 * ug/Kg 10000 50000
2-Chloronaphthalene 91-58-7 UN 1000 * ug/Kg 2000 10000
2-Chlorophenol 95-57-8 UN 1000 ug/Kg 2000 10000
2-Methylnaphthalene 91-57-6 UH 1000 * ug/Kg 2000 10000
2-Methylphenol 95-48-7 UH 1000 * ug/Kg 2000 10000
2-Nitroaniline 88-74-4 UH 1000 ug/Kg 10000 50000
2-Nitrophenol 88-75-5 UH 1000 ug/Kg 4000 20000
3- & 4-Methylphenol 1319-77-3 UH 1000 • ug/Kg 4000 20000
3,3-Dichlorobenzidine 91-94-1 UH 1000 * ug/Kg 20000 50000
3-Nitroaniline 99-09-2 UN 1000 • ug/Kg 10000 50000
4,6-Dinitro-2-methylphenol 534-52-1 UN 1000 • ug/Kg 10000 50000
4-Bromophenyl phenyl ether 101-55-3 UH 1000 * ug/Kg 2000 10000
4-Chloro-3-methylphenol 59-50-7 UN 1000 * ug/Kg 2000 10000
4-Chloroaniline 106-47-8 UN 1000 ug/Kg 2000 10000
4-Chlorophenyl phenyl ether 7005-72-3 UN 1000 * ug/Kg 2000 10000
4-Nitroaniline 100-01-6 UH 1000 • ug/Kg 10000 50000
4-Nitrophenol 100-02-07 UH 1000 • ug/Kg 10000 50000
Acenaphthene 83-32-9 UH 1000 ug/Kg 2000 10000
Acenaphthylene 208-96-8 UH 1000 * ug/Kg 2000 10000
Aniline 62-53-3 UH 1000 ug/Kg 10000 50000
Anthracene 120-12-7 UH 1000 * ug/Kg 2000 10000
Azobenzene 103-33-3 UH 1000 * ug/Kg 10000 50000
Benzo(a)anthracene 56-55-3 UH 1000 ug/Kg 2000 10000
Benzo(a)pyrene 50-32-8 UH 1000 * ug/Kg 2000 10000
Benzo(b)fluoranthene 205-99-2 UH 1000 ug/Kg 2000 10000
Benzo(g,h,i)perylene 191-24-2 UH 1000 * ug/Kg 2000 10000
Benzo(k)fluoranthene 207-08-9 UH 1000 ug/Kg 2000 10000
Benzoic acid 65-85-0 UH 1000 • ug/Kg 20000 50000
REPOR.01.01.01.02 ' Please refer to Oualiller Reports for details.
Page 9 of 26
Laboratories, Inc. Organic Analyrcal
Results 2773 Downhill Dnve Steamboat Springs. CO 80487 [phone]

Uranium Resources Inc. ACZ Sample ID: L94161-01
Project ID: KVD Pond Sediment Date Sampled: 04/19/12 11:30
Sample ID: POND SED DIGESTED Date Received: 04/20/12
Sample lvtatrix: Sediment
Benzyl alcohol 100-51-6 UH 1000 ug/Kg 2000 10000
Bis(2-chloroethoxy)methane 111-91-1 UH 1000 ug/Kg 2000 10000
Bis(2-chloroethyl) ether 111-44-4 UH 1000 ug/Kg 2000 10000
Bis(2-chloroisopropyl) ether 108-60-1 UH 1000 ug/Kg 2000 10000
Bis(2-ethylhexyl) phthalate 117-81-7 UH 1000 • ug/Kg 4000 20000
Butyl benzyl phthalate 85-68-7 UH 1000 ug/Kg 2000 10000
Chrysene 218-01-9 UH 1000 • ug/Kg 2000 10000
Dibenzo(a,h)anthracene 53-70-3 UH 1000 • ug/Kg 2000 10000
Dibenzoturan 132-64-9 UH 1000 ug/Kg 2000 10000
Diethylphthalate 84-66-2 UH 1000 • ug/Kg 2000 10000
Dimethyl phthalate 131-11-3 UH 1000 ug/Kg 2000 10000
Di-n-butyl phthalate 84-74-2 UH 1000 ug/Kg 2000 10000
Di-n-octyl phthalate 117-84-0 UH 1000 • ug/Kg 2000 10000
Fluoranthene 206-44-0 UH 1000 • ug/Kg 2000 10000
Fluorene 86-73-7 UH 1000 ug/Kg 2000 10000
Hexachlorobenzene 118-74-1 UH 1000 * ug/Kg 2000 10000
Hexachlorobutadiene 87-68-3 UH 1000 * ug/Kg 2000 10000
Hexachlorocyclopentadiene 77-47-4 UH 1000 ug/Kg 2000 10000
Hexachloroethane 67-72-1 UH 1000 • ug/Kg 2000 10000
lndeno(1 .2,3-cd)pyrene 193-39-5 UH 1000 ug/Kg 2000 10000
lsophorone 78-59-1 UH 1000 * ug/Kg 2000 10000
Naphthalene 91-20-3 UH 1000 ug/Kg 2000 10000
Nitrobenzene 98-95-3 UH 1000 • ug/Kg 2000 10000
N-Nitrosodimethylamine 62-75-9 UH 1000 • ug/Kg 10000 50000
N-Nitrosodi-n-propylamine 621-64-7 UH 1000 ug/Kg 2000 10000
N-Nitrosodiphenylamine 86-30-6 UH 1000 ug/Kg 2000 10000
Pentachlorophenol 87-86-5 UH 1000 * ug/Kg 10000 50000
Phenanthrene 85-01-8 UH 1000 • ug/Kg 2000 10000
Phenol 108-95-2 UH 1000 ug/Kg 4000 20000
Pyrene 129-00-0 UH 1000 * ug/Kg 2000 10000
SutTogate Recoveries CAS % Recovery Dilution X0 Units LCL UCL
2,4,6-Tribromophenol 118-79-6 91.7 1000 35 125
2-Fluorobiphenyl 321-60-8 86 1000 45 105
2-Fluorophenol 367-12-4 77.9 1000 35 105
Nitrobenzene-d5 4165-60-0 82.5 1000 It 35 100
Phenol-d6 13127-88-3 79.4 1000 40 100
Terphenyl-dl 4 1718-51-0 104.6 1000 30 125
REPOR.01.01.01.02 " Please refer to Qualifier Reports for details.
Page 10 of 26
Laboratories, Inc.
2773 Downhill Drive Steamboat Smogs, CO 80487 [phone]
Organic
Reference

. • RepOft Header Explanations '-'11111111111111111111•11
Ba(ch
Found
Limit
Lower
LCL
MDL
PCN/SCN
PQL
QC
Rec
RPD
Upper
UCL
Sample
A distinct set of samples analyzed at a spe,cific time
Value of tho QC Typo of interest
Upper limit for RPD, in %.
Lower Recovery Limit, in % (except for LCSS, Ing/K9)
Lower Control Limit
Method Detection Limit. Same as fvlinimurn Reporting Limit Allows for instrument and annual fluctuations
A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
Practical Ouarititation Lirnit, typically 5 times the MDL
True Value of the Control Sample or the amount added to the Spike
Amount of the true value or spike added recovered, in % (except for LCSS, mg/Kg)
Relative Percent Difference, calculation used for Duplicate QC Types
Upper Recovery LimiL in % (except for LCSS, mg/Kg)
Upper Control Limit
Value of the Sample of interest
QC sampto TyPes
SURR
INTS
(.:iUP
LCSS
LCSW
LFB
Surrogate
Internal Standard
Sample Duplicate
Laboratory Control Sample Soil
Laboratory Control Sample - Water
Laboratory Fortified Blank
I FM
LFMD
LRB
USIMSD
PBS
PBW
Laboratory Fortified Matrix
Laboratory Fortified Matrix Duplicate
Laboratory Reagent Blank
Matrix Spike/Matrix Spike Duplicate
Prep Blank Soil
Prep Blank Water
Explanations
Blanks Verifies that there is no or minimal contamination in the prep method or calibration procedure.
Control Samples Verifies the accuracy of the method, including the prep procedure_
Duplicates Venfies the precision of tho instrument and/or methoe.
Spikes/Fortified Matrix Determines sample matrix interf erencos, if any.
ACZ Qualifiers (Qua!
• Analyte concentration detected at a value between MDL and PQL The associated value is an estimated quantity.
• Analyte concentration is estimated due to result exceeding calibration range.
• Analysis exceeded method hold tirne pH is a field test with an irnmediate hold time,
Analyie concentration detected at a value between MDL and PQL. The associated value is an estimated quantity.
I argot analyte response was below the laboratory defined negative threshold.
• Poor spike recovery is accepted because sample concentration is four times greater than spike concentration
• Analyte concentration differs from second detector by more than 40%
• Poor spike recovery accepted because the other spike in the set full witnin the given limits.
• High Relative Percent Difference (RPD) accepted because sample concentrations are less than 10x tho MDL.
• The material was analyzed for, but was not detected above the level of the associated value.
The associated value is either the sample quantitation Srnit or the aample detection limit.
✓ High blank data accepted because sample concentration is 10 tirnes higher than blank concentration
• Quality control sample is out of control.
• Poor spike recovery is accepted because sample concentration is four times greater than spike concentration.
(1) EPA 600/4-83-020. Methods for Chemical Analysts of Water and Wastes, March 1963.
(2) EPA 600/4-90/020. Methods for the Determination of Organic Compounds in Drinking Water (I), July 1990,
(3) EPA 600/R-92/129. Methods tor the Determination of Organic Compounds in Drinking Water (II), July 1990.
(4) EPA SW-846, Test Methods for Evaluating Solid Waste, Third Edition with Update III, December 1996.
(5) Standard Methods for the Examination of Water and Wastewater, 19th edition, 1995 & 20th edition (1998).
Comments
(1) QC results calculated from raw data. Results may vary slightly if the rounded yam are used in the calculations
(2) Soli. Sludge, and Plant matrices for Inorganic analyses are reported on a dry weight basis
(3) An asterisk in the ''Xa column indicates there is an extended qualifier and/or certification qualifier
asiociated with the result.
For a complete list of ACZ's Extended Qualifiers, please click: Intp:// x Nue pd
REPIN11 Page 11 of 26
1357 ug/Kg 81.4 45 110
1244 ug/Kg 74.6 35 105
1400 ug/Kg 84.0 50 115
2037 ug/Kg 81.5 45 105
1,2,4-TR1CHLOROBENZENE 1666,7
1,4-DICHLOROBENZENE 1666.7
2,4-DINITROTOLUENE 1666.7
2-CHLOROPHENOL 2500.7
ACZ Laboratories, Inc.

Organic OC
Summary 2773 Downhill Drive Steamboat Springs, CO 80487 (800) 334-5,193

Uranium Resources Inc.
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
Base Neutral Acid Extractables by GC/MS M8270C GC/MS
WG322392
MS Sample 10: 194060-06MS PCN/SCN: BNA120227-2-30 Analyzed: 05/09/12 19:54
1,2,4•TRICHLOROBENZENE 1666.7 1275 t104<9 76.5 45 110
1,4 DICHLOROBENZENE 1666.7 1209 ug/Kg 72.5 35 105
2,4-DIN1TROTOLUENE 1666.7 1331 ug/Kg 79.9 50 115
2-CHLOROPHENOL 2500.7 1997 ug/Kg 79.9 45 105
4-CHLOR0-3-METHYLPHENOL 2500.3 2057 ug/Kg 82.3 45 115
4-NITROPHENOL 2500.7 2170 ug/Kg 86,8 15 140
ACENAPHTHENE 1666.7 1266 ug/Kg 76.0 45 110
N-NITROSODI-N PROPYLAMINE 1666.7 1316 ug/Kg 79.0 40 115
PENTACHLOROPHENOL 2500 1780 ug/Kg 71.2 25 120
PHENOL 2500 2000 ug/Kg 80.0 40 100
PYRENE 1666.7 1551 ug/Kg 93.1 45 125
2,4.6.•TRIBROMOPHENOL (surf) 74.3 35 125
2-FLUOROBIPHENYL (surr) 92.7 45 105
2-FLUOROPHENOL (surr) 84.4 35 105
NITROBENZENE-05 (surr) 91 0 35 100
PHENOL-06 (surr) 84.2 40 100
TERPHENYL-014 (surr) 106.0 30 125
MSD Sample ID: L94060-06MSD PCN/SCN: NA120227-2-30 Analyzed: 05/09/12 20:25
COMpound OC Sample Found Units Res Lower Upper FWD Limn Oual
1,2,4-TRICHLOROBENZENE 1666,7 1122 ug/Kg 67,3 45 110 12.77 20
1,4 -DICHLOROBENZENE 1666.7 977 ug/Kg 58.6 35 105 21.23 20 R4
2,4-DIN1TROTOLUENE 1666.7 1345 ug/Kg 80.7 50 115 1.05 20
2-CHLOROPHENOL 2500.7 1720 ug/Kg 68.8 45 105 14.9 20
4-CHLOR0-3-METHYLPHENOL 2500,3 1909 ug/Kg 76.3 45 115 7.46 20
4-NITROPHENOL 2500.7 2240 ug/Kg 89.6 15 140 3.17 20
ACENAPHTHENE 1666.7 1153 ug/Kg 59.2 45 110 9.34 20
N-NITROSODI-N-PROPYLAMINE 1666.7 1144 trg/Kg 68.6 40 115 13.98 20
PEN1ACHLOROPHENOL 2500 1920 ug/Kg 76.8 25 120 7.57 20
PHENOL 2500 1770 ug/Kg 70.8 40 100 12.2 20
PYRENE 1666.7 1566 lig/Kg 94.0 45 125 0.96 20
2,4,6-TRIBROMOPHENOL (surr) 77.8 35 125
2-FLUOROBIPHENYL (surr) 81.2 45 105
2-FLUOROPHENOL (surr) 71.3 35 105
NITROBENZENE-05 (surr) 78.4 35 100
PHENOL-D6 (surr) 74.6 40 100
TERPHENYL-014 (sun.) 106.1 30 125
LCSS Sample ID: WG322266LCSS PCN/SCN: BNA120227-2-30 Analyzed: 05/09/12 16:46

Compound OC Sample Found Units Res I.owes Upper RPD Limn Ouel
REPOR.01.06.05.01
Page 12 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Spnngs, CC) 80487 [phone]
Organic QC
Summary

Uranium Resources Inc.
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
101.1=MMINIMIN
4-CHL OR0-3-METHYLPHENOL 2500.3
4-NITROPHENOL 2500.7
ACE NAPHTH EN E 1666.7
N-NITROSODI-N-PROPYLAMINE 1666.7
PENTACHLOROPHENOL 2500
PHENOL 2500
PYR EN E 1666.7
2,4,6•TRIBROMOPHENOL (surr)
2-FLUOROB IP HE NYL (surr)
2-FLUOROPHENOL (surr)
NITROBENZENE-DS (surr)
PHENOL-D6 (surr)
TERPHENYL.D14 (surr)
2199 ugiltg 87.9
2260 ug/Kg 90.4
1342 ug/Kg 80.5
1361 ugrKg 81.7
2020 ugiKg 80.8
2050 ug/Kg 82.0
1631 ug/Kg 97.9
% 87.3
% 98.8
% 86.0
% 95.4
% 87.3
% 111.2
45
15
45
40
25
40
45
35
45
35
35
40
30
115
140
110
115
120
100
125
125
105
105
100
100
125
Analyzed: 05/09/12 17:17 LCSSD Sample ID: WG322266LCSSD PCN/SCN: BNA120227-2-30
Compound QC Sample P0111 RPD
1.2.4-7RICHLOROBENZENE 1666.7
1,4 D IC HLOROBENZENE 1666.7
2.4 -DIN ITROTOLUENE 1666.7
2-C HLOROPHENOL 2500.7
4-CHLOR0-3-METHYLPHENOL 2500.3
4-N ITROPHENOL 2500.7
ACENAPHTHENE 1666.7
N-NITROSODI-N-PROPYLAMINE 1666 7
PENTACHLOROPHENOL 2500
PHENOL 2500
PYRENE 1666.7
24,6-TRIBROMOPHENOL (surr)
2-FLUOROBIPHENYL (surr)
2-FLUOROPHENOL (surr)
NITROBENZENE-D5 (surr)
PHENOL-06 (surr)
TERPHENYL-014 (surr)
1268 ug/Kg 76.1
1183 ug/Kg 71.0
1380 ug/Kg 82.8
1924 ug/Kg 76.9
1970 ug/Kg 78.8
2200 ug/Kg 88.0
1278 ugh(g 76.7
1292 ug/Kg 77.5
2010 ug/Kg 80.4
1920 ug/Kg 76.8
1627 ug/Kg 97.6
81.9
90.9
80.0
89.2
81.1
108.6
45
35
50
45
45
15
45
40
25
40
45
35
45
35
35
40
30
110 6.8
105 5
115 1 .4
105 5.7
115 11
140 2.7
110 4.9
115 5.2
120 0.5
100 6.5
125 0.2
125
105
105
100
100
125
20
20
20
20
20
20
20
20
20
20
20
PBS Sample ID: WG322266PB5 Analyzed: 05/09/12 6:14
Compound QC Sample Found Units Lower Upper R umš.,
1,2.4-TRICHLOROBENZENE ug/Kg -300 300
1.2-DICHLOROBENZENE ug/Kg -300 300
1.3.DICHLOROBENZENE ug/Kg -300 300
1,4.DICHLOROBENZENE ug/Kg -300 300
2,4.5-TR ICHLOROPHENOL ug/Kg .2000 2000
24,6.TRICHLOROPHENOL ug/Kg -300 300
2,4 -DICHLOROPHENOL ug/Kg -300 300
2,4-DIMETHYLPHENOL ug/Kg -700 700
2.4-DINITROPHENOL ug/Kg -2000 2000
2,4-DINITROTOLUENE ug/Kg -300 300
2,6-DINITROTOLUENE ug/Kg -2000 2000
2-CHLORONAPHTHAL ENE ug/Kg -300 300
2.CHLOROPHENOL ug/Kg -300 300
REPOR.01 06.05.01
Page 13 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 (800) 334-5-193

Organic OC
Summary

Uranium Resources Inc.
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
2-METHYLNAPHTHALENE u ug/Kg -300 300
2-METHYLPHENOL u ucyKg -300 300
2-NITROANILINE U ug/Kg -2000 2000
2-NI TROPHENOL u ug/Kg -700 700
3- & 4-METHYLPHENOL u ug/Kg -700 700
3,3-DICHLOROBENZIDINE U ug/Kg -2000 2000
3-NITROANILINE u ug/Kg -2000 2000
4,6-DINITRO-2-METHYLPHENOL u ug/Kg -2000 2000
4-BROMOPHENYL PHENYL ETHER U ug/Kg -300 300
4-CHLORO-3-METHYLPHENOL U ug/Kg -300 300
4-CHLOROANILJNE U ug/Kg -300 300
4-CHLOROPHENYL PHENYL ETHER Li ug/Kg -300 300
4-NITROANILINE U ug/Kg .2000 2000
4-NITROPHENOL u ug/Kg -2000 2000
ACENAPHTHENE U ug/Kg -300 300
ACENAPHTHYLENE U ug/Kg -300 300
ANILINE U ug/Kg -2000 2000
AN THRACENE u ug/Kg -300 300
AZOBENZENE u ug/Kg -2000 2000
BENZO(A)ANTHRACENE U ug/Kg -300 300
BENZO(A)PYRENE U ug/Kg -300 300
BENZO(B)FLUORANTHENE u ug/Kg -300 300
BENZO(G.H,I)PERYLENE u ug/Kg -300 300
BENZO(K)FLUORANTHENE u ug/Kg -300 300
BENZOIC ACID u ug/Kg -2000 2000
BENZYL ALCOHOL u ug/Kg -300 300
BIS(2-CHLOROETHOXY)METHANE U ug/Kg -300 300
BIS(2-CHLOROETHYL) ETHER U ug/Kg -300 300
BIS(2-CHLOROISOPROPYL) ETHER u ug/Kg -300 300
BIS(2-ETHYLHEXYL) PHTHALATE U ug/Kg -700 700
BUTYL BENZYL PHTHALATE U ug/Kg -300 300
CHRYSENE u ug/Kg -300 300
DIBENZO(A,H)ANTHRACENE u ug/Kg -300 300
DIBENZOFURAN U ug/Kg -300 300
DIETHYLPHTHALATE u ug/Kg -300 300
DIMETHYL PHTHALATE u ug/Kg -300 300
01-N-BUTYL PHTHALATE U ug/Kg -390 300
DI-N-OCTYL PHTHALATE u ug/Kg -300 300
FLUORANTHENE u ugIKg -300 300
FLUORENE u ug/Kg -300 300
HEXACHLOROBENZENE u ug/Kg -300 300
HEXACHLOROBUTADIENE u ug/Kg -300 300
HEXACHLOROCYCLOPENTADIENE u ug/Kg -300 300
HEXACHLOROETHANE u uriKg -300 300
INDENO(1,2,3-CD)PYRENE u ug/Kg -300 300
ISOPHORONE U ug/Kg -300 300
NAPHTHALENE u ug/Kg -300 300
NITROBENZENE u ugfKg -300 300
N-NITROSODIMETHYLAMINE u ug/Kg -2000 2000
REPOR.01.06.05.01
Page 14 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 (800) 93
Organic OC
Sumrnary

Uranium Resources Inc.
Project ID: KVD Pond Sediment
ACZ Project ID: L94151
N-NITROSODI-N-PROPYLAMINE U ug/Kg -300 300
N-NITROSODIPHENYLAMINE U ug/Kg -300 300
PENTACHLOROPHENOL U ug/Kg -2000 2000
PHENANTHRENE U ug/Kg -300 300
PHENOL U ug/Kg - 700 700
PYRENE U ug/Kg .300 300
2,0-TRIBROMOPHENOL (surr) % 66.9 35 125
2-FLUOROBIPHENYL (surr) % 79.1 45 105
2-FLUOROPHENOL (surr) % 72.5 35 105
NITROBENZENE-135 (surr) % 81.0 35 100
PHENOL-D6 (surr) % 73.0 40 100
TERPHENYL-D14 (surr) % 91,9 30 125
REPOR.01.06.05.01
Page 15 of 26
/CZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Organic Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: L94161

ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION
L94161-01 WG322392 'All Compounds*
1,4-0ichlorobenzono
WG321596 'All Compounds'
WG322266
M8270C GC/MS
M8270C GC/MS
M8270C GOMS
M8270C GC/MS
M3540
M3540
M3540
01 Sarnple required dilution due to matrix.
HC Initial analysis within holding time. Reanalysis was past
holding time, which was required due to a OC failure during
the initial analysis.
NI See Case Narrative
R4 RP!) tor a spike and spike duplicate exceeded the method
or laboratory acceptance limit. At a minimum, one spike
recovery met acceptance criteria.
DI Sarnple reguked dilution due to matrix.
01 Sample required dilution due to matrix.
HC Initial analysis within holding time. Reanalysis was past
holding time, which was required due to a QC failure during
the initial analysis.
REPAD.15,06.05.01
Page 16 of 26
pCi/g 40 12 100
Radium 226 Alpha Emitting Radium Isotopes (3050)
M9315
Prep Method:
UnIte xo Anatyst Parameter P/leasure Date Result Error(+/-) LLD Prep Date
Radium 226 + Alpha 05 08/12 13:46 0.19 0.6 3.3 r:Ci/9 zsh
Thorium, Isotopic (3050)
ESM 4506
Prep Method:
Parameter Measure Date Prep Date Result Error(+!-) LLD Units XO Analyst
Uranium, Isotopic (3050)
Eichrom ACWO3
Prep Method:
• Please refer to Qualifier Reports for details. REPRC 02.06.05,01
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs. CO 80487 [phone]
Uranium Resources Inc.
Project ID: KVD Pond Sediment
Sample ID: POND SED DIGESTED
Locator:
RadioChemistry
Analytical Results
ACZ Sample ID: L94161-01
Date Sampled: 04/19/1211:30
Date Received: 0412011 2
Sample Matrix: Sediment
Lead 210 (3050)
Eichrom
Parameter Measure Date
Lead 210 (3050) 05/07/12 16:34
Prep Method:
Prep Date Result Error(+;-) LLD Units XO Analyst ,
Thorium 228
Thorium 230
Thorium 232
05/14/12 0:02 0.42 0.72
05/14/12 0:02 17 1.8
05/14/12 0:02 -0.29 0.51
0.31 pCi/g
0.81 pCi/g
0.31 pCi/g
ilg
ijg
lig
Prep Date
Uranium 234
Uranium 235
Uranium 238
Result Errori+/-) LLD Units XO Analyst
760 44 4.9 pCi/g * jig
38 11 4.9 pCi/g ' jig
939 49 4,9 pCi/g * jjg
Parameter Measure Date
05/09/12 0:04
05/09/12 0:04
05/09/12 0:04
Page 17 of 26
ACZ Laboratories, Inc. Radiochemistry
Reference 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

-.sport Header Explanations -
Batch A distinct set of samples analyzed at a specific time
Error(+/-) Calculated sample specific uncertainty
Found Value of the QC Type of interest
Limit Upper limit for RPD, in %.
LCL Lower Control Limit, in % (except for LCSS, mg/Kg)
LLD Calculated sample specific Lower Limit of Detection
PCN/SCN A number assigned to reagents/standards to trace to the manufacturers certificate of analysis
PQL Practical Quantitation Limit
QC True Value of the Control Sample or the amount added to the Spike
Rec Amount of the true value or spike added recovered, in % (except for LCSS, mg/Kg)
RER Relative Error Ratio, calculation used for Dup. QC taking into account the error factor.
UCL Upper Control Limit, in % (except for LCSS, mg/Kg)
Sample Value of the Sample of interest
QC sample T es
DUP Sample Duplicate MS/MSD Matrix Spike/Matrix Spike Duplicate
LCSS Laboratory Control Sample - Soil PBS Prep Blank - Soil
LCSW Laboratory Control Sample - Water PBW Prep Blank - Water
QC Sample Type Explanations
Blanks Verifies that there is no or minimal contamination in the prep method procedure.
Control Samples Verifies the accuracy of the method, including the prep procedure.
Duplicates Verifies the precision of the instrument and/or rnethod
Matrix Spikes Determines sample matrix interferences, if any.
ACZ Qualifiers (Qual)
Analysis exceeded method hold time.
Poor spike recovery accepted because the other spike in the set fell within the given limits.
High Replicate Error Ratio (RER) accepted because sample concentrations are less than 10x the MDL.
No nuclides detected above the Lower Limit of Detection (LLD)
V High blank data accepted because sample concentration is 10 times higher than blank concentration
X QC is out of control. See Case Narrative.
Poor spike recovery is accepted because sample concentration is four times greater than spike concentration.
EPA methodology, including those under SDWA, CWA, and RCRA
SM Standard Methods for the Examination of Water and Wastewater, 19th edition (1995) & 20th edition (1998),
ASTM
RP DOE
ESM DOE/ESM
Comments
(1) Solid matrices are reported on a dry weight basis.
(2) Preparation method: "Method" indicates preparation defined in analytical method.
(3) QC results calculated from raw data. Results may vary slightly if the rounded values are used in the calculations.
(4) An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification
qualifier associated with the result.
For a complete list of ACZ's Extended Qualifiers, please click: http://v, acz,comipuhlic/extquallist.pdf
REPIN09.12,29.01rc
Page 18 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Radiochemistry QC
Summary

Uranium Resources inc.
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
Lead 210 (3050) Eichrom Units: pCWg
ACZ ID Type Anayzed PCNISCH Error 1.10 Fourd Error. LLD Roc La 1FD/11ER Ltztt Qua!
WG322287
WG321858RBS1
WG321900PBS2
PBS 05/07/12
PBS 05107/12
0
0
8.9
8
35
32
70
64
WG322071LCSS LCSS 05/07/12 RC 111115-3 19224 170 10 28 884 47 101
194067-01 DUP DUP-RE 05107/12 2.6 2.8 11 1.3 2.9 11 0.32 2
194161-04 DUP OUP-RE 05/07/12 100 12 40 140 12 34 2.36 2 RC
194067-02MS MS 05/07/12 RC111115-3 73.05 4.1 3 12 78 5 13 101.2 47 101 /41
Radium 226 + Alpha Emitting Radium M9315 Units: pCi/g
ACZ ID Type A PC QC Sample Error LLD Found Error Rec Lower Upper RPD RER Lima Dual
WG322478
WG322201P8S PBS 05/08/12 .09 0.19 lA 2.8
WG322201LCSS LCSS 05/08/12 RC120118-1 47.83 60 3.2 1.5 125.4 63 126
L94161-01OUP DUP-RE 05/08/12 0.19 0.6 3.3 .41 0.59 3.3 0.26 2
L94161-01MS MS 05/08/12 RC120118-1 125.87 0.19 0.6 3.3 93 6.3 3.7 73.7 63 126
Thorium 228 ESM 4506 Units: pCifg
ACZ ID Type Analyzed PCN SCR QC Sample Error LLD Fotmd Error LLD Rec Lower Upper PPD,RER Limit Qual
WG322700
WG322503PBS PBS 05/14/12 -.09 0.66 0A1 0.82
L94161-01 DUP DUP-RE 05/14/12 0.42 0.72 0.31 .12 0.55 0.26 0.33 2
REPRa01.06.05.01
Page 19 of 26
AGZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Radiochemistry QC
Summary

Uranium Resources Inc. ACZ Project ID: L94161
Project ID: KVD Pond Sediment
Thorium 230 ESM 4506 Units: pCiig
ACZID Type Analyzed PCtISCN Sample Error LLD Found Error LLD Rec Lower Upper RP D)RER Lim lt Dual
WG322700
WG32.2503PBS PBS 05/14/12 0.66 1.1 2.2
WG322503LC3S LCSS 06/14/12 RC111214-1 162.12 190 5.1 0.73 117.2 93 124
L94161-01DUP DUP-RE 05/14/12 17 1.8 0.81 19 1.6 0.67 0.83 2
194161-01MS MS 05/14/12 RC111214-1 162.12 17 1.8 0.81 190 4.8 0.64 106.7 93 124
Thorium 232 ESM 4506 Units: pCVg
ACZ 11) Type Analyzed PCN SCN Sam le Error Found Error L. Rec Lo er Upper RPCIRER Limit falai
WG322700
WG322503PBS PBS 05/14/12 -.14 0.17 0.41 0.82
194161-01DUP DUP-RE 05/14/12 -0.29 0.51 0.31 -.23 0.35 0.26 0.1 2
Uranium 234 Eichrom ACW03 Units: pCi/g
ACZID Type Analyzed PCN:SCN QC Sornplc Error Found Er ror LLD Roc Low Upper RPDRER Limit Owl
WG322517
WG322286P8S PBS 05/139/12 A2 0.29 0.19 0.38 N1
WG322286P88 PBS 05439/12 .77 0.34 0.2 OA N1
WG322286LC5S LCSS 05/09/12 PCN35523 39.2 46 3.2 0.41 117.3 79 122
194185-0 I DUP DUP-RE 05/09/12 0.42 0.38 024 .36 0.32 0.26 0.12 2
L94185-01MS MS 05/09/12 P6N35523 39.2 0.42 0.38 024 39 2.9 0.42 98.4 79 122
REPRC.01.06.05.01
Page 20 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Radiochemistry QC
Summary

Uranium Resources Inc.
Project ID: KVD Pond Sediment
ACZ Project ID: L94161
Uranium 235 Eichrom ACWO3 Units: pCiig
ACZ ID Type Analyzed FCNISCN Sample LLD Found Error LLD Rec Lower Upper RPDIRER Limit Duel
WG322517
WG322286P BS P BS 05/09112 .07 0.12 0.19 0.38
WG322286P8S PBS 05109/12 .07 0.08 0.2 0.4
WG322286LCSS LCSS 05109/12 PC1135523 1.79 1.7 0.78 0.41 95 56 144
194185-01DUP DUP -RE 05/09112 0.06 0.16 0.24 .03 0.19 0.26 0.12 2
L94185-0 I MS MS 05/09/12 PCN35523 1.79 0.06 0.16 0_24 1.8 0.63 0.42 97.2 56 144
Uranium 238 Eichrom ACW03 Units: pGi/g
Found Erro LLD Rec Lower
WG 322517
WG322286PBS PBS 05/09/12 .51 0.29 0.19 0.38 N I
WG322286PBS PBS 05/09/12 .75 0.29 0.2 0.4 N1
WG322286LCSS LCSS 0509/12 PCI435523 39 43.9 3.1 0.41 112.6 81 124
L94185-01DUP DUP-RE 05/09112 0.8 0.38 0.24 .45 0.32 0.26 03 2
L94185-01MS MS 05,09/12 PCN35523 39 0.8 0.38 0.24 42.3 3 0.42 106.4 81 124
REPRC.01.06.05.01
Page 21 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, (X) 80487 [phone]

RadChem Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: L94161

ACZ ID WORK NUM P AR AtI ET ER METHOD QUAI. QESCRIPTION
L04161-01 W0322287 Lead 210 (3050)
WG322517 Uranium 234
Uranium 235
Uranium 238
Eichrom
Eichrom
Eichrom ACWO3
Eichrom ACWO3
Eichrom ACWO3
Eichrom ACWO3
Eichrom ACWO3
M1 Matrix spike recovery was high, the recovery of the
associated control sample (LCS or LER) was acceptable.
RC For a solid matrix, the matrix duplicate precision
assessment (RED or RER) exceeded the control limit,
which is attributable to the non-homogeneity of the sample.
N1 See Case Narrative.
N1A See Case Narrative,
N1A See Case Narrative.
N1 See Case Narrative.
NIA See Case Narrative,
REPAD.15,06.05.01
Page 22 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Uranium Resources inc.
Certification
Qualifiers
ACZ Project ID: L94161
GC/MS
The foliowtng par3meters are not offered for cenificatIon or are not covered by NELAC certlfica ACZ.
AniOne fv18270C GC/IAS
Radiochemistry
The following parameters are not offered for certification or are rkot covered by NELAC certificate #ACZ.
Lead 210 (3050) Eichrom
Thorium 228 ESM 4506
Thorium 230 ESM 4506
Thorium 232 ESM 4506
Uranium 234 Eichrom ACWO3
Uranium 235 Eichrom ACWO3
Uranium 238 Eichrom ACW03
Soil Analysis
Tho following parameters are not offered for certification or are not covered by NELAC certificate #ACZ
Solids, Percent CLPSOW390, PART F, D-98
REPAD.05.06.05.01
Page 23 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Sample
Receipt

Uranium Resources Inc.
KVD Pond Sediment

ACZ Project ID: L94161
Date Received: 04/20/2012 1014

Received By: ksj

Date Printed: 4/20/2012
Receipt Verification
YES NO NA
1) Does this project require special handling procedures such as CLP protocol?
2) Are the custody seals on the cooler intact?
3) Are the custody seals on the sample containers intact?
4) Is there a Chain of Custody or other directive shipping papers present?
5) Is the Chain of Custody complete?
6) ls the Chain of Custody in agreement with the samples received?
7) ls there enough sample for all requested analyses?
8) Are all samples within holding times for requested analyses?
9) Were all sample containers received intact?
10) Are the temperature blanks present?
11) Are the trip blanks (VOA and/or Cyanide) present?
12) Are samples requiring no headspace, headspace free?
13) Do the samples that require a Foreign Soils Permit have one?
Exceptions: If you answered no to any of the above questions, please describe
N/A
Contact (For any discrepancies, the client must be contacted)
N/A
Shipping Containers
Cooler id Temp (eC) Rad (p,R/hr)-1
23 Na15205 9
Client must contact ACZ Project Manager if analysis should not proceed tor
samples received outside of thermal presorvation acceptance criteria.
Notes
REPAD.03.11.00.01
Page 24 of 26
SAMPLE CLIENT ID R<21G<2 BK<2 Y< 2 "—VG< 2 13< 2 0 <2 T >12 1 N/A RAD ID
L94161-01 POND SED DIGESTED
Sample Container Preservation Legend
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Sample
Receipt

Uranium Resources inc.
KVD Pond Sediment

ACZ Project ID: L94161
Date Received: 04/20/2012 10:14

Received By: ksj

Date Printed: 4/20/2012
Sample Container Preservation
Abbreviation
BK
0
YG
N/A
RAD
Description
Raw/Nitric
Filtered/Sulfuric
Filtered/Nitric
Filtered/Nitric
Raw/Sulfuric
Raw/NaOH
Raw/NaOH Zinc Acetate
Raw/Sulfuric
Raw/Sulfuric
No preservative needed
Gamma/Beta dose rate
Container Type
RED
BLUE
BLACK
GREEN
ORANGE
PURPLE
TAN
YELLOW
YELLOW GLASS
Not applicable
Not applicable
Preservative/LImits
pH must be < 2
pH must be < 2
pH must be < 2
pH must be < 2
pH must be < 2
pH must be > 12 *
pH must be > 12
pH must be < 2
pH must be < 2
must be < 250 pR/hr
* pH check performed by analyst prior to sample preparation
Sample IDs Reviewed By: ksj
REPAD.03,11.00.01
Page 25 of 26
0
- 3
A Laboratories, Inc. L 1(o\ CHAIN of CUST01)Y
2773 Downhi 9 Drive Steamboat Springs, CO 80487 (800) 334-.5493
,
Name: Joshua Holland Address: 641 E FM 1118
Company: URI, Inc. Kingsville, TX 78363
[e-mail] Telephone: [phone]
,...:.q.,/ 7: 1.41...:,7 '.•.-:
Name: Jim Kegebein E-mail: ickegebeineuraniumresources.com
Company: URI, Inc. Telephone: [phone]
Name:
Company: URI, Inc.
E-mail: Tete .
11:( ,.I I 'i.i ( .1.!1,1,. li '
Quote #: POND-Sediment
, •. I: ....:1 ..t: i,•;I,'!, W.: or ;:.i r :i" “I. ti:.
Project/PO #: KVD Pond Sediment Character a) c
Reporfing state for compliance testing: Texas a Z Samplers Name: Joshua Holland 0 (..)
Are any samples NRC licensable
.;.%f PI I 11.1 r...1 i II !..:.,\ ! k )r..1
material? Yes No
!;.•‘;':-. IIMI. 1.1- il: ..
"6
Pond Sed. Digeted 2012-4-19 . 1:30 SO
Matrix
Joshua Holland
SW (Surface Water) • GW (Ground Water)
Please refer to ACEs
ri r‘j. )1d,,i ,l 1 , I.,
, 4W iiii"
• WW (Waste Water) • DW
terms & conditions
II I
2012-04-19 : 1700
(Drinking Water) • SL (Sludge) • SO (Soil) • OL (Oil)
located on the reverse side of this COC.
I '; CI 'VI II -.V
- Olher (Specify)
; . •
FRMADO50.01.15.09 White - Retum with sample. Yellow - Retafl for your records.
Page 26 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Analytical
Report

July 18, 2013
Report to:
Joshua Holland
Uranium Resources Inc.
405 State Highway 121 Bypass A110
Lewisville, TX 75067
cc: Jim Kegebein
Bill to:
Terry Blaszak
Uranium Resources Inc.
405 State Highway 121 Bypass A110
Lewisville, TX 75067
Project ID: Pond Mat. Char./K13-5355
ACZ Project ID: L12277
Joshua Holland:
Enclosed are the analytical results for sample(s) submitted to ACZ Laboratories, Inc. (ACZ) on May 24, 2013.
This project has been assigned to ACZ's project number, L12277. Please reference this number in all future
inquiries.
All analyses were performed according to ACZ's Quality Assurance Plan. The enclosed results relate only to
the samples received under L12277. Each section of this report has been reviewed and approved by the
appropriate Laboratory Supervisor, or a qualified substitute.
Except as noted, the test results for the methods and parameters listed on ACZ's current NELAC certificate
letter (#ACZ) meet all requirements of NELAC.
This report shall be used or copied only in its entirety. ACZ is not responsible for the consequences arising
from the use of a partial report.
All samples and sub-samples associated with this project will be disposed of after August 17, 2013. If the
samples are determined to be hazardous, additional charges apply for disposal (typically $11/sample). If you
would like the samples to be held longer than ACZ's stated policy or to be returned, please contact your Project
Manager or Customer Service Representative for further details and associated costs. ACZ retains analytical
raw data reports for ten years.
If you have any questions or other needs, please contact your Project Manager.
cvOL,
Sue Webber has reviewed and
approved this report.
ACC 0 Ro t. ,.... 44, ,... ,..0,6 ce ,.. u, . e . , '4444 .4
I ' " .. z
REPAD.01.06.05.02

ACIL

Page 1 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Case
Narrative

Uranium Resources Inc. July 18, 2013
Project ID: Pond Mat. Char./K13-5355
ACZ Project ID: L12277
sample Receipt
ACZ Laboratories, Inc. (ACZ) received 1 sediment sample from Uranium Resources Inc. on May 24, 2013. The sample was
received in good condition. Upon receipt, the sample custodian removed the sample from the cooler, inspected the
contents, and logged the sample into ACZ's computerized Laboratory Information Management System (LIMS). The sample
was assigned ACZ LIMS project number L12277. The custodian verified the sample information entered into the computer
against the chain of custody (COC) forms and sample bottle labels.
Holding Times
All analyses were performed within EPA recommended holding times.
sample Analysis
This sample was analyzed for inorganic, organic, radiochemistry parameters. The individual methods are referenced on
both, the ACZ invoice and the analytical reports. The following anomaly required further explanation not provided by the
Extended Qualifier Report:
1. For Isotopic Uranium values flagged with an "Nl", the sample was diluted due to matrix interferences (high sample
activity), the columns became over-saturated and the tracer was lost.
REPAD.03.06.05.01 Page 2 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Inorganic Analytical
Results

Uranium Resources Inc. ACZ Sample ID: 1.1 2277-01
Project ID: Pond Mat. Char./K13-5355 Date Sampled: 05/23/13 11:45
Sample ID: IRON CAKE Date Received: 05/24/13
Sample Matrix: Sediment
Inorganic Prep
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
Total Hot Plate M3010A ICP 06/06/13 11:05 aeb
Digestion
Metals Analysis
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
Arsenic (TCLP) M6010B ICP 5 mg/L 0.5 3 06/08/13 8:08 aeb
Barium (TCLP) M60106 ICP 5 0.08 mg/L 0.02 0.08 06/08/13 8:08 aeb
Cadmium (TCLP) M6010B ICP 5 mg/L 0.03 0.08 06/08/13 8:08 aeb
Chromium (TCLP) M6010B ICP 5 mg/L 0.05 0.3 06/08/13 8:08 aeb
Lead (TCLP) M6010B ICP 5 mg/L 0.2 1 06/08/13 8:08 aeb
Mercury (TCLP) M7470CVAA 1 mg/L 0.0002 0.001 06/06/13 14:58 mfm
Selenium (TCLP) M60106 ICP 5 mg/L 0.5 3 06/08/13 8:08 aeb
Silver (TCLP) M60106 ICP 5 0.25 mg/L 0.05 0.1 06/08/13 8:08 aeb
Soil Analysis
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
Solids, Percent CLPSOW390, PART F, D-98 1 42.5 0.1 0.5 06/10/13 16:18 cdb
Soil Preparation
Parameter EPA Method Dilution Result Qua! XQ Units MDL PQL Date Analyst
Air Dry at 34 Degrees USDA No. 1, 1972 06/06/13 8:30 kpd/brd
TCLP Metal Extraction M1311 06/04/13 22:50 nrc/cdb
REPIN.02.06.05.01 * Please refer to Qualifier Reports for details.
Page 3 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Inorganic
Reference

Report Header Explanations
Batch
Found
Limit
Lower
MDL
PCN/SCN
PQL
QC
Rec
RPD
Upper
Sample
A distinct set of samples analyzed at a specific time
Value of the QC Type of interest
Upper limit for RPD, in %.
Lower Recovery Limit, in % (except for LCSS, mg/Kg)
Method Detection Limit. Same as Minimum Reporting Limit. Allows for instrument and annual fluctuations.
A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
Practical Quantitation Limit, typically 5 times the MDL.
True Value of the Control Sample or the amount added to the Spike
Recovered amount of the true value or spike added, in % (except for LCSS, mg/Kg)
Relative Percent Difference, calculation used for Duplicate QC Types
Upper Recovery Limit, in % (except for LCSS, mg/Kg)
Value of the Sample of interest
QC Sample Types
AS Analytical Spike (Post Digestion) LCSWD Laboratory Control Sample - Water Duplicate
ASD Analytical Spike (Post Digestion) Duplicate LFB Laboratory Fortified Blank
CCB Continuing Calibration Blank LFM Laboratory Fortified Matrix
CCV Continuing Calibration Verification standard LFMD Laboratory Fortified Matrix Duplicate
DUP Sample Duplicate LRB Laboratory Reagent Blank
ICB Initial Calibration Blank MS Matrix Spike
ICV Initial Calibration Verification standard MSD Matrix Spike Duplicate
ICSAB Inter-element Correction Standard - A plus B solutions PBS Prep Blank - Soil
LCSS Laboratory Control Sample - Soil PBW Prep Blank - Water
LCSSD Laboratory Control Sample - Soil Duplicate PQV Practical Quantitation Verification standard
LCSW Laboratory Control Sample - Water SDL Serial Dilution
QC Sample Type Explanations
Blanks
Control Samples
Duplicates
Spikes/Fortified Matrix
Standard
Verifies that there is no or minimal contamination in the prep method or calibration procedure.
Verifies the accuracy of the method, including the prep procedure.
Verifies the precision of the instrument and/or method.
Determines sample matrix interferences, if any.
Verifies the validity of the calibration.
ACZ Qualifiers (Qua])
• Analyte concentration detected at a value between MDL and PQL. The associated value is an estimated quantity.
• Analysis exceeded method hold time. pH is a field test with an immediate hold time.
Target analyte response was below the laboratory defined negative threshold.
• The material was analyzed for, but was not detected above the level of the associated value.
The associated value is either the sample quantitation limit or the sample detection limit.
Method References
(1)
(2)
(3)
(4)
(5)
Comments
(1)
(2)
(3)
(4)
(5)
EPA 600/4-83-020. Methods for Chemical Analysis of Water and Wastes, March 1983.
EPA 600/R-93-100. Methods for the Determination of Inorganic Substances in Environmental Samples, August 1993.
EPA 600/R-94-111. Methods for the Determination of Metals in Environmental Samples - Supplement I, May 1994.
EPA SW-846. Test Methods for Evaluating Solid Waste.
Standard Methods for the Examination of Water and Wastewater.
QC results calculated from raw data. Results may vary slightly if the rounded values are used in the calculations.
Soil, Sludge, and Plant matrices for Inorganic analyses are reported on a dry weight basis.
Animal matrices for Inorganic analyses are reported on an "as received" basis.
An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification qualifier
associated with the result.
If the MDL equals the PQL or the MDL column is omitted, the PQL is the reporting limit.
For a complete list of ACZ's Extended Qualifiers, please click: http://www.acz.com/public/extquallist.pdf
REP001.09.12.01
Page 4 of 26

ACZ Laboratories, Inc.

Inorganic QC
Summary 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Project ID: L1 2277
Arsenic (TCLP) M6010B ICP
ACZ ID Type Analyzed PCN/SCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG345138
WG3451381CV !CV 06/08/13 7:46 11130514-1 4 4.05 mg/L 101.3 90 110
WG345138ICB ICB 06/08/13 7:49 U mg/L -0.3 0.3
WG344927PBS PBS 06/08/13 8:01 u mg/L -0.3 0.3
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK 1 1.1 mg/L 110 85 115
L12277-01DUP DUP 06/08/13 8:11 U u mg/L 0 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK 1 U 1.01 mg/L 101 75 125
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK 1 u 1.09 mg/L 109 75 125 7.62 20
Barium (TCLP) M6010B ICP
ACZ ID Type Analyzed PCN/SCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG345138
WG3451381CV ICV 06/08/13 7:46 11130514-1 2 1.967 mg/L 98.4 90 110
WG345138ICB ICB 06/08/13 7:49 U mg/L -0.009 0.009
WG344927PB5 PBS 06/08/13 8:01 U mg/L -0.009 0.009
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK 20.5 19.82 mg/L 96.7 85 115
L12277-01DUP DUP 06/08/13 8:11 .08 .068 mg/L 16.2 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK 20.5 .08 2.876 mg/L 13.6 75 125 M2
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK 20.5 .08 2.849 mg/L 13.5 75 125 0.94 20 M2
Cadmium (TCLP) M60106 ICP
ACZ ID Type Analyzed PCNISCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG345138
WG3451381CV ICV 06/08/13 7:46 11130514-1 2 1.947 mg/L 97.4 90 110
WG345138ICB ICB 06/08/13 7:49 u mg/L -0.015 0.015
WG344927PBS PBS 06/08/13 8:01 u mg/L -0.015 0.015
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK .5 .5118 mg/L 102.4 85 115
L12277-01DUP DUP 06/08/13 8:11 u U mg/L 0 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK .5 U .531 mg/L 106.2 75 125
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK .5 U .522 mg/L 104.4 75 125 1.71 20
Chromium (TCLP) M6010B ICP
ACZ ID Type Analyzed PCN/SCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG345138
WG3451381CV ICV 06/08/13 7:46 11130514-1 2 1.969 mg/L 98.5 90 110
WG345138ICB 1CB 06/08/13 7:49 U mg/L -0.03 0.03
WG344927PBS PBS 06/08/13 8:01 U mg/L -0.03 0.03
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK .5 .512 mg/L 102.4 85 115
L12277-01DUP DUP 06/08/13 8:11 u u mg/L 0 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK .5 U .514 mg/L 102.8 75 125
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK .5 u .518 mg/L 103.6 75 125 0.78 20
REPIN.01.06.05.01 Page 5 of 26

ACZ Laboratories, Inc.

inorganic QC
Summary 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Project ID: L12277
Lead (TCLP) M6010B ICP
ACZ ID Type Analyzed PCN/SCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG345138
WG3451381CV ICV 06/08/13 7:46 11130514-1 4 3.948 mg/L 98.7 90 110
WG345138ICB ICB 06/08/13 7:49 U mg/L -0.12 0.12
WG344927PBS PBS 06/08/13 8:01 u mg/L -0.12 0.12
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK 1 1.022 mg/L 102.2 85 115
L12277-01DUP DUP 06/08/13 8:11 U u mg/L 0 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK 1 U u mg/L 0 75 125 MD
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK 1 u u mg/L 0 75 125 20 MD
Mercury (TCLP) M7470CVAA
ACZ ID Type Analyzed PCN/SCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG344958
WG3449581CV ICV 06/06/13 10:18 11130522-4 .005025 .00484 mg/L 96.3 90 110
WG3449581CB ICB 06/06/13 10:20 mg/L -0.0006 0.0006
WG345005
WG345005PBW PBW 06/06/13 14:52 u mg/L -0.00044 0.00044
WG344927PB5 PBS 06/06/13 14:54 U mg/Kg -0.0006 0.0006
WG344927LFB LFB 06/06/13 14:56 11130515-2 .002002 .00186 mg/L 92.9 85 115
L12277-01DUP DUP 06/06/13 15:00 u U mg/L 0 20 RA
L12277-01MS MS 06/06/13 15:02 11130515-2 .002002 U .00183 mg/L 91.4 85 115
L12277-01MSD MSD 06/06/13 15:04 11130515-2 .002002 U .00181 mg/L 90.4 85 115 1.1 20
Selenium (TCLP) M60106 ICP
ACZ ID Type Analyzed PCN/SCN QC Sample Found Units Rec Lower Upper RPD Limit Qual
WG345138
WG3451381CV ICV 06/08/13 7:46 11130514-1 4 4.06 mg/L 101.5 90 110
WG345138ICB ICB 06/08/13 7:49 U mg/L -0.3 0.3
WG344927PBS PBS 06/08/13 8:01 U mg/L -0.3 0.3
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK 1 1.12 mg/L 112 85 115
L12277-01DUP DUP 06/08/13 8:11 U u mg/L 0 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK 1 U .62 mg/L 62 75 125 MD
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK 1 U .72 mg/L 72 75 125 14.93 20 MD
Silver (TCLP) M6010B ICP
ACZ ID Type Analyzed PCNISCN QC Sample Found Units Rec Lo er Upper RPD Limit Qual
WG345138
WG3451381CV ICV 06/08/13 7:46 11130514-1 .998 .993 mg/L 99.5 90 110
WG345138ICB ICB 06/08/13 7:49 U mg/L -0.03 0.03
WG344927PBS PBS 06/08/13 8:01 U mg/L -0.03 0.03
WG344927LFB LFB 06/08/13 8:05 IITCLPSPIK .5 .516 mg/L 103.2 85 115
L12277-01DUP DUP 06/08/13 8:11 .25 .142 mg/L 55.1 20 RA
L12277-01MS MS 06/08/13 8:14 IITCLPSPIK .5 .25 .777 mg/L 105.4 75 125
L12277-01MSD MSD 06/08/13 8:18 IITCLPSPIK .5 .25 .783 mg/L 106.6 75 125 0.77 20
REPIN.01.06.05.01 Page 6 of 26

ACZ Laboratories, Inc.

Inorganic QC
Summary 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Project ID: L12277
Solids, Percent CLPSOW390, PART F, D-98
ACZ ID Type Analyzed PCNiSCN QC Sample Found Units Rec. Lower Upper RPD Limit Qual
WG345272
WG345272P6S PBS 06/10/13 11:15 99.9 100.1
L12341-03DUP DUP 06/11/13 12:30 33.9 35.48 % 4.6 20
REPIN.01.06.05.01 Page 7 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Inorganic Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: L12277

ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION
L12277-01 WG345138 Arsenic (TCLP) M6010B ICP D1 Sample required dilution due to matrix.
M6010B ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
Barium (TCLP) M6010B ICP D1 Sample required dilution due to matrix.
M6010B ICP M2 Matrix spike recovery was low, the recovery of the
associated control sample (LCS or LFB) was acceptable.
M60108 ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
Cadmium (TCLP) M6010B ICP D1 Sample required dilution due to matrix.
M60106 ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
Chromium (TCLP) M601013 ICP D1 Sample required dilution due to matrix.
M6010B ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
Lead (TCLP) M60106 ICP D1 Sample required dilution due to matrix.
M6010B ICP MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M60106 ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
WG345005 Mercury (TCLP) M7470CVAA RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
WG345138 Selenium (TCLP) M60106 ICP D1 Sample required dilution due to matrix.
M6010B ICP MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M60106 ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
Silver (TCLP) M6010B ICP RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
REPAD.15.06.05.01
Page 8 of 26
•

ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic Analytical
Results

Uranium Resources Inc. ACZ Sample ID: L12277-01
Project ID: Pond Mat. Char./K13-5355 Date Sampled: 05/23/13 11:45
Sample ID: IRON CAKE Date Received: 05/24/13
Sample Matrix: Sediment
Base Neutral Acid Extractables by GUMS
Analysis Method: M8270C GC/MS
Extract Method: M3540
Work, rou : WG344791
Analyst: itk
Extract Date: 05/29/13 16:17
Analysis Date: 06/03/13 23:34
Co pound CAS
1,2,4-Trichlorobenzene 120-82-1
1,2-Dichlorobenzene 95-50-1
1,3-Dichlorobenzene 541-73-1
1,4-Dichlorobenzene 106-46-7
2,4,5-Trichlorophenol 95-95-4
2,4,6-Trichlorophenol 88-06-2
2,4-Dichlorophenol 120-83-2
2,4-Dimethylphenol 105-67-9
2,4-Dinitrophenol 51-28-5
2,4-Dinitrotoluene 121-14-2
2,6-Dinitrotoluene 606-20-8
2-Chloronaphthalene 91-58-7
2-Chlorophenol 95-57-8
2-Methylnaphthalene 91-57-6
2-Methylphenol 95-48-7
2-Nitroaniline 88-74-4
2-Nitrophenol 88-75-5
3- & 4-Methylphenol 1319-77-3
3,3-Dichlorobenzidine 91-94-1
3-Nitroaniline 99-09-2
4,6-Dinitro-2-methylphenol 534-52-1
4-Bromophenyl phenyl ether 101-55-3
4-Chloro-3-methylphenol 59-50-7
4-Chloroaniline 106-47-8
4-Chlorophenyl phenyl ether 7005-72-3
4-Nitroaniline 100-01-6
4-Nitrophenol 100-02-07
Acenaphthene 83-32-9
Acenaphthylene 208-96-8
Aniline 62-53-3
Anthracene 120-12-7
Azobenzene 103-33-3
Benzo(a)anthracene 56-55-3
Benzo(a)pyrene 50-32-8
Benzo(b)fluoranthene 205-99-2
Benzo(g,h,i)perylene 191-24-2
Benzo(k)fluoranthene 207-08-9
Benzoic Acid 65-85-0
REPOR.01.01.01.02
Result QUAL Dilution XQ Units MDL PQL
500 * ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 5000 30000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 2000 10000
500 * ug/Kg 10000 30000
500 * ug/Kg 1000 5000
500 ug/Kg 5000 30000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 * ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 5000 30000
500 ug/Kg 2000 10000
500 * ug/Kg 2000 10000
500 ug/Kg 10000 30000
500 ug/Kg 5000 30000
500 * ug/Kg 5000 30000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 * ug/Kg 1000 5000
500 ug/Kg 5000 30000
500 ug/Kg 5000 30000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 5000 30000
500 ug/Kg 1000 5000
500 * ug/Kg 5000 30000
500 * ug/Kg 1000 5000
500 * ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 ug/Kg 1000 5000
500 * ug/Kg 1000 5000
500 ug/Kg 10000 30000
* Please refer to Qualifier Reports for details.
Page 9 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic Analytical
Results

Uranium Resources Inc. ACZ Sample ID: L12277-01
Project ID: Pond Mat. Char./K13-5355 Date Sampled: 05/23/13 11.45
Sample ID: IRON CAKE Date Received: 05/24/13
Sample Matrix: Sediment
Benzyl alcohol 100-51-6 500 ug/Kg 1000 5000
Bis(2-chloroethoxy)methane 111-91-1 500 ug/Kg 1000 5000
Bis(2-chloroethyl) ether 111-44-4 500 ug/Kg 1000 5000
Bis(2-chloroisopropyl) ether 108-60-1 500 ug/Kg 1000 5000
Bis(2-ethylhexyl) phthalate 117-81-7 500 ug/Kg 2000 10000
Butyl benzyl phthalate 85-68-7 500 ug/Kg 1000 5000
Chrysene 218-01-9 500 ug/Kg 1000 5000
Dibenzo(a,h)anthracene 53-70-3 500 ug/Kg 1000 5000
Dibenzofuran 132-64-9 500 ug/Kg 1000 5000
Diethylphthalate 84-66-2 500 ug/Kg 1000 5000
Dimethyl phthalate 131-11-3 500 ug/Kg 1000 5000
Di-n-butyl phthalate 84-74-2 500 ug/Kg 1000 5000
Di-n-octyl phthalate 117-84-0 500 ug/Kg 1000 5000
Fluoranthene 206-44-0 500 ug/Kg 1000 5000
Fluorene 86-73-7 500 ug/Kg 1000 5000
Hexachlorobenzene 118-74-1 500 ug/Kg 1000 5000
Hexachlorobutadiene 87-68-3 500 ug/Kg 1000 5000
Hexachlorocyclopentadiene 77-47-4 500 ug/Kg 1000 5000
Hexachloroethane 67-72-1 500 ug/Kg 1000 5000
lndeno(1,2,3-cd)pyrene 193-39-5 500 ug/Kg 1000 5000
lsophorone 78-59-1 500 ug/Kg 1000 5000
Naphthalene 91-20-3 500 ug/Kg 1000 5000
Nitrobenzene 98-95-3 500 ug/Kg 1000 5000
N-Nitrosodimethylamine 62-75-9 500 ug/Kg 5000 30000
N-Nitrosodi-n-propylamine 621-64-7 500 ug/Kg 1000 5000
N-Nitrosodiphenylamine 86-30-6 500 ug/Kg 1000 5000
Pentachlorophenol 87-86-5 500 ug/Kg 5000 30000
Phenanthrene 85-01-8 500 ug/Kg 1000 5000
Phenol 108-95-2 500 ug/Kg 2000 10000
Pyrene 129-00-0 500 ug/Kg 1000 5000
Surrogate Recoveries CAS % Recovery Dilution XQ Units LCL UCL
2,4,6-Tribromophenol 118-79-6 330.6 500 * % 35 125
2-Fluorobiphenyl 321-60-8 275.1 500 * % 45 105
2-Fluorophenol 367-12-4 250 500 * % 35 105
Nitrobenzene-d5 4165-60-0 279 500 * % 35 100
Phenol-d6 13127-88-3 264.2 500 * % 40 100
Terphenyl-d14 1718-51-0 265.8 500 * % 30 125
REPOR.01.01.01.02 * Please refer to Qualifier Reports for details.
Page 10 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic
Reference

Report Header Explanations
Batch
Found
Limit
Lower
LCL
MDL
PCN/SCN
PQL
QC
Rec
RPD
Upper
UCL
Sample
A distinct set of samples analyzed at a specific time
Value of the QC Type of interest
Upper limit for RPD, in %.
Lower Recovery Limit, in % (except for LCSS, mg/Kg)
Lower Control Limit
Method Detection Limit. Same as Minimum Reporting Limit Allows for instrument and annual fluctuations.
A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
Practical Quantitation Limit, typically 5 times the MDL.
True Value of the Control Sample or the amount added to the Spike
Amount of the true value or spike added recovered, in % (except for LCSS, mg/Kg)
Relative Percent Difference, calculation used for Duplicate QC Types
Upper Recovery Limit, in % (except for LCSS, mg/Kg)
Upper Control Limit
Value of the Sample of interest
QC Sample Types
SURR Surrogate LFM Laboratory Fortified Matrix
INTS internal Standard LFMD Laboratory Fortified Matrix Duplicate
DUP Sample Duplicate LRB Laboratory Reagent Blank
LCSS Laboratory Control Sample - Soil MS/MSD Matrix Spike/Matrix Spike Duplicate
LCSW Laboratory Control Sample - Water PBS Prep Blank - Soil
LFB Laboratory Fortified Blank PBW Prep Blank - Water
Sample Type Explanations
Blanks Verifies that there is no or minimal contamination in the prep method or calibration procedure.
Control Samples Verifies the accuracy of the method, including the prep procedure.
Duplicates Verifies the precision of the instrument and/or method.
Spikes/Fortified Matrix Determines sample matrix interferences, if any.
ACZ Qualifiers (Qual)
Analyte concentration detected at a value between MDL and PQL. The associated value is an estimated quantity.
O Analyte concentration is estimated due to result exceeding calibration range.
Analysis exceeded method hold time. pH is a field test with an immediate hold time.
Analyte concentration detected at a value between MDL and PQL. The associated value is an estimated quantity.
Target analyte response was below the laboratory defined negative threshold.
The material was analyzed for, but was not detected above the level of the associated value.
The associated value is either the sample quantitation limit or the sample detection limit.
Method References
(1) EPA 600/4-83-020. Methods for Chemical Analysis of Water and Wastes, March 1983.
(2) EPA 600/4-90/020. Methods for the Determination of Organic Compounds in Drinking Water (0, July 1990.
(3) EPA 600/R-92/129. Methods for the Determination of Organic Compounds in Drinking Water (ll), July 1990.
(4) EPA SW-846. Test Methods for Evaluating Solid Waste.
(5) Standard Methods for the Examination of Water and Wastewater.
Comments
(1) QC results calculated from raw data. Results may vary slightly if the rounded values are used in the calculations.
(2) Excluding Oil & Grease, solid & biological matrices for organic analyses are reported on a wet weight basis.
(3) An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification qualifier
associated with the result.
(4) lf the MDL equals the PQL or the MDL column is omitted, the PQL is the reporting limit
For a complete list of ACZ's Extended Qualifiers, please click: http://www.acz.com/public/extQuallist.Tdf
REP002.09.12.01
Page 11 of 26
Compound
1,2,4-TRICHLOROBENZENE
1,4-DICHLOROBENZENE
2,4-DINITROTOLUENE
2-CHLOROPHENOL
Sample Found Units Rec Lower Upper RPD Limit Qual
1321 ug/Kg 79.3 45 110
1296 ug/Kg 77.8 35 105
1400 ug/Kg 84.0 50 115
2089 ug/Kg 83.5 45 105
QC
1666.7
1666.7
1666.7
2500.7
ADZ Laboratories, Inc.

Organic QC
Summary 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Project ID: L12277
Base Neutral Acid Extractables by GC/MS M8270C GC/MS
WG344791
MS Sample ID: L12169-02MS PCN/SCN: BNA130306-1-30 Analyzed: 06/03/13 22:27
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,2,4-TRICHLOROBENZENE 1666.7 1540 ug/Kg 92.4 45 110 MD S8
1,4-DICHLOROBENZENE 1666.7 1500 ug/Kg 90.0 35 105 MD S8
2,4-DINITROTOLUENE 1666.7 1320 ug/Kg 79.2 50 115 MD S8
2-CHLOROPHENOL 2500.7 2430 ug/Kg 97.2 45 105 MD S8
4-CHLOR0-3-METHYLPHENOL 2500.3 2370 ug/Kg 94.8 45 115 MD S8
4-NITROPHENOL 2500.7 ug/Kg 0.0 15 140 MD S8
ACENAPHTHENE 1666.7 1610 ug/Kg 96.6 45 110 MD S8
N-NITROSODI-N-PROPYLAMINE 1666.7 1640 ug/Kg 98.4 40 115 MD S8
PENTACHLOROPHENOL 2500 3800 ug/Kg 152.0 25 120 MD S8
PHENOL 2500 2500 ug/Kg 100.0 40 100 MD S8
PYRENE 1666.7 1630 ug/Kg 97.8 45 125 MD S8
2,4,6-TRIBROMOPHENOL (surr) 140.4 35 125 MD S8
2-FLUOROBIPHENYL (surr) 101.2 45 105 MD S8
2-FLUOROPHENOL (surr) 91.2 35 105 MD S8
NITROBENZENE-D5 (surr) 98.2 35 100 MD S8
PHENOL-D6 (surr) 95.9 40 100 MD S8
TERPHENYL-D14 (surr) 90.4 30 125 MD S8
MSD Sample ID: L12169-02MSD PCN/SCN: BNA130306-1-30 Analyzed: 06/03/13 23:00
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,2,4-TRICHLOROBENZENE 1666.7 1560 ug/Kg 93.6 45 110 1.29 20 MD S8
1,4-DICHLOROBENZENE 1666.7 1540 ug/Kg 92.4 35 105 2.63 20 MD S8
2,4-DINITROTOLUENE 1666.7 1400 ug/Kg 84.0 50 115 5.88 20 MD S8
2-CHLOROPHENOL 2500.7 2470 ug/Kg 98.8 45 105 1.63 20 MD S8
4-CHLOR0-3-METHYLPHENOL 2500.3 2500 ug/Kg 100.0 45 115 5.34 20 MD S8
4-NITROPHENOL 2500.7 ug/Kg 0.0 15 140 20 MD S8
ACENAPHTHENE 1666.7 1550 ug/Kg 93.0 45 110 3.8 20 MD S8
N-NITROSODI-N-PROPYLAMINE 1666.7 1690 ug/Kg 101.4 40 115 3 20 MD S8
PENTACHLOROPHENOL 2500 3900 ug/Kg 156.0 25 120 2.6 20 MD S8
PHENOL 2500 2500 ug/Kg 100.0 40 100 0 20 MD S8
PYRENE 1666.7 1640 ug/Kg 98.4 45 125 0.61 20 MD S8
2,4,6-TRIBROMOPHENOL (surr) 141.1 35 125 MD S8
2-FLUOROBIPHENYL (surr) 101.8 45 105 MD S8
2-FLUOROPHENOL (surr) 94.0 35 105 MD S8
NITROBENZENE-D5 (surr) 101.4 35 100 MD S8
PHENOL-D6 (surr) 96.7 40 100 MD S8
TERPHENYL-D14 (surr) 89.2 30 125 MD S8
LCSS Sample ID: WG344520LCSS PCN/SCN: BNA130306-1-30 Analyzed: 06/03/13 20:45
REPOR.01.06.05.01
Page 12 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic QC
Summary

Uranium Resources Inc. ACZ Project ID: L12277
4-CHLOR0-3-METHYLPHENOL 2500.3 2147 ug/Kg 85.9 45 115
4-NITROPHENOL 2500.7 2140 ug/Kg 85.6 15 140
ACENAPHTHENE 1666.7 1351 ug/Kg 81.1 45 110
N-NITROSODI-N-PROPYLAMINE 1666.7 1379 ug/Kg 82.7 40 115
PENTACHLOROPHENOL 2500 1790 ug/Kg 71.6 25 120
PHENOL 2500 2030 ug/Kg 81.2 40 100
PYRENE 1666.7 1663 ug/Kg 99.8 45 125
2,4,6-TRIBROMOPHENOL (surr) % 89.3 35 125
2-FLUOROBIPHENYL (surr) % 85.9 45 105
2-FLUOROPHENOL (surr) % 79.1 35 105
NITROBENZENE-D5 (surr) % 85.9 35 100
PHENOL-D6 (surr) % 80.3 40 100
TERPHENYL-D14 (surr) % 98.8 30 125
LCSSD Sample ID: WG344520LCSSD PCN/SCN: BNA130306-1-30 Analyzed: 06/03/13 21:19
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,2,4-TRICHLOROBENZENE 1666.7 1320 ug/Kg 79.2 45 110 0.1 20
1,4-DICHLOROBENZENE 1666.7 1282 ug/Kg 76.9 35 105 1.1 20
2,4-DINITROTOLUENE 1666.7 1462 ug/Kg 87.7 50 115 4.3 20
2-CHLOROPHENOL 2500.7 2053 ug/Kg 82.1 45 105 1.7 20
4-CHLOR0-3-METHYLPHENOL 2500.3 2234 ug/Kg 89.3 45 115 4 20
4-NITROPHENOL 2500.7 2310 ug/Kg 92.4 15 140 7.6 20
ACENAPHTHENE 1666.7 1384 ug/Kg 83.0 45 110 2.4 20
N-NITROSODI-N-PROPYLAMINE 1666.7 1403 ug/Kg 84.2 40 115 1.7 20
PENTACHLOROPHENOL 2500 1880 ug/Kg 75.2 25 120 4.9 20
PHENOL 2500 2060 ug/Kg 82.4 40 100 1.5 20
PYRENE 1666.7 1647 ug/Kg 98.8 45 125 1 20
2,4,6-TRIBROMOPHENOL (surr) 83.0 35 125
2-FLUOROBIPHENYL (surr) 87.0 45 105
2-FLUOROPHENOL (surr) 77.6 35 105
NITROBENZENE-D5 (surr) 86.1 35 100
PHENOL-D6 (surr) 81.5 40 100
TERPHENYL-D14 (surr) 98.3 30 125
PBS Sample ID: WG344520PBS Analyzed: 06/03/13 20:11
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,2,4-TRICHLOROBENZENE ug/Kg -300 300
1,2-DICHLOROBENZENE ug/Kg -300 300
1,3-DICHLOROBENZENE ug/Kg -300 300
1,4-DICHLOROBENZENE ug/Kg -300 300
2,4,5-TRICHLOROPHENOL ug/Kg -2000 2000
2,4,6-TRICHLOROPHENOL ug/Kg -300 300
2,4-DICHLOROPHENOL ug/Kg -300 300
2,4-DIMETHYLPHENOL ug/Kg -700 700
2,4-DINITROPHENOL ug/Kg -2000 2000
2,4-DINITROTOLUENE ug/Kg -300 300
2,6-DINITROTOLUENE ug/Kg -2000 2000
2-CHLORONAPHTHALENE ug/Kg -300 300
2-CHLOROPHENOL ug/Kg -300 300
REPOR.01.06.05.01
Page 13 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic QC
Summary

Uranium Resources Inc. ACZ Project ID: L12277
2-METHYLNAPHTHALENE U ug/Kg -300 300
2-METHYLPHENOL U ug/Kg -300 300
2-NITROANILINE U ug/Kg -2000 2000
2-NITROPHENOL U ug/Kg -700 700
3- & 4-METHYLPHENOL U ug/Kg -700 700
3,3-DICHLOROBENZIDINE U ug/Kg -2000 2000
3-NITROANILINE u ug/Kg -2000 2000
4,6-DINITRO-2-METHYLPHENOL U ug/Kg -2000 2000
4-BROMOPHENYL PHENYL ETHER U ug/Kg -300 300
4-CHLOR0-3-METHYLPHENOL U ug/Kg -300 300
4-CHLOROANILINE u ug/Kg -300 300
4-CHLOROPHENYL PHENYL ETHER U ug/Kg -300 300
4-NITROANILINE u ug/Kg -2000 2000
4-NITROPHENOL U ug/Kg -2000 2000
ACENAPHTHENE U ug/Kg -300 300
ACENAPHTHYLENE U ug/Kg -300 300
ANILINE U ug/Kg -2000 2000
ANTHRACENE U ug/Kg -300 300
AZOBENZENE u ug/Kg -2000 2000
BENZO(A)ANTHRACENE U ug/Kg -300 300
BENZO(A)PYRENE u ug/Kg -300 300
BENZO(B)FLUORANTHENE u ug/Kg -300 300
BENZO(G,H,I)PERYLENE U ug/Kg -300 300
BENZO(K)FLUORANTHENE U ug/Kg -300 300
BENZOIC ACID U ug/Kg -2000 2000
BENZYL ALCOHOL U ug/Kg -300 300
BIS(2-CHLOROETHOXY)METHANE U ug/Kg -300 300
BIS(2-CHLOROETHYL) ETHER U ug/Kg -300 300
BIS(2-CHLOROISOPROPYL) ETHER u ug/Kg -300 300
BIS(2-ETHYLHEXYL) PHTHALATE U ug/Kg -700 700
BUTYL BENZYL PHTHALATE U ug/Kg -300 300
CHRYSENE U ug/Kg -300 300
DIBENZO(A,H)ANTHRACENE u ug/Kg -300 300
DIBENZOFURAN U ug/Kg -300 300
DIETHYLPHTHALATE U ug/Kg -300 300
DIMETHYL PHTHALATE U ug/Kg -300 300
DI-N-BUTYL PHTHALATE U ug/Kg -300 300
DI-N-OCTYL PHTHALATE U ug/Kg -300 300
FLUORANTHENE U ug/Kg -300 300
FLUORENE u ug/Kg -300 300
HEXACHLOROBENZENE U ug/Kg -300 300
HEXACHLOROBUTADIENE u ug/Kg -300 300
HEXACHLOROCYCLOPENTADIENE U ug/Kg -300 300
HEXACHLOROETHANE U ug/Kg -300 300
INDEN0(1,2,3-CD)PYRENE U ug/Kg -300 300
ISOPHORONE U ug/Kg -300 300
NAPHTHALENE U ug/Kg -300 300
NITROBENZENE U ug/Kg -300 300
N-NITROSODIMETHYLAMINE U ug/Kg -2000 2000
REPOR.01.06.05.01
Page 14 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic QC
Summary

Uranium Resources Inc. ACZ Project ID: L1 2277
N-NITROSODI-N-PROPYLAMINE U ug/Kg -300 300
N-NITROSODIPHENYLAMINE U ug/Kg -300 300
PENTACHLOROPHENOL U ug/Kg -2000 2000
PHENANTHRENE U ug/Kg -300 300
PHENOL U ug/Kg -700 700
PYRENE U ug/Kg -300 300
2,4,6-TRIBROMOPHENOL (surr) % 81.5 35 125
2-FLUOROBIPHENYL (surr) % 85.9 45 105
2-FLUOROPHENOL (surr) % 77.9 35 105
NITROBENZENE-D5 (surr) % 85.3 35 100
PHENOL-D6 (surr) % 79.9 40 100
TERPHENYL-D14 (surr) % 98.5 30 125
REPOR.01.06.05.01
Page 15 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Uranium Resources Inc.
Organic Extended
Qualifier Report
ACZ Project ID: L12277

ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION
L12277-01 WG344791 *All Compounds*
1,2,4-Trichlorobenzene
1,4-Dichlorobenzene
2,4,6-Tribromophenol
2,4-Dinitrotoluene
2-Chlorophenol
2-Fluorobiphenyl
2-Fluorophenol
4-Chloro-3-methylphenol
4-Nitrophenol
Acenaphthene
Nitrobenzene-d5
N-Nitrosodi-n-propylamine
N-Nitrosodiphenylamine
Pentachlorophenol
Phenol
Phenol-d6
M8270C GC/MS D1 Sample required dilution due to matrix.
M8270C GC/MS Q6 Sample was received above recommended temperature.
M8270C GC/MS S8 The sample required a dilution such that the surrogate
recovery calculation does not provide useful information.
The recovery for the associated control sample was
acceptable.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit
N18270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable) was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
REPAD.15.06.05.01
Page 16 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Organic Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: L1 2277

ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION
Pyrene
Terphenyl-d14
WG344520 *All Cornpounds*
of the sample and/or the spike was less than the reporting
limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable)
was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting limit.
M8270C GC/MS MD The spike recovery (and spike duplicate RPD, if applicable) was not used for data validation because the concentration
of the sample and/or the spike was less than the reporting
limit.
M3540 D1 Sample required dilution due to matrix.
REPAD.15.06.05.01
Page 17 of 26
Measure Date Prep Date Result Error(+/-) LLD Units XQ Analyst
Lead 210 (3050)
Eichrom
Parameter
Lead 210 (3050) 06/17/13 17:25
Prep Method
240 7.9 14 pCi/g thf
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
RadioChemistry
Analytical Results

Uranium Resources Inc. ACZ Sample ID: L12277-01
Project ID: Pond Mat. Char./K13-5355 Date Sampled: 05/23/13 1145
Sample ID: IRON CAKE Date Received: 05/24/13
Locator: Sample Matrix: Sediment
Radium 226 + Alpha Emitting Radium Isotopes (3050) Prep Method:
M9315
Parameter Measure Date Prep Date Result Error(+/-) LLD Units XQ Analyst
Radium 226 + Alpha 06/27/13 13:46 730 12 1.6 pCi/g thf
Thorium, Isotopic (3050) Prep Method:
ESM 4506
Parameter Measure Date Prep Date Result Error(+/-) LLD Units XQ Analyst
Thorium 228 06/26/13 0:02 0.29 0.69 0.36 pCi/g thf
Thorium 230 06/26/13 0:02 35 2.6 0.94 pCi/g thf
Thorium 232 06/26/13 0:02 1.91 0.66 0.36 pCi/g thf
Uranium, Isotopic (3050) Prep Method:
Eichrom ACW03
Parameter Measure Date Prep Date Result Error(+/-) LLD Units XQ Analyst
Uranium 234 07/16/13 0:02 22000 730 46 pCi/g thf
Uranium 235 07/16/13 0:02 1900 220 46 pCi/g thf
Uranium 238 07/16/13 0:02 28300 830 46 pCi/g thf
REPRC.02.06.05.01 * Please refer to Qualifier Repods for details.
Page 18 of 26
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Radiochemistry
Reference

Report Header Explanations
Batch A distinct set of samples analyzed at a specific time
Error(+/-) Calculated sample specific uncertainty
Found Value of the QC Type of interest
Limit Upper limit for RPD, in %.
LCL Lower Control Limit, in % (except for LCSS, mg/Kg)
LLD Calculated sample specific Lower Limit of Detection
PCN/SCN A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
PQL Practical Quantitation Limit
QC True Value of the Control Sample or the amount added to the Spike
Rec Amount of the true value or spike added recovered, in % (except for LCSS, mg/Kg)
RER Relative Error Ratio, calculation used for Dup. QC taking into account the error factor.
RPD Relative Percent Difference, calculation used for Duplicate QC Types
UCL Upper Control Limit, in % (except for LCSS, mg/Kg)
Sample Value of the Sample of interest
DUP Sample Duplicate MS/MSD Matrix Spike/Matrix Spike Duplicate
LCSS Laboratory Control Sample - Soil PBS Prep Blank - Soil
LCSW Laboratory Control Sample - Water PBW Prep Blank - Water
QC Sample Type Explanations
Blanks Verifies that there is no or minimal contamination in the prep method procedure.
Control Samples Verifies the accuracy of the method, including the prep procedure.
Duplicates Verifies the precision of the instrument and/or method.
Matrix Spikes Determines sample matrix interferences, if any.
ACZ Qualifiers (Qual)
Analysis exceeded method hold time.
Method Prefix Reference
EPA methodology, including those under SDWA, CWA, and RCRA
SM Standard Methods for the Examination of Water and Wastewater.
ASTM
RP DOE
ESM DOE/ESM
mer
(1) Solid matrices are reported on a dry weight basis.
(2) Preparation method: "Method" indicates preparation defined in analytical method.
(3) QC results calculated from raw data. Results may vary slightly if the rounded values are used in the calculations.
(4) An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification
qualifier associated with the result.
For a complete list of ACZ's Extended Qualifiers, please click: http://www.acz.com/publiclextquallist.pdf
REP003.09.12.01
Page 19 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Radiochemistry QC
Summary

Uranium Resources Inc. ACZ Project ID: L12277
Lead 210 (3050) Eichrom Units: pCi/g
ACZ ID Type Analyzed PCN/SCN QC Sample Error LLD Found Error LLD Rec Lower Upper RPOIRER Limit Qual
WG345882
L12277-01MS MS 06/17/13 RC120601-1 69.19 240 7.9 14 250 8 15 14.5 55 121 M2
L12277-01DUP DUP-RPD 06/17/13 240 7.9 14 200 7 13 18.2 20
L12277-01DUP DUP-RER 06/17/13 240 7.9 14 200 7 13 3.79 2 RN
WG345268LCSS LCSS 06/17/13 RC120601-1 70.57 78 4.8 12 110.5 55 121
WG345268PBS PBS 06/17/13 8 4 2 15 30
Radium 226 + Alpha Emitting Radium M9315 Units: pCi/g
ACZ ID Type Analyzed PCN/SCN QC Sample Error LLD Found Error LLD Rec Lower Upper RPD/RER Limit Qual
WG346615
WG345436PB5 PBS 06/27/13 .11 0.32 1.6 3.2
WG345436LCSS LCSS 06/27/13 RC130227-2 47.83 48 3.2 1.8 100.4 66 132
L12277-01DUP DUP-RER 06/27/13 730 12 1.6 620 11 1.9 6 76 2 RN
L12277-01DUP DUP-RPD 06/27/13 730 12 1.6 620 11 1.9 16 3 20
L12277-01MS MS 06/27/13 RC130227-2 47.83 730 12 1.6 600 12 2.1 -271.8 66 132 M3
Thorium 228 ESM 4506 Units: pCi/g
ACZ ID Type Analyzed PCN/SCN QC Sample Error LLD Found Error LLD Rec Lower Upper RPD/RER Limit Qual
WG346490
WG345268PB5 PBS 06/26/13 -.25 0.36 0.24 0.48
L12277-01DUP DUP-RER 06/26/13 0.29 0.69 0.36 1.4 0.68 0.36 1.15 2
REPRC.01.06.05.01
Page 20 of 26
WG347674
WG347136PBS PBS 07/16/13 .22 0.28 0.21
WG347136LCSS LCSS 07/16/13 PCN41962 39.2 36 2.6 0.35 91.8 77
L12277-01DUP DUP-RER 07/16/13 22000 730 46 12000 680 62
L12277-01MS MS 07/16/13 PCN41962 392 22000 730 46 15000 890 82 -1785.7 77
Uranium 235 Eichrom ACW03
ACZ 10 Type Analyzed PCN/SCN QC Sample Error LLD Found Error LLD Rec Lower
WG347136PBS PBS 07/16/13 .1 0.13 0.21
WG347136LC55 LCSS 07/16/13 PCN41962 1.79 1.7 0.55 0.35 95 42
L12277-01DUP DUP-RER 07/16/13 1900 220 46 600 200 62
L12277-01MS MS 07/16/13 PCN41962 17.92 1900 220 46 800 250 82 -6138.4 42
0.42
136
4.37 2 RC
136 M3
0.42
122
10.02 2 RC
122 M3
Units: pCi/g
Upper RPD/RER Limit Qual
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Radiochemistry QC
Summary

Uranium Resources Inc. ACZ Project ID: L12277
Thorium 230 ESM 4506 Units: pCi/g
ACZ ID Type Analyzed PCN/SCN
WG346490
WG345268PBS PBS 06/26/13
WG345268LCSS LCSS 06/26/13 RC111214-1
L12277-01DUP DUP-RER 06/26/13
L12277-01MS MS 06/26/13 RC111214-1
Thorium 232 ESM 4506
ACZ ID Type Analyzed PCN/SCN
WG346490
QC Sample Error L.LD Found
162.12
162.12
35
35
2.6
2.6
0.94
0.94
.03
160
36
170
QC Sample Error LLD Found
Error LLD Rec Lower Upper RPD/RER Limit Qual
0.28 0.64 1.28
4.5 0.63 98.7 91 126
2.6 0.94 0.27 2
5.6 0.92 83.3 91 126 M2
Units: pCi/g
Error LLD Rec Lower Upper RPD/RER Limit Qual
WG345268PBS PBS 06/26/13 -.08 0.18 0.24 0.48
L12277-01DUP DUP-RER 06/26/13 1.91 0.66 0.36 .65 0.47 0.36 1.55 2
Uranium 234 Eichrom ACW03 Units: pCi/g
ACZ ID Type Analyzed PCN/SCN QC Sample Error LLD Found Error LLD Rec Lower Upper RPD/RER Limit Qua!
WG347674
REPRC.01.06.05.01
Page 21 of 26
ADZ Laboratories, Inc. Radiochemistry QC
Summary 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Project ID: L12277
Uranium 238 Eichrom ACWO3 Units: pCi/g
ACZ ID Type Analyzed PCN/SCN QC Sample Error LLD Found Error LLD Rec Lower Upper RPDIRER Limit Qual
WG347674
WG347136PBS PBS 07/16/13 .17 0.25 0.21 0 42
WG347136LCSS LCSS 07/16/13 PCN41962 39 39.7 2.7 0.35 101.8 87 124
L12277-01DUP DUP-RER 07/16/13 28300 830 46 14400 770 62 12 28 2 RC
L12277-01MS MS 07/16/13 PCN41962 390 28300 830 46 18300 980 82 -2564.1 87 124 M3
REPRC.01.06.05.01
Page 22 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

RadChem Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: L12277

ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION

L12277-01 WG345882 Lead 210 (3050) Eichrom M2 Matrix spike recovery was low, the recovery of the
associated control sample (LCS or LFB) was acceptable.
Eichrom RN Sample concentration is greater than 5x LLD; RPD was
used for data validation. Replicate Error Ratio (RER) is
greater than 2. Precision judged to be in control.
WG346615 Radium 226 + Alpha Emitting Radium M9315 M3 The spike recovery value is unusable since the analyte

Isotopes (3050) concentration in the sample is disproportionate to the spike
level. The recovery of the associated control sample (LCS
or LFB) was acceptable.
M9315 RN Sample concentration is greater than 5x LLD; RPD was
used for data validation. Replicate Error Ratio (RER) is
greater than 2. Precision judged to be in control.

WG346490 Thorium 230 ESM 4506 M2 Matrix spike recovery was low, the recovery of the
associated control sample (LCS or LFB) was acceptable.

WG347674 Uranium 234 Eichrom ACW03 D1 Sample required dilution due to matrix.
Eichrom ACW03 M3 The spike recovery value is unusable since the analyte
concentration in the sample is disproportionate to the spike level. The recovery of the associated control sample (LCS
or LFB) was acceptable.
Eichrom ACW03 N1 See Case Narrative.
Eichrom ACW03 RC For a solid matrix, the matrix duplicate precision
assessment (RPD or RER) exceeded the control limit,
which is attributable to the non-homogeneity of the sample.

Uranium 235 Eichrom ACW03 D1 Sample required dilution due to matrix.
Eichrom ACW03 M3 The spike recovery value is unusable since the analyte
concentration in the sample is disproportionate to the spike
level. The recovery of the associated control sample (LCS
or LFB) was acceptable.
Eichrom ACW03 N1 See Case Narrative.
Eichrom ACW03 RC For a solid matrix, the matrix duplicate precision
assessment (RPD or RER) exceeded the control limit, which is attributable to the non-homogeneity of the sample.

Uranium 238 Eichrom ACW03 D1 Sample required dilution due to matrix.
Eichrom ACW03 M3 The spike recovery value is unusable since the analyte
concentration in the sample is disproportionate to the spike
level. The recovery of the associated control sample (LCS
or LFB) was acceptable.
Eichrom ACW03 N1 See Case Narrative.
Eichrom ACW03 RC For a solid matrix, the matrix duplicate precision
assessment (RPD or RER) exceeded the control limit,
which is attributable to the non-homogeneity of the sample.
REPAD.15.06.05.01
Page 23 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Certification
Qualifiers

Uranium Resources Inc. ACZ Project ID: L12277
Radiochemistry
The following parameters are not offered for certification or are not covered by NELAC certificate #ACZ.
Lead 210 (3050) Eichrom
Thorium 228 ESM 4506
Thorium 230 ESM 4506
Thorium 232 ESM 4506
Uranium 234 Eichrom ACW03
Uranium 235 Eichrom ACW03
Uranium 238 Eichrom ACW03
Soil Analysis
The following parameters are not offered for certification or are not covered by NELAC certificate #ACZ.
Solids, Percent CLPSOW390, PART F, D-98
REPAD.05.06.05.01
Page 24 of 26
X
X
X
X
X
X
X
INN
X
X
X
X
X
X
X
X
X
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Sample
Receipt

Uranium Resources Inc.
Pond Mat. Char./K13-5355

ACZ Project ID: L12277
Date Received: 05/24/2013 09:51

Received By: ksj

Date Printed: 5/28/2013
Receipt Verification
YES NO NA
1) Is a foreign soil permit included for applicable samples?
2) Is the Chain of Custody or other directive shipping papers present?
3) Does this project require special handling procedures such as CLP protocol?
4) Are any samples NRC licensable material?
5) If samples are received past hold time, proceed with requested short hold time analyses?
6) Is, the Chain of Custody complete and accurate?
7) Were any changes made to the Chain of Custody prior to ACZ receiving the samples?
Sarnples/Containers
YES NO NA
8) Are all containers intact and with no leaks?
9) Are all labels on containers and are they intact and legible?
10) Do the sample labels and Chain of Custody match for Sample ID, Date, and Time?
11) For preserved bottle types, was the pH checked and within limits?
12) Is there sufficient sample volume to perform all requested work?
13) Is the custody seal intact on all containers?
14) Are samples that require zero headspace acceptable?
15) Are all sample containers appropriate for analytical requirements?
16) Is there an Hg-1631 trip blank present?
17) Is there a VOA trip blank present?
18) Were all samples received within hold time?
Chain of Custody Related Remarks
Client Contact Remarks
Shipping Containers
Cooler Id Temp (°C) Rad (pR/Hr) Custody Seal Intact?
NA17656

18.9 110 Yes
Was ice present in the shipment container(s)?
No - Wet or gel ice was not present in the shipment container(s).
Client must contact an ACZ Project Manager if analysis should not proceed for samples received
outside of their thermal preservation acceptance criteria.
REPAD LPII 2012-03
Page 25 of 26
1
11115
=...---
--••••-•141 ara-C4
2773 Dotent
Name:
-7102 Laboratories,
CO 80487
Inc;s4Ciap2.02 ()P7
Address: 641 E FM 1118
a I 1 Mee Steamboat '
Joshua Holland
company: URI, Inc. Kingsville, TX 78363
E-mall: knholluld@uraniumresources-com Telephone: [phone]
Name: Jim Kegebein mat ickegebektauraniumresources.com
Company: URI, Inc. Telephone: [phone]
Name:
HT remains
short
neither
even if HT
Address: 405 State Highway 121 Bypass, Building A, Suite 110
Company: URI, Inc. Lewisville, Texas 75067
E-mail: Telephone: [phone]
if sarnple(s) received past holding time (HT), or if insufficient
analysis before expiration, shall ACZ proceed with requested
# *NO" then ACZ wilt contact client for further instruction. if
s indicated, ACZ will proceed with the requested snares.
to complete
HT analyses?
'YEW nor "NO"
is expired, and data will be qualified.
YES Lg
NO
Are samples for CO DW Compliance Monitoring?
lf yes, please include state forms. Results will be raported to
Quote #: POND-SEDIMENT
POL.
; c
15 a
YES
NO
Pr.:lied/PO #: Pond Material Char./ K13-5355
Reportiny state for compliance testing: Texas
Sampler's Name: Joshua Holland
Are any sam les NRC licensable material? Yes No
ron Cake 5/23/2013 : 11:45 SO 3
,
1'
,
I
s tAmtrix SW (Surtimos Water) • CNN (Ground Water)
MISS PAW 10 ACZIS
Joshua Holland 4 41.—/i
• WW (Wale Water) • OW
*OM & COnditiOna
5/23/2013 : 1400
(Drinking Waw) - Sl. (Sludge) • SO (Soil) • 01. (ON) • Other
kidded On #111 MOM Side of this COC.
(Spedfy)
FRMAD050.01.15.09 White - Return with sample. YeNow - Retainlr your records.
Page 26 of 26
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Analytical
Report

April 09, 2014
Report to:
Joshua Holland
Uranium Resources Inc.
405 State Highway 121 Bypass A110
Lewisville, TX 75067
cc: Jim Kegebein
Bill to:
Terry Blaszak
Uranium Resources Inc.
6950 S. Potomac Street
Suite 300
Centannial, CO 80112
Project ID: KCD iron cake charactization/K
ACZ Project ID: L17505
Joshua Holland:
Enclosed are the analytical results for sample(s) submitted to ACZ Laboratories, Inc. (ACZ) on March 28,
2014. This project has been assigned to ACZ's project number, L17505. Please reference this number in all
future inquiries.
All analyses were performed according to ACZ's Quality Assurance Plan. The enclosed results relate only to
the samples received under L17505. Each section of this report has been reviewed and approved by the
appropriate Laboratory Supervisor, or a qualified substitute.
Except as noted, the test results for the methods and parameters listed on ACZ's current NELAC certificate
letter (#ACZ) meet all requirements of NELAC.
This report shall be used or copied only in its entirety. ACZ is not responsible for the consequences arising
from the use of a partial report.
All samples and sub-samples associated with this project will be disposed of after May 09, 2014. If the
samples are determined to be hazardous, additional charges apply for disposal (typically $11/sample). If you
would like the samples to be held longer than ACZ's stated policy or to be returned, please contact your Project
Manager or Customer Service Representative for further details and associated costs. ACZ retains analytical
raw data reports for ten years.
If you have any questions or other needs, please contact your Project Manager.
Sue Webber has reviewed and
approved this report.
ACC AC I

:74

L17505-1404091154 Page 1 of 15
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
inorganic Analytica
Results

Uranium Resources Inc. ACZ Sample ID: 07505-01
Project ID: KCD iron cake charactizatio Date Sampled: 03/27/14 /5:35
Sample ID: IRON CAKE A Date Received: 03/28/14
Sample Matrix: Soil
Organic Prep
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
BNA TCLP Extraction M1311 & 3520 1 500 mL 04/02/14 14:11 rjv
Soil Preparation
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
BNA TCLP Extraction M1311 04/01/14 8:03 spl
REPIN.02.06.05.01 * Please refer to Qualifier Reports for details.
L17505-1404091154 Page 2 of 15
• ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Inorganic Analytical
Results

Uranium Resources Inc. ACZ Sample ID: L17505-02
Project ID: KCD iron cake charactizatio Date Sampled: 03/27/14 15:40
Sample ID: IRON CAKE B Date Received: 03/28/14
Sample Matrix: Soil
Organic Prep
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
BNA TCLP Extraction M1311 & 3520 1 500 mL 04/02/14 14:13 rjv
Soil Preparation
Parameter EPA Method Dilution Result Qual XQ Units MDL PQL Date Analyst
BNA TCLP Extraction M1311 04/01/14 13:45 spl
REPIN.02.06.05.01 * Please refer to Qualifier Reports for details.
L17505-1404091154 Page 3 of 15
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Inorganic
Reference

Report eade xplanations
Batch
Found
Limit
Lower
MDL
PCN/SCN
PQL
QC
Rec
RPD
Upper
Sample
A distinct set of samples analyzed at a specific time
Value of the QC Type of interest
Upper limit for RPD, in %.
Lower Recovery Limit, in % (except for LCSS, mg/Kg)
Method Detection Limit. Same as Minimum Reporting Limit. Allows for instrument and annual fluctuations.
A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
Practical Quantitation Limit, typically 5 times the MDL.
True Value of the Control Sample or the amount added to the Spike
Recovered amount of the true value or spike added, in % (except for LCSS, mg/Kg)
Relative Percent Difference, calculation used for Duplicate QC Types
Upper Recovery Limit, in % (except for LCSS, mg/Kg)
Value of the Sample of interest
QC Sample Types
AS Analytical Spike (Post Digestion) LCSWD Laboratory Control Sample - Water Duplicate
ASD Analytical Spike (Post Digestion) Duplicate LFB Laboratory Fortified Blank
CCB Continuing Calibration Blank LFM Laboratory Fortified Matrix
CCV Continuing Calibration Verification standard LFMD Laboratory Fortified Matrix Duplicate
DUP Sample Duplicate LRB Laboratory Reagent Blank
ICB Initial Calibration Blank MS Matrix Spike
ICV Initial Calibration Verification standard MSD Matnx Spike Duplicate
ICSAB Inter-element Correction Standard - A plus B solutions PBS Prep Blank - Soil
LCSS Laboratory Control Sample - Soil PBW Prep Blank - Water
LCSSD Laboratory Control Sample - Soil Duplicate PQV Practical Quantitation Verification standard
LCSW Laboratory Control Sample - Water SDL Serial Dilution
QC Sample Type Explanations
Blanks
Control Samples
Duplicates
Spikes/Fortified Matrix
Standard
Verifies that there is no or minimal contamination in the prep method or cal bration procedure.
Verifies the accuracy of the method, including the prep procedure.
Verifies the precision of the instrument and/or method.
Determines sample matrix interferences, if any.
Verifies the validity of the calibration.
ACZ Qualifiers (Quail
Analyte concentration detected at a value between MDL and POL. The associated value is an estimated quantity.
Analysis exceeded method hold time. pH is a field test with an immediate hold time
Target analyte response was below the laboratory defined negative threshold.
The material was analyzed for, but was not detected above the level of the associated value_
The associated value is either the sample quantitation limit or the sample detection limit.
Method References
(1)
(2)
(3)
(4)
(5)
Comments
(1)
(2)
(3)
(4)
(5)
EPA 600/4-83-020. Methods for Chemical Analysis of Water and Wastes, March 1983.
EPA 600/R-93-100. Methods for the Determination of Inorganic Substances in Environmental Samples, August 1993.
EPA 600/R-94-111. Methods for the Determination of Metals in Environmental Samples - Supplement I, May 1994.
EPA SW-846. Test Methods for Evaluating Solid Waste.
Standard Methods for the Examination of Water and Wastewater.
QC results calculated from raw data. Results may vary slightly if the rounded values are used in the calculations.
Soil, Sludge, and Plant matrices for Inorganic analyses are reported on a dry weight basis.
Animal matrices for Inorganic analyses are reported on an "as received" basis.
An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification qualifier
associated with the result.
If the MDL equals the PQL or the MDL column is omitted, the PQL is the reporting limit.
For a complete list of ACZ's Extended Qualifiers, please click: ht://www.acz.comlpublic/extqualIist.pdf
REP001.09.12.01
L17505-1404091154 Page 4 of 15
•
ACZ Laboratories, Inc.

Inorganic Extended
Qualifier Report 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Project ID: L17505
ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION
L17505-01 WG361650 BNA TCLP Extraction M1311 & 3520 D1 Sample required dilution due to matrix.
L17505-02 WG361650 BNA TCLP Extraction M1311 & 3520 D1 Sample required dilution due to matrix.
REPAD.15.06.05.01
L17505-1404091154 Page 5 of 15
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Organic Analytical
Results

Uranium Resources Inc. ACZ Sample ID: L17505-01
Project ID: KCD iron cake charactizatio Date Sampled: 03/27/14 15:35
Sample ID: IRON CAKE A Date Received: 03/28/14
Sample Matrix: Soil
BNA Extract., !les (TCLP) by GC/MS
Analysis Method: M8270C GC/MS
Extract Method: M1311 & 3520
Work rou : WG361900
Analyst: itk
Extract Date: 04/02/14 14:11
Analysis Date: 04/08/14 1:43
Compound CAS Result QUAL Dilution XQ Units MDL PQL
1,4-Dichlorobenzene 106-46-7 u 2 . mg/L 0.004 0.02
2,4 ,5-Trichlorophen ol 95-95-4 U 2 * mg/L 0.02 0.1
2,4 ,6-Trichlorophen ol 88-06-2 U 2 * mg/L 0.004 0.02
2,4-Din itrotoluene 121-14-2 U 2 * mg/L 0.004 0.02
2-Methylphenol 95-48-7 U 2 * mg/L 0.004 0.02
3- & 4-Methylphenol 1319-77-3 U 2 * mg/L 0.008 0.04
Hexachlorobenzene 118-74-1 U 2 * mg/L 0.004 0.02
Hexachlorobutadiene 87-68-3 U 2 * mg/L 0.004 0.02
Hexachloroethane 67-72-1 U 2 * mg/L 0.004 0.02
Nitrobenzene 98-95-3 U 2 * mg/L 0.004 0.02
Pentachlorophenol 87-86-5 U 2 * mg/L 0.02 0.1
Pyridine 110-86-1 U 2 * mg/L 0.008 0.04
Surrogate Recoveries CAS % Recovery Dilution XQ Units LCL UCL
2,4,6-Tribromophenol 118-79-6 99.2 2 40 125
2-Fluorobiphenyl 321-60-8 82.6 2 50 110
2-Fluorophenol 367-12-4 81.4 2 54 100
Nitrobenzene-d5 4165-60-0 86.7 2 40 110
Phenol-d6 13127-88-3 86.1 2 47 113
Terphenyl-d14 1718-51-0 89.2 2 50 135
REPOR.01.01.01.02 * Please refer to Qualifier Reports for details.
L17505-1404091154 Page 6 of 15
• ADZ Laboratories, Inc.

Organic Analytical
Results 2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Uranium Resources Inc. ACZ Sample ID: L17505-02
Project ID: KCD iron cake charactizatio Date Sampled: 03/27/14 15:40
Sample ID: IRON CAKE B Date Received: 03/28/14
Sample Matrix: Soil
BNA Extractables (TCLP) by GC/MS
Analysis Method: M8270C GC/MS
Extract Method: M1311 & 3520
Work. rou WG361900
Analyst: itk
Extract Date: 04/02/14 14:13
Analysis Date: 04/08/14 2:51
Compound CAS Result QUAL Dilution XQ Units MDL PQL
1,4-Dichlorobenzene 106-46-7 2 mg/L 0.004 0.02
2,4,5-Trichlorophenol 95-95-4 2 mg/L 0.02 0.1
2,4,6-Trichlorophenol 88-06-2 2 mg/L 0.004 0.02
2,4-Dinitrotoluene 121-14-2 2 mg/L 0.004 0.02
2-Methylphenol 95-48-7 2 mg/L 0.004 0.02
3- & 4-Methylphenol 1319-77-3 2 mg/L 0.008 0.04
Hexachlorobenzene 118-74-1 2 mg/L 0.004 0.02
Hexachlorobutadiene 87-68-3 2 mg/L 0.004 0.02
Hexachloroethane 67-72-1 2 mg/L 0.004 0.02
Nitrobenzene 98-95-3 2 mg/L 0.004 0.02
Pentachlorophenol 87-86-5 2 mg/L 0.02 0.1
Pyridine 110-86-1 2 mg/L 0.008 0.04
Surrogate Recoveries CAS % Recovery Dilution XQ Units LCL UCL
2,4,6-Tribromophenol 118-79-6 94.6 2 40 125
2-Fluorobiphenyl 321-60-8 83.2 2 50 110
2-Fluorophenol 367-12-4 81.1 2 54 100
Nitrobenzene-d5 4165-60-0 88.3 2 40 110
Phenol-d6 13127-88-3 87.4 2 47 113
Terphenyl-d14 1718-51-0 86.8 2 50 135
REPOR.01.01.01.02 * Please refer to Qualifier Reports for details.
L17505-1404091154 Page 7 of 15
ACZ Laboratories, Inc.
2773 Downhill Dfive Steamboat Springs, CO 80487 [phone]
Organic
Reference

Report Header Explanations
Batch A distinct set of samples analyzed at a specific time
Found Value of the QC Type of interest
Limit Upper limit for RPD, in %.
Lower Lower Recovery Limit, in % (except for LCSS, mg/Kg)
LCL Lower Control Limit
MDL Method Detection Limit Same as Minimum Reporting Limit. Allows for instrument and annual fluctuations.
PCN/SCN A number assigned to reagents/standards to trace to the manufacturer's certificate of analysis
PQL Practical Quantitation Limit, typically 5 times the MDL.
QC True Value of the Control Sample or the amount added to the Spike
Rec Arnount of the true value or spike added recovered, in % (except for LCSS, mg/Kg)
RPD Relative Percent Difference, calculation used for Duplicate QC Types
Upper Upper Recovery Limit, in % (except for LCSS, mg/Kg)
UCL Upper Control Limit
Sample Value of the Sample of interest
OC Sample Types
SURR
INTS
DUP
LCSS
LCSW
LFB
Surrogate
Internal Standard
Sample Duplicate
Laboratory Control Sample Soil
Laboratory Control Sample Water
Laboratory Fortified Blank
LFM
LFMD
LRB
MS/MSD
PBS
PBW
Laboratory Fortified Matrix
Laboratory Fortified Matrix Duplicate
Laboratory Reagent Blank
Matrix Spike/Matrix Spike Duplicate
Prep Blank - Soil
Prep Blank - Water
QC Sample Type Explanations
Blanks Verifies that there is no or minimal contamination in the prep method or calibration procedure.
Control Samples Verifies the accuracy of the method, including the prep procedure.
Duplicates Verifies the precision of the instrument and/or method.
Spikes/Fortified Matrix Determines sample matrix interferences, if any.
ACZ Qualifiers (Qual)
Analyte concentration detected at a value between MDL and PQL. The associated value is an estimated quantity.
O Analyte concentration is estimated due to result exceeding calibration range.
Analysis exceeded method hold time. pH is a field test with an immediate hold time.
Analyte concentration detected at a value between MDL and PQL. The associated value is an estimated quantity.
Target analyte response was below the laboratory defined negative threshold.
The material was analyzed for, but was not detected above the level of the associated value.
The associated value is either the sample quantitation limit or the sample detection limit.
Method References
(1)
(2)
(3)
(4)
(5)
Comments
(1)
(2)
(3)
(4)
EPA 600/4-83-020. Methods for Chemical Analysis of Water and Wastes, March 1983.
EPA 600/4-90/020. Methods for the Determination of Organic Compounds in Drinking Water (I), July 1990.
EPA 600/R-92/129. Methods for the Determination of Organic Compounds in Drinking Water (II), July 1990.
EPA SW-846. Test Methods for Evaluating Solid Waste.
Standard Methods for the Examination of Water and Wastewater.
QC results calculated from raw data. Results may vary slightly if the rounded values are used in the calculations.
Excluding Oil & Grease, solid & biological matrices for organic analyses are reported on a wet weight basis.
An asterisk in the "XQ" column indicates there is an extended qualifier and/or certification qualifier
associated with the result.
If the MDL equals the PQL or the MDL column is omitted, the PQL is the reporting limit
For a complete list of ACZ's Extended Qualifiers, please click: httn://www.acz.corn/nublic/extqual I ist.pdf
REP002.09.12.01
L17505-1404091154 Page 8 of 15
QC
50
50
75
• ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Organic QC
Summary

Uranium Resources Inc. ACZ Project ID: L17505
BNA Extractables (TCLP) by GC/MS M8270C GC/MS
WG361900
MS Sample ID: L17384-01MS PCN/SCN: BNA140324-2-50 Analyzed: 04/08/14 1:09
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
100
120
115
125
110
100
110
113
135
1,4-DICHLOROBENZENE
2,4-DINITROTOLUENE
PENTACHLOROPHENOL
2,4,6-TRIBROMOPHENOL (surr)
2-FLUOROBIPHENYL (surr)
2-FLUOROPHENOL (surr)
NITROBENZENE-D5 (surr)
PHENOL-D6 (surr)
TERPHENYL-014 (surr)
100 U 75 ug/L 75.0 30
100 U 89.9 ug/L 89.9 50
150 U 140 ug/L 93.3 40
% 100.2 40
% 89.3 50
% 84.8 54
% 92.5 40
% 90.4 47
% 74.6 50
DUP Sample ID: L17505-01DUP Analyzed: 04/08/14 2:17
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,4-DICHLOROBENZENE u U ug/L 20 RA
2,4,5-TRICHLOROPHENOL U U ug/L 20 RA
2,4,6-TRICHLOROPHENOL U U ug/L 20 RA
2,4-DINITROTOLUENE U U ug/L 20 RA
2-METHYLPHENOL U u ug/L 20 RA
3- & 4-METHYLPHENOL u u ug/L 20 RA
HEXACHLOROBENZENE U u ug/L 20 RA
HEXACHLOROBUTADIENE U u ug/L 20 RA
HEXACHLOROETHANE u U ug/L 20 RA
NITROBENZENE u U ug/L 20 RA
PENTACHLOROPHENOL U U ug/L 20 RA
2,4,6-TRIBROMOPHENOL (surr) % 103.2 40 125 RA
2-FLUOROBIPHENYL (surr) % 88.0 50 110 RA
2-FLUOROPHENOL (surr) % 83.4 54 100 RA
NITROBENZENE-D5 (surr) % 92.7 40 110 RA
PHENOL-D6 (surr) % 91.4 47 113 RA
TERPHENYL-D14 (surr) % 88.3 50 135 RA
LCSW Sample ID: WG361650LCSW PCN/SCN: BNA140324-2-10 Analyzed: 04/07/14 22:53

Compound
1,4-DICHLOROBENZENE
2,4-DINITROTOLUENE
PENTACHLOROPHENOL
2,4,6-TRIBROMOPHENOL (surr)
2-FLUOROBIPHENYL (surr)
2-FLUOROPHENOL (surr)
NITROBENZENE-D5 (surr)
PHENOL-06 (surr)
TERPHENYL-D14 (surr)
Sample Found Units Rec Lower Upper RPD Limit Qual
33.4 ug/L 66.8 30 100
42 ug/L 84.0 50 120
55 ug/L 73.3 40 115
84.6 40 125
% 79.5 50 110
% 75.7 54 100
% 80.1 40 110
% 80.1 47 113
88.1 50 135
L17505-1404091154 Page 9 of 15
• ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Organic QC
Summary

Uranium Resources Inc. ACZ Project ID: L17505
LCSWD Sample ID: WG361650LCSWD PCN/SCN: BNA140324-2-10 Analyzed: 04/07/14 23:27
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,4-DICHLOROBENZENE 50 35 ug/L 70.0 30 100 4.7 20
2,4-DINITROTOLUENE 50 42.2 ug/L 84.4 50 120 0.5 20
PENTACHLOROPHENOL 75 56 ug/L 74.7 40 115 1.8 20
2,4,6-TRIBROMOPHENOL (surr) 87.4 40 125
2-FLUOROBIPHENYL (surr) 84.8 50 110
2-FLUOROPHENOL (surr) 78.9 54 100
NITROBENZENE-D5 (surr) 84.3 40 110
PHENOL-D6 (surr) 83.9 47 113
TERPHENYL-D14 (surr) 90.0 50 135
PBW Sample ID: WG361650PBW Analyzed: 04/07/14 22:19
Compound QC Sample Found Units Rec Lower Upper RPD Limit Qual
1,4-DICHLOROBENZENE ug/L -10 10
2,4,5-TRICHLOROPHENOL ug/L -50 50
2,4,6-TRICHLOROPHENOL ug/L -10 10
2,4-DINITROTOLUENE ug/L -10 10
2-METHYLPHENOL ug/L -10 10
3- & 4-METHYLPHENOL ug/L -20 20
HEXACHLOROBENZENE ug/L -10 10
HEXACHLOROBUTADIENE ug/L -10 10
HEXACHLOROETHANE ug/L -10 10
NITROBENZENE ug/L -10 10
PENTACHLOROPHENOL ug/L -50 50
2,4,6-TRIBROMOPHENOL (surr) 82.8 40 125
2-FLUOROBIPHENYL (surr) 82.8 50 110
2-FLUOROPHENOL (surr) 80.9 54 100
NITROBENZENE-D5 (surr) 83.0 40 110
PHENOL-06 (surr) 84.5 47 113
TERPHENYL-D14 (surr) 89.1 50 135
L17505-1404091154 Page 10 of 15
•
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Organic Extended
Qualifier Report

Uranium Resources Inc. ACZ Project ID: 07505

ACZ ID WORKNUM PARAMETER METHOD QUAL DESCRIPTION
L17505-01 WG361900 *All Compounds*
WG361650
L17505-02 WG361900 *All Compounds*
WG361650
M8270C GC/MS
M1311 & 3520
RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
D1 Sample required dilution due to matrix.
M8270C GC/MS RA Relative Percent Difference (RPD) was not used for data
validation because the sample concentration is too low for
accurate evaluation (< 10x MDL).
M1311 & 3520 D1 Sample required dilution due to matrix.
REPAD.15.06.05.01
L17505-1404091154 Page 11 of 15
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]

Certification
Qualifiers

Uranium Resources Inc. ACZ Project ID: L17505
GC/MS
The following parameters are not offered for certification or are not covered by NELAC certificate #ACZ.
Pyridine M8270C GUMS
REPAD.05.06.05.01
L17505-1404091154 Page 12 of 15
•
ACZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Uranium Resources Inc.
KCD iron cake charactization/K14-5585
Sample
Receipt
ACZ Project ID: L17505
Date Received: 03/28/2014 09:53
Received By: ear
Date Printed: 3/28/2014
Receipt Verification
1) Is a foreign soil permit included for applicable samples?
2) Is the Chain of Custody or other directive shipping papers present?
3) Does this project require special handling procedures such as CLP protocol?
4) Are any samples NRC licensable material?
5) If samples are received past hold time, proceed with requested short hold time analyses?
6) Is the Chain of Custody complete and accurate?
7) Were any changes made to the Chain of Custody prior to ACZ receiving the samples?
8) Is the sampler attestation statement signed?
NA
X
X
X
X
X
X
YES NO
Samples Containers
YES NO NA
9) Are all containers intact and with no leaks?
10) Are all labels on containers and are they intact and legible?
11) Do the sample labels and Chain of Custody match for Sample ID, Date, and Time?
12) For preserved bottle types, was the pH checked and within limits?
13) Is there sufficient sample volume to perform all requested work?
14) Is the custody seal intact on all containers?
15) Are samples that require zero headspace acceptable?
16) Are all sample containers appropriate for analytical requirements?
17) Is there an Hg-1631 trip blank present?
18) Is there a VOA trip blank present?
19) Were all samples received within hold time?
X
X
X
X
X
X
X
X
X
X
Chain of Cus ody Related Remarks
The sample authenticity statement on ACZ's COC was not signed by the sampler. The State of Nevada requires this
statement to be signed for any samples used to determine compliance with regulations. If this presents a problem for the
intended data use, please contact your project manager immediately. ACZ will continue with scheduled analyses unless
directed otherwise.
Client Contact Remarks
Shipping Containers
Cooler Id Temp (°C) Rad (uR/Hr) Custody Seal Intact?
NA19371

2.6 100 Yes
Was ice present in the shipment container(s)?
Yes - Wet ice was present in the shipment container(s).
REPAD LPII 2012-03
L17505-1404091154 Page 13 of 15
ADZ Laboratories, Inc.
2773 Downhill Drive Steamboat Springs, CO 80487 [phone]
Sample
Receipt

Uranium Resources Inc. ACZ Project ID: L17505
KCD iron cake charactization/K14-5585 Date Received: 03/28/2014 09:53
Received By: ear
Date Printed: 3/28/2014
Client must contact an ACZ Project Manager if analysis should not proceed for samples received
outside of their thermal preservation acceptance criteria.
REPAD LPII 2012-03
L17505-1404091154 Page 14 of 15
unimmorif) grommave...
ADZ Laboratories, Inc. CUSTODY tt..5 CHAIN of
2773 Downhill Drive Steamboat Springs, CO 80487 (800) 334-549
Name: Joshua Holland Address: 641 E FM 1118
Company: URI, Inc. Kingsville, TX 78363
[e-mail] Telephone: [phone]
P (,1'
Name: Jim Kegebein E-mail: ickegebeinAuraniumresources.com
Company: URI, Inc. Telephone: [phone]
Name: Address: 6950 S. Potomac Street, Suite 300
Company: URI, Inc. Centennial, CO 80112
E-mail: Telephone: [phone] Fax: [phone]
If sample(s) received past holding time (HT), or if insufficient HT remains to complete YES I X
analysis before expiration, shall ACZ proceed with requested short HT analyses? NO
If "NO" then ACZ will contact client for further instruction. If neither
's indicated, ACZ will proceed with the requested analyses, even if HT
"YET nor "NO"
is expired, and data will be qualified.
Are samples for CO DW Compliance Monitoring? YES
If yes, please include state forms. Results will be reported to PQL. NO
CT IN.: (-)F•;^.1;\ r k ,,N ,-,%f,1 -:F , r '1. J 1 !, ., '.", -'
Quote #: 0
Project/PO #: KVD iron cake charactization/K14-5585 15 o c 0 >
Reporting state for compliance testing: Texas '613 Z Cr) Sampler's Name: Joshua Holland o o a.
Are any samples NRC licensable material? Yes No •13 _,
0 c:. \ .1PLE DLNHHCA DIJE TILIE í 1 1--
Iron Cake A 2014-3-27 : 15:35 SO 1 IC
Iron Cake B 2014-3-27 : 15:40 SO
Matrix SW (Surface Water) • GW Ground Water) - WW (Waste Water) - DW (Drinking Wate ) • SL (Sludge) - SO (Soil) • OL (Oil) • Other (Specify)
Priority- Need ASAP
Keep dilutions to a minimum.
Please refer to ACZ's terms & conditions located on the reverse side of this COC.
kf L It. 'A ,I ,H( 1_, f: Y 1,,,L -rIUE- KL.,.Lr.L I, ', t if ti 11',Ir
- Joshua Holland r 2014-03-27 : 17:00 4
FRMAD050.01.15.09 White - Retum with sample. Yellow - Retain for your records.
L17505-1404091154 Page 15 of 15
GEL Luoratories LLC

a member of The GEL Group INC PO Box 30712 Charleston, SC 29417
2040 Savage Road Charleston, SC 29407
P 843.566.8171 F 843.766.1178
www.gel.com
May 15, 2015
Joshua Holland
Uranium Resources
URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Re: Iron Cake Analysis
Work Order: 371623
Dear Joshua Holland:
GEL Laboratories, LLC (GEL) appreciates the opportunity to provide the enclosed analytical results for the
sample(s) we received on April 23, 2015. This revised data report has been prepared and reviewed in accordance
with GEL's standard operating procedures.
Our policy is to provide high quality, personalized analytical services to enable you to meet your analytical needs
on time every time. We trust that you will find everything in order and to your satisfaction. If you have any
questions, please do not hesitate to call me at [phone], ext. 4707.
Sincerely,
AvNtut.C,Dati---
Anna Day
Project Manager
Purchase Order: K15-5783
Enclosures

11111111111111111

11

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report
for
URII001 URI, Inc.
Client SDG: 371623 GEL Work Order: 371623
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
** Analyte is a Tracer compound
** Analyte is a surrogate compound
B The target analyte was detected in the associated blank.
J Value is estimated
N Metals--The Matrix spike sample recovery is not within specified control limits
U Analyte was analyzed for, but not detected above the MDL, MDA, or LOD.
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless qualified on the Certificate of Analysis.
The designation ND, if present, appears in the result column when the analyte concentration is not detected above
the limit as defmed in the 'U' qualifier above.
This data report has been prepared and reviewed in accordance with GEL Laboratories LLC
standard operating procedures. Please direct any questions to your Project Manager, Anna Day.
..kentia,;Deut--
Reviewed by
age 2 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address :
Contact:
Project:
URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Joshua Holland
Iron Cake Analysis
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Moisture:
Feed Sample 1
371623001
Soil
22-APR-15 09:15
23-APR-15
Client
61.9%
Project: URII00115
Client ID: URII001
3arameter Qualifier Result DL RL Units DF Analyst Date Time Batch Method
4ercury Analysis-CVAA
AV846 7471B Mercury in Solid "Dry Weight Corrected"
lercury U ND 10.2 30.6 ug/kg 1 MTM1 04/29/15 1131 1474670 1
4etals Analysis-ICP
M846 3050B/6010C Solid "Dry Weight Corrected"
ssenic 3910000 12800 77000 ug/kg 10 LS 04/27/15 1547 1473747 2
4rium 49700 2570 12800 ug/kg 10
elenium 341000 12800 77000 ug/kg 10
:admium U ND 12800 64200 uWkg 50 LS 04/28/15 1101 1473747 3
:hromium 495000 19200 64200 ug/kg 50
,ead 187000 42300 128000 ug/kg 50
ilver U ND 12800 64200 uWkg 50
4etals Analysis-ICP-MS
AV846 3050B/6020A Solid "Dry Weight Corrected"
irconium 11500 253 5050 ug/kg 2 BCD1 05/01/15 2157 1473731 4
Tranium 142000000 3340 10100 ug/kg 200 BCD1 05/05/15 1454 1473731 5
-on 360000000 334000 1010000 ug/kg 40 BCD1 04/29/15 2220 1473731 6
Rolybdenum 5120000 3030 10100 ug/kg 40
;emi-Volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
,1'-Biphenyl U ND 262 873 ug/kg 1 RMB 04/29/15 0051 1474500 7
,2,4,5-Tetrachlorobenzene U ND 262 873 uWkg 1
,2,4-Trichlorobenzene U ND 262 873 ug/kg 1
,2-Dichlorobenzene U ND 262 873 ug/kg 1
,2-Diphenylhydrazine U ND 262 873 ug/kg 1
,3,5-Trinitrobenzene U ND 262 873 ug/kg 1
,3-Dichlorobenzene U ND 262 873 uWkg 1
,4-Dichlorobenzene U ND 262 873 uWkg 1
,4-Dinitrobenzene U ND 262 873 ug/kg 1
,4-Dioxane u ND 262 873 ug/kg 1
,4-Naphthoquinone U ND 262 873 ug/kg 1
-Methylnaphthalene U ND 26.2 87.3 ug/kg 1
-Naphthylamine U ND 262 873 ug/kg 1
,3,4,6-Tetrachlorophenol U ND 262 873 ug/kg 1
,3-Dichloroaniline U ND 262 873 ug/kg 1
,4,5-Trichlorophenol U ND 262 873 ug/kg 1
,4,6-Trichlorophenol U ND 262 873 ug/kg 1
age 3 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
;emi-Volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
,4-Dichlorophenol u ND 262 873 ug/kg 1
,4-Dimethylphenol u ND 262 873 ug/kg 1
,4-Dinitrophenol U ND 262 1750 ug/kg 1
,4-Dinitrotoluene u ND 262 873 ug/kg 1
,6-Dichlorophenol u ND 262 873 ug/kg 1
,6-Dinitrotoluene U ND 262 873 ug/kg 1
-Acetylaminofluorene u ND 262 873 ug/kg 1
-Chloronaphthalene u ND 26.2 87.3 ug/kg 1
-Chlorophenol u ND 262 873 ug/kg 1
-Ethoxyethanol u ND 873 4360 ug/kg 1
-Methy1-4,6-dinitrophenol u ND 262 873 ug/kg 1
-Methylnaphthalene U ND 26.2 87.3 ug/kg 1
-Naphthylamine u ND 262 873 ug/kg 1
-Nitrophenol u ND 262 873 ug/kg 1
-Picoline U ND 262 873 ug/kg 1
,3'-Dichlorobenzidine u ND 262 873 ug/kg 1
,3'-Dimethylbenzidine u ND 262 873 ug/kg 1
-Methylcholanthrene u ND 262 873 ug/kg 1
,4'-Methylenebis(2-chloroaniline) U ND 873 4360 ug/kg 1
-Aminobiphenyl u ND 262 873 ug/kg 1
.-Bromophenylphenylether u ND 262 873 ug/kg 1
-Chloro-3-methylphenol u ND 349 873 ug/kg 1
-Chloroaniline u ND 262 873 ug/kg 1
--Chlorophenylphenylether u ND 262 873 ug/kg 1
.-Nitrophenol U ND 262 873 ug/kg 1
-Nitroquinoline-l-oxide U ND 262 873 ug/kg 1 ,-Nitro-o-toluidine u ND 262 873 ug/kg 1
',12-Dimethylbenz(a)anthracene u ND 262 873 ug/kg 1
c.enaphthene U ND 26.2 87.3 ug/kg 1
Wenaphthy1ene u ND 26.2 87.3 ug/kg 1
cetophenone u ND 262 873 ug/kg 1
Wiline u ND 262 873 ug/kg 1
Wthracene U ND 26.2 87.3 ug/kg 1
Ummite U ND 262 873 ug/g 1
grazine u ND 349 873 ug/kg 1
3enzaldehyde u ND 262 873 ug/kg 1
age 4 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample I Project: URII00115
Sample ID: 371623001 Client ID: URII001
;emi-volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
)enzo(a)anthracene u ND 26.2 87.3 ug/kg 1
)enzo(a)pyrene u ND 26.2 87.3 ug/kg 1
)enzo(b)fluoranthene u ND 26.2 87.3 ug/kg 1
lenzo(ghi)perylene u ND 26.2 87.3 ug/kg 1
lenzo(k)fluoranthene U ND 26.2 87.3 ug/kg 1
lenzyl alcohol U ND 262 873 ug/kg 1
lutylbenzylphthalate u ND 262 873 ug/kg 1
aprolactam u ND 262 873 ug/kg 1
;arbazole u ND 26.2 87.3 ug/kg 1
llorobenzilate u ND 262 873 ug/kg 1
lrysene U ND 26.2 87.3 ug/kg 1
)i-n-butylphthalate U ND 262 873 ug/kg 1
)i-n-octylphthalate U ND 262 873 ug/kg 1
Nallate U ND 262 873 ug/kg 1
)ibenzo(a,e)pyrene u ND 262 873 ug/kg 1
)thenzo(a,h)anthracene U ND 26.2 87.3 ug/kg 1
)ibenzofuran U ND 262 873 ug/kg 1
Nethylphthalate U ND 262 873 ug/kg 1
)imethoate U ND 262 873 ug/kg 1
)imethylphthalate U ND 262 873 ug/kg 1
)inoseb u ND 262 873 ug/kg 1
)iphenylamine u ND 262 873 ug/kg 1
Nsulfoton U ND 262 873 ug/kg 1
7.,thy1 Methanesulfonate u ND 262 873 ug/kg 1
3,thy1 methacrylate u ND 262 873 ug/kg 1
7amphur u ND 262 873 ug/kg 1
quoranthene u ND 26.2 87.3 ug/kg 1
quorene U ND 26.2 87.3 ug/kg 1
Texachlorobenzene U ND 262 873 ug/kg 1
iexachlorobutadiene U ND 262 873 ug/kg 1
Texachlorocyclopentadiene u ND 262 873 ug/kg 1
Texachloroethane u ND 262 873 ug/kg 1
Texachloropropene u ND 262 873 ug/kg 1
Tydroxymethyl phthalimide u ND 262 873 ug/kg 1
ndeno(1,2,3-cd)pyrene u ND 26.2 87.3 ug/kg 1
sodrin u ND 175 873 ug/kg 1
age 5 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company :
Address : URI, Inc.
641 East FM 1118 Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Report Date: May 15, 2015
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
;emi-volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Thy Weight Corrected"
sophorone U ND 262 873 ug/kg 1
sosafrole u ND 262 873 ug/kg 1
:epone U ND 262 873 ug/kg 1
ilethapyrilene U ND 262 873 ug/kg 1
Aethoxychlor U ND 262 873 ug/kg 1
Aethyl methacrylate U ND 262 873 ug/kg 1
/lethyl methanesulfonate U ND 262 873 ug/kg 1
i1ethyl parathion U ND 262 873 ug/kg 1
4-Methyl-N-nitrosomethylamine U ND 262 873 ug/kg 1
4-Nitrosodi-n-butylamine U ND 262 873 ug/kg 1
J-Nitrosodiethylamine U ND 262 873 ug/kg 1
4-Nitrosodipropylamine U ND 262 873 ug/kg 1
4-Nitrosomethylethylamine U ND 262 873 ug/kg 1
4-Nitrosomorpholine U ND 262 873 ug/kg 1
4-Nitrosopiperidine U ND 262 873 ug/kg 1
4-Nitosopyrrolidine U ND 262 873 ug/kg 1
Iaphthalene U ND 26.2 87.3 ug/kg 1
fitrobenzene U ND 262 873 ug/kg 1
'arathion U ND 262 873 ug/kg 1
'entachlorobenzene U ND 262 873 ug/kg 1
'entachloroethane U ND 262 873 ug/kg 1
'entachloronitrobenzene U ND 262 873 ug/kg 1
'entachlorophenol U ND 262 873 ug/kg 1
'henacetin U ND 262 873 ug/kg 1
'henanthrene U ND 26.2 87.3 ug/kg 1
'henol U ND 262 873 ug/kg 1
'horate U ND 262 873 ug/kg 1
'hthalic Anhydride U ND 1400 4360 ug/kg 1
'ronamide U ND 262 873 ug/kg 1
'yrene U ND 26.2 87.3 ug/kg 1
'yridine U ND 262 873 ug/kg 1
afrole U ND 262 873 ug/kg 1
411fotepp U ND 262 873 ug/kg 1
'hionazin U ND 262 873 ug/kg 1
'ributylphosphate U ND 262 873 ug/kg 1
'riethylphosphorothioate U ND 262 873 ug/kg
t.
1
age 6 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company :
Address : URI, Inc. 641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Report Date: May 15, 2015
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
;emi-Volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
,a-Dimethylphenethylamine U ND 305 873 ug/kg 1
1pha-Terpineol U ND 262 873 ug/kg 1
is(2-Chloro-1-methylethypether U ND 262 873 ug/kg 1
is(2-Chloroethoxy)methane U ND 262 873 ug/kg 1
is(2-Chloroethyl) ether U ND 262 873 ug/kg 1
is(2-Ethylhexyl)phthalate U ND 262 873 ug/kg 1
1,p-Creso1s U ND 262 873 ug/kg 1
1-Dinitrobenzene u ND 262 873 ug/kg 1
i-Nitroaniline U ND 262 873 ug/kg 1
t-Toluidine U ND 262 873 ug/kg 1
-Decane U ND 262 873 ug/kg 1
-Octadecane U ND 262 873 ug/kg 1
-Cresol U ND 262 873 ug/kg 1
-Nitroaniline U ND 288 873 ug/kg 1
-Toluidine U ND • 262 873 ug/kg 1
-(Dimethylamino)azobenzene U ND 262 873 ug/kg 1
-Benzoquinone U ND 524 1750 ug/kg 1
-Nitroaniline U ND 262 873 ug/kg 1
-Phenylenediamine U ND 8730 43600 ug/kg 1
-Toluidine U ND 262 873 ug/kg 1
knzoic acid U ND 436 1750 ug/kg 1 AGS1 04/28/15 2337 1474500 8
lexachlorophene u ND 10100 43600 ug/kg 1
/olatile Organics
/olatiles SW846 8260B Solid "Dry Weight Corrected"
,1,1,2-Tetrachloroethane U ND 0.450 1.35 ug/kg 1 GRB2 05/06/15 1810 1476574 9
,1,1-Trichloroethane U ND 0.450 1.35 ug/kg 1
,1,2,2-Tetrachloroethane U ND 0.450 1.35 ug/kg 1
,1,2-Trichloroethane U ND 0.450 1.35 ug/kg 1
,1-Dichloroethane U ND 0.450 1.35 ug/kg 1
,1-Dichloroethylene U ND 0.450 1.35 ug/kg 1
,1-Dichloropropene U ND 0.450 1.35 ug/kg 1
,2,3-Trichlorobenzene U ND 0.450 1.35 ug/kg 1
,2,3-Trichloropropane U ND 0.450 1.35 ug/kg 1
,2,4-Trichlorobenzene U ND 0.450 1.35 ug/kg 1
,2,4-Trimethylbenzene U ND 0.450 1.35 ug/kg 1
,2-Dibromo-3-chloropropane U ND 0.676 1.35 ug/kg 1
age 7 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
folatile Organics
r olatiles SW846 8260B Solid "Dry Weight Corrected"
,2-Dibromoethane U ND 0.450 1.35 ug/kg 1
,2-Dichlorobenzene u ND 0.450 1.35 ug/kg 1
,2-Dichloroethane u ND 0.450 1.35 ug/kg 1
,2-Dichloropropane U ND 0.450 1.35 ug/kg 1
,3,5-Trimethylbenzene U ND 0.450 1.35 ug/kg 1
,3-Dichlorobenzene U ND 0.450 1.35 ug/kg 1
,3-Dichloropropane U ND 0.450 1.35 ug/kg 1
,4-Dichlorobenzene U ND 0.450 1.35 ug/kg 1
,4-Dioxane U ND 22.5 67.6 ug/kg 1
,2-Dichloropropane U ND 0.450 1.35 ug/kg 1
-Butanone U ND 2.25 6.76 ug/kg 1
-Chloro-1,3-butadiene U ND 0.450 1.35 ug/kg 1
-Chloroethylvinyl ether U ND 2.25 6.76 ug/kg 1
-Chlorotoluene U ND 0.450 1.35 ug/kg 1
-Hexanone U ND 2.25 6.76 ug/kg 1
-Nitropropane U ND 2.25 6.76 ug/kg 1
-Pentanone U ND 4.51 13.5 ug/kg 1
-Chlorotoluene U ND 0.450 1.35 ug/kg 1
-Isopropyltoluene U ND 0.450 1.35 ug/kg 1
-Methyl-2-pentanone u ND 2.25 6.76 ug/kg 1
Lcetone U ND 2.25 6.76 ug/kg 1
Lcetonitrile U ND 11.3 33.8 ug/kg 1
Lcrolein U ND 2.25 6.76 ug/kg 1
Lcrylonitrile U ND 2.25 6.76 ug/kg 1
Lily! chloride U ND 2.25 6.76 ug/kg 1
lenzene U ND 0.450 1.35 ug/kg 1
lenzyl chloride U ND 2.25 6.76 ug/kg 1
lromobenzene U ND 0.450 1.35 ug/kg 1
Iromochloromethane U ND 0.450 1.35 ug/kg 1
lromodichloromethane U ND 0.450 1.35 ug/kg 1
lromoform U ND 0.450 1.35 ug/kg 1
lromomethane U ND 0.450 1.35 ug/kg 1
;arbon disulfide U ND 2.25 6.76 ug/kg 1
:arbon tetrachloride U ND 0.450 1.35 ug/kg 1
llorobenzene U ND 0.450 1.35 ug/kg 1
lloroethane U ND 0.450 1.35 ug/kg 1
age 8 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc. 641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
/Waffle Organics
/olatiles SW846 8260B Solid "Dry Weight Corrected"
llorofonn U ND 0.450 1.35 ug/kg 1
lloromethane U ND 0.450 1.35 ug/kg 1
;yclohexane U ND ' 0.450 1.35 ug/kg 1
;yclohexanone U ND 22.5 67.6 ug/kg 1
tibromochloromethane U ND 0.450 1.35 ug/kg 1
hbromomethane u ND 0.450 1.35 ug/kg 1
tichlorodifluoromethane U ND 0.450 1.35 ug/kg 1
Ihyl acetate U ND 2.25 6.76 ug/kg 1
Ihyl ether U ND 0.450 1.35 ug/kg 1
Ihyl methacrylate U ND 2.25 6.76 ug/kg 1
bylbenzene U ND 0.450 1.35 ug/kg 1
lexachlorobutadiene u ND 0.450 1.35 ug/kg 1
Dclomethane U ND 2.25 6.76 ug/kg 1
mbutyl alcohol U ND 22.5 67.6 ug/kg 1
sopropylbenzene U ND 0.450 1.35 ug/kg 1
4ethaciylonitrile U ND 2.25 6.76 ug/kg 1
4ethy1 acetate U ND 2.25 6.76 ug/kg 1
4ethy1 methacrylate u ND 2.25 6.76 ug/kg 1
4ethy1cyc1ohexane U ND 0.450 1.35 ug/kg 1
4ethy1ene chloride u ND 2.25 6.76 ug/kg 1
1aphthalene u ND 0.450 1.35 ug/kg 1
'entachloroethane U ND 2.25 6.76 ug/kg 1
topionitrile U ND 2.25 6.76 ug/kg 1
tyrene U ND 0.450 1.35 ug/kg 1
'etrachloroethylene U ND 0.450 1.35 ug/kg 1
'etrahydrofuran U ND 2.25 6.76 ug/kg 1
bluene u ND 0.450 1.35 ug/kg 1
'richloroethylene U ND 0.450 1.35 ug/kg 1
'fichlorofluoromethane U ND 0.450 1.35 ug/kg 1
'richlorotrifluoroethane U ND 2.25 6.76 ug/kg 1
!idyl acetate u ND 2.25 6.76 ug/kg 1
finyl chloride Ux ND 0.450 1.35 ug/kg 1
Cylenes (total) U ND 1.35 4.06 ug/kg 1
is(2-Chloro-1-methylethypether U ND 2.25 6.76 ug/kg 1
is-1,2-Dichloroethylene , is-1,3-Dichloropropylene
u u ND
ND
0.450
0.450
1.35
1.35
ug/kg
ug/kg
1
1
age 9 of 52
GEL LABORATORIES LL1P
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
folatile Organics
folatiles SW846 8260B Solid "Dry Weight Corrected"
is-1,4-Dichloro-2-butene U ND 2.25 6.76 ug/kg 1
1,p-Xy1enes U ND 0.902 2.70 ug/kg 1
-Butyl alcohol U ND 22.5 67.6 ug/kg 1
-Butylbenzene U ND 0.450 1.35 ug/kg 1
-Propylbenzene u ND 0.450 1.35 ug/kg 1
-Xylene U ND 0.450 1.35 ug/kg 1
:.c-Butylbenzene U ND 0.450 1.35 ug/kg 1
xt-Butyl Alcohol U ND 22.5 67.6 ug/kg 1
xt-Butyl methyl ether U ND 0.450 1.35 ug/kg 1
:rt-Butylbenzene U ND 0.450 1.35 ug/kg 1
-ans-1,2-Dichloroethylene U ND 0.450 1.35 ug/kg 1
ms-1,3-Dichloropropylene U ND 0.450 1.35 ug/kg 1
•ans-1,4-Dichloro-2-butene U ND 2.25 6.76 ug/kg 1
rbe following Prep Methods were performed:
iIethod Description Analyst Date Time Prep Batch
W846 3050B ICP-MS 3050BS PREP JP1 04/24/15 1130 1473730
W846 3050B SW846 3050B Prep for 6010C JP1 04/23/15 1956 1473746
W846 3541 Prep Method 3541 8270D BNA for Soil MXD2 04/28/15 1230 1474499
.W846 5030 Volatile 5030 Solid Prep JEB 05/06/15 0915 1476573
.W846 7471B Prep SW846 7471B Mercury Prep Soil AXS5 04/28/15 1521 1474669
The following Analytical Methods were performed:
vlethod Description Analyst Comments
5W846 7471B
SW846 3050B/6010C
5W846 3050B/6010C
SW846 3050B/6020A
SW846 3050B/6020A
SW846 3050B/6020A
SW846 3541/8270D
5W846 3541/8270D
5W846 8260B
;urrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
-Fluorobiphenyl 8270D/3541 BNA Soil Automated Soxhlet "Dry 2370 ug/kg 4360 54.3 (25%400%)
age 10 of 52
GEL LABORATORIES LLO
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address :
Contact:
Project:
URI, Inc.
641 East FM 1118 Kingsville, Texas 78363
Joshua Holland
Iron Cake Analysis
Client Sample ID: Feed Sample 1 Project: URII00115
Sample ID: 371623001 Client ID: URII001
urrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Weight Corrected"
fitrobenzene-d5 8270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected" 2280 ug/kg 4360 52.2 (21%403%)
-Terphenyl-d14 8270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected" 3460 ug/kg 4360 79.2 (31%-124%)
,4,6-Tribromophenol 8270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected" 6080 ug/kg 8730 69.7 (20%-122%)
-Fluorophenol 8270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected" 5200 ug/kg 8730 59.6 (23%-107%)
henol-d5 8270D/3541 BNA Soil Automated Soxhlet "Dry
Weight Corrected"
5750 ug/kg 8730 65.9 (25%408%)
,2-Dichloroethane-d4 Volatiles SW846 8260B Solid "Dry Weight
Corrected"
83.2 ug/kg 50.0 123 (70%428%)
;romofluorobenzene Volatiles 5W846 8260B Solid "Dry Weight
Corrected"
72.0 ug/kg 50.0 106 (63%438%)
bluene-d8 Volatiles SW846 8260B Solid "Dry Weight
Corrected"
69.8 ug/kg 50.0 103 (80%420%)
iotes:
age 11 of 52
GEL LABORATORIES LA
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address :
Contact:
Project:
URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Joshua Holland
Iron Cake Analysis
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Moisture:
Feed Sample 2
371623002
Soil
22-APR-15 09:19
23-APR-15
Client
60.3%
Project: URII00115
Client ID: URII001
'arameter Qualifier Result DL RL Units DF Analyst Date Time Batch Method
4ercury Analysis-CVAA
W846 7471B Mercury in Solid "Dry Weight Corrected"
lercury 281 8.67 25.9 ug/kg 1 MTM1 04/29/15 1132 1474670 1
4etals Analysis-ICP
AV846 3050B/6010C Solid "Dry Weight Corrected"
menic 3190000 12400 74200 ug/kg 10 LS 04/27/15 1559 1473747 2
;arium 58400 2470 12400 ug/kg 10
elenium 351000 12400 74200 ug/kg 10
!admium U ND 12400 61800 ug/kg 50 L S 04/28/15 1113 1473747 3
Irom ium 405000 18600 61800 ug/kg 50
ead 138000 40800 124000 ug/kg 50
ilver U ND 12400 61800 ug/kg 50
4etals Analysis-ICP-MS
V846 3050B/6020A Solid "Dry Weight Corrected"
irconium 9670 241 4820 ug/kg 2 BCD1 05/01/15 2217 1473731 4
Tranium 126000000 3180 9650 ug/kg 200 BCD1 05/05/15 1511 1473731 5
-on 315000000 318000 965000 ug/kg 40 BCD1 04/29/15 2240 1473731 6
4olybdenum 4360000 2890
lemi-Volatile-GC/MS
9650 ug/kg 40
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
,1'-Biphenyl ND 252 839 ug/kg 1 RMB 04/29/15 0129 1474500 7
,2,4,5-Tetrachlorobenzene ND 252 839 ug/kg 1
,2,4-Trichlorobenzene ND 252 839 ug/kg 1
,2-Dichlorobenzene ND 252 839 ug/kg 1
,2-Diphenylhydrazine ND 252 839 ug/kg 1
,3,5-Trinitrobenzene ND 252 839 ug/kg 1
,3-Dichlorobenzene ND 252 839 ug/kg 1
,4-Dichlorobenzene ND 252 839 ug/kg 1
,4-Dinitrobenzene ND 252 839 ug/kg 1
,4-Dioxane ND 252 839 ug/kg 1
,4-Naphthoquinone ND 252 839 ug/kg 1
-Methylnaphthalene ND 25.2 83.9 ug/kg 1
-Naphthylamine ND 252 839 ug/kg 1
,3,4,6-Tetrachlorophenol ND 252 839 ug/kg 1
,3-Dichloroaniline ND 252 839 ug/kg 1
,4,5-Trichlorophenol ND 252 839 ug/kg 1
,4,6-Trichlorophenol ND 252 839 ug/kg 1
age 12 of 52
GEL LABORATORIES LLO
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Report Date: May 15, 2015
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
.emi-Volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
,4-Dichlorophenol u ND 252 839 ug/kg 1
,4-Dimethylphenol U ND 252 839 ug/kg 1
,4-Dinitrophenol u ND 252 1680 ug/kg 1
,4-Dinitrotoluene u ND 252 839 ug/kg 1
,6-Dichlorophenol u ND 252 839 ug/kg 1
,6-Dinitrotoluene u ND 252 839 ug/kg 1
-Acetylaminofluorene u ND 252 839 ug/kg 1
-Chloronaphthalene U ND 25.2 83.9 ug/kg 1
-Chlorophenol u ND 252 839 ug/kg 1
-Ethoxyethanol u ND 839 4200 ug/kg 1
-Methy1-4,6-dinitrophenol u ND 252 839 ug/kg 1
-Methylnaphthalene u ND 25.2 83.9 ug/kg 1
-Naphthylamine u ND 252 839 ug/kg 1
-Nitrophenol u ND 252 839 ug/kg 1
-Picoline U ND 252 839 ug/kg 1
,3'-Dichlorobenzidine U ND 252 839 ug/kg 1
,3'-Dimethylbenzidine u ND 252 839 ug/kg 1
-Methylcholanthrene u ND 252 839 ug/kg 1
,4'-Methylenebis(2-chloroaniline) U ND 839 4200 ug/kg 1
-Aminobiphenyl u ND 252 839 ug/kg 1
-Bromophenylphenylether u ND 252 839 ug/kg 1
-Chloro-3-methylphenol U ND 336 839 ug/kg 1
-Chloroaniline U ND 252 839 ug/kg 1
-Chlorophenylphenylether u ND 252 839 ug/kg 1
-Nitrophenol u ND 252 839 ug/kg 1
-Nitroquinoline-1-oxide u ND 252 839 ug/kg 1
-Nitro-o-toluidine u ND 252 839 ug/kg 1
,12-Dimethylbenz(a)anthracene u ND 252 839 ug/kg 1
xenaphthene u ND 25.2 83.9 ug/kg 1
Lcenaphthy1ene u ND 25.2 83.9 ug/kg 1
.cetophenone u ND 252 839 ug/kg 1
ailine u ND 252 839 ug/kg 1
sithracene U ND 25.2 83.9 ug/kg 1
samite u ND 252 839 ug/kg 1
Arazine u ND 336 839 ug/kg 1
enzaldehyde U ND 252 839 ug/kg 1
age 13 of 52
GEL LABORATORIES LAP
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Report Date: May 15, 2015
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
;emi-yolatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Thy Weight Corrected"
lenzo(a)anthracene U ND 25.2 83.9 ug/kg 1
lenzo(a)pyrene U ND 25.2 83.9 ug/kg 1
tenzo(b)fluoranthene U ND 25.2 83.9 ug/kg 1
lenzo(ghi)perylene U ND 25.2 83.9 ug/kg 1
lenzo(k)fluoranthene U ND 25.2 83.9 ug/kg 1
lenzyl alcohol u ND 252 839 ug/kg 1
lutylbenzylphthalate U ND 252 839 ug/kg 1
;aprolactam U ND 252 839 ug/kg 1
;arbazole U ND 25.2 83.9 ug/kg 1
llorobenzilate U ND 252 839 ug/kg 1
lrysene U ND 25.2 83.9 ug/kg 1
)i-n-butylphthalate U ND 252 839 ug/kg 1
N-n-octylphthalate U ND 252 839 ug/kg 1
Xallate U ND 252 839 ug/kg 1
Mbenzo(a,e)pyrene U ND 252 839 ug/kg 1
Xbenzo(a,h)anthracene u ND 25.2 83.9 ug/kg 1
Xbenzofuran U ND 252 839 ug/kg 1
Nethylphthalate u ND 252 839 ug/kg 1
hmethoate U ND 252 839 ug/kg 1
Xrmethylphthalate u ND 252 839 ug/kg 1
)inoseb U ND 252 839 ug/kg 1
Mphenylamine U ND 252 839 ug/kg 1
Nsulfoton u ND 252 839 ug/kg 1
thyl Methanesulfonate U ND 252 839 ug/kg 1
:thyl methacrylate u ND 252 839 ug/kg 1
'amphur U ND 252 839 ug/kg 1
luoranthene U ND 25.2 83.9 ug/kg 1
borene U ND 25.2 83.9 ug/kg 1
{exachlorobenzene U ND 252 839 ug/kg 1
fexachlorobutadiene u ND 252 839 ug/kg 1
Iexachlorocyclopentadiene U ND 252 839 ug/kg 1
fexachloroethane U ND 252 839 ug/kg 1
fexachloropropene U ND 252 839 ug/kg 1
fydroxymethyl phthalimide U ND 252 839 ug/kg 1
ndeno(1,2,3-cd)pyrene U ND 25.2 83.9 ug/kg 1
sodrin U ND 168 839 ug/kg 1
age 14 of 52
GEL LABORATORIES LA
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Report Date: May 15, 2015
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
;emi-Volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
wphorone U ND 252 839 ug/kg 1
3osafrole U ND 252 839 ug/kg 1
:epone U ND 252 839 ug/kg 1
4ethapyrilene U ND 252 839 ug/kg 1
4ethoxychlor U ND 252 839 ug/kg 1
4ethy1 methacrylate u ND 252 839 ug/kg 1
4ethy1 methanesulfonate U ND 252 839 ug/kg 1
4ethy1 parathion U ND 252 839 ug/kg 1
T-Methyl-N-nitrosomethy1amine U ND 252 839 ug/kg 1
1-Nitrosodi-n-butylamine U ND 252 839 ug/kg 1
1-Nitrosodiethylamine U ND 252 839 ug/kg 1
1-Nitrosodipropylamine U ND 252 839 ug/kg 1
1-Nitrosomethylethylamine U ND 252 839 ug/kg 1
T-Nitrosomorpholine U ND 252 839 ug/kg 1
I-Nitrosopiperidine U ND 252 839 ug/kg 1
1-Nitrosopyrro1idine U ND 252 839 ug/kg 1
laphthalene U ND 25.2 83.9 ug/kg 1
fitrobenzene u ND 252 839 ug/kg 1
'arathion U ND 252 839 ug/kg 1
'entachlorobenzene u ND 252 839 ug/kg 1
'entachloroethane U ND 252 839 ug/kg 1
'entachloronitrobenzene U ND 252 839 ug/kg 1
'entachlorophenol U ND 252 839 ug/kg 1
benacetin u ND 252 839 ug/kg 1
benanthrene U ND 25.2 83.9 ug/kg 1
benol U ND 252 839 ug/kg 1
%orate U ND 252 839 ug/kg 1
lithalic Anhydride U ND 1340 4200 ug/kg 1
'ronamide U ND 252 839 ug/kg 1
'yrene U ND 25.2 83.9 ug/kg 1
'yridine U ND 252 839 ug/kg 1
afrole u ND 252 839 ug/kg 1
alfotepp U ND 252 839 ug/kg 1
'hionazin u ND 252 839 ug/kg 1
'ributylphosphate U ND 252 839 ug/kg 1
'riethylphosphorothioate U ND 252 839 ug/kg 1
age 15 of 52
GEL LABORATORIES LAP
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
iemi-volatile-GC/MS
270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected"
,a-Dimethylphenethylamine U ND 294 839 ug/kg 1
Ipha-Terpineol U ND 252 839 ug/kg 1
4s(2-Chloro-1-methylethyDether u ND 252 839 ug/kg 1
lis(2-Chloroethoxy)methane u ND 252 839 ug/kg 1
ds(2-Chloroethyl) ether u ND 252 839 ug/kg 1
lis(2-EthylhexyDphthalate u ND 252 839 ug/kg 1
ri,p-Cresols u ND 252 839 ug/kg 1
ri-Dinitrobenzene U ND 252 839 ug/kg 1
ri-Nitroaniline u ND 252 839 ug/kg 1
ri-Toluidine u ND 252 839 ug/kg 1
t-Decane u ND 252 839 ug/kg 1
t-Octadecane u ND 252 839 ug/kg 1
1-Cresol u ND 252 839 ug/kg 1
r-Nitroaniline u ND 277 839 ug/kg 1
r-Toluidine u ND 252 839 ug/kg 1
1-(Dimethylamino)azobenzene U ND 252 839 ug/kg 1
r-Benzoquinone u ND 504 1680 ug/kg 1
r-Nitroaniline u ND 252 839 ug/kg 1
1-Pheny1enediamine u ND 8390 42000 ug/kg 1
1-Toluidine u ND 252 839 ug/kg 1
krioic acid u ND 420 1680 ug/kg 1 AGS1 04/29/15 0005 1474500 8
lexach1orophene u ND 9740 42000 ug/kg 1
Volatile Organics
Volatiles SW846 8260B Solid "Dry Weight Corrected"
,1,1,2-Tetrachloroethane U ND 38.5 116 ug/kg 50 GRB2 05/06/15 1839 1476574 9
,1,1-Trichloroethane u ND 38.5 116 ug/kg 50
,1,2,2-Tetrachloroethane u ND 38.5 116 ug/kg 50
,I,2-Trichloroethane U ND 38.5 116 ug/kg 50
,I-Dichloroethane U ND 38.5 116 ug/kg 50
,1-Dichloroethylene U ND 38.5 116 ug/kg 50
,1-Dichloropropene U ND 38.5 116 ug/kg 50
,2,3-Trichlorobenzene U ND 38.5 116 ug/kg 50
,2,3-Trichloropropane u ND 38.5 116 ug/kg 50
,2,4-Trichlorobenzene u ND 38.5 116 ug/kg 50
,2,4-Trimethylbenzene U ND 38.5 116 ug/kg 50
,2-Dibromo-3-chloropropane U ND 57.8 116 ug/kg 50
age 16 of 52
GEL LABORATORIES LLO
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
folatile Organics
folatiles SW846 8260B Solid "Dry Weight Corrected"
,2-Dibromoethane U ND 38.5 116 ug/kg 50
,2-Dichlorobenzene U ND 38.5 116 ug/kg 50
,2-Dichloroethane u ND 38.5 116 ug/kg 50
,2-Dichloropropane U ND 38.5 116 ug/kg 50
,3,5-Trimethylbenzene U ND 38.5 116 ug/kg 50
,3-Dichlorobenzene u ND 38.5 116 ug/kg 50
,3-Dichloropropane U ND 38.5 116 ug/kg 50
,4-Dichlorobenzene U ND 38.5 116 ug/kg 50
,4-Dioxane U ND 1930 5780 ug/kg 50
,2-Dichloropropane U ND 38.5 116 ug/kg 50
-Butanone U ND 193 578 ug/kg 50
-Chloro-1,3-butadiene U ND 38.5 116 ug/kg 50
-Chloroethylvinyl ether U ND 193 578 ug/kg 50
-Chlorotoluene U ND 38.5 116 ug/kg 50
-Hexanone U ND 193 578 ug/kg 50
-Nitropropane U ND 193 578 ug/kg 50
-Pentanone U ND 385 1160 ug/kg 50
-Chlorotoluene u ND 38.5 116 ug/kg 50
-Isopropyltoluene U ND 38.5 116 ug/kg 50
-Methy1-2-pentanone U ND 193 578 ug/kg 50
kcetone U ND 193 578 ug/kg 50
kcetonitrile U ND 963 2890 ug/kg 50
kcrolein U ND 193 578 ug/kg 50
kcrylonitrile U ND 193 578 ug/kg 50
dlyl chloride u ND 193 578 ug/kg 50
lenzene u ND 38.5 116 ug/kg 50
lenzyl chloride U ND 193 578 ug/kg 50
lromobenzene U ND 38.5 116 ug/kg 50
lromochloromethane U ND 38.5 116 ug/kg 50
lromodichloromethane U ND 38.5 116 ug/kg 50
1romoform u ND 38.5 116 ug/kg 50
komomethane u ND 38.5 116 ug/kg 50
;arbon disulfide U ND 193 578 ug/kg 50
;arbon tetrachloride u ND 38.5 116 ug/kg 50
llorobenzene U ND 38.5 116 ug/kg 50
lloroethane U ND 38.5 116 ug/kg 50
age 17 of 52
GEL LABORATORIES
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
folatile Organics
folatiles SW846 8260B Solid "Dry Weight Corrected"
lloroform U ND 38.5 116 ug/kg 50
lloromethane U ND 38.5 116 ug/kg 50
:yclohexane U ND 38.5 116 ug/kg 50
:yclohexanone U ND 1930 5780 ug/kg 50
hbromochloromethane u ND 38.5 116 ug/kg 50
hbromomethane U ND 38.5 116 ug/kg 50
hchlorodifluoromethane U ND 38.5 116 ug/kg 50
Thy! acetate u ND 193 578 ug/kg 50
Myl methacrylate U ND 193 578 ug/kg 50
bylbenzene U ND 38.5 116 ug/kg 50
lexachlorobutadiene U ND 38.5 116 ug/kg 50
adomethane u ND 193 578 ug/kg 50
mbutyl alcohol U ND 1930 5780 ug/kg 50
mpropylbenzene u ND 38.5 116 ug/kg 50
4ethacrylonitrile u ND 193 578 ug/kg 50
4ethyl acetate U ND 193 578 ug/kg 50
4ethyl methacrylate U ND 193 578 ug/kg 50
4ethy1cyc10hexane U ND 38.5 116 ug/kg 50
4ethy1ene chloride U ND 193 578 ug/kg 50
1aphtha1ene U ND 38.5 116 ug/kg 50
'entachloroethane U ND 193 578 ug/kg 50
'ropionitrile U ND 193 578 ug/kg 50
,tyrene U ND 38.5 116 ug/kg 50
'etrachloroethylene U ND 38.5 116 ug/kg 50
'etrahydrofuran U ND 193 578 ug/kg 50
'oluene U ND 38.5 116 ug/kg 50
'fichloroethylene U ND 38.5 116 ug/kg 50
•richlorofluoromethane U ND 38.5 116 ug/kg 50
'fichlorotrifluoroethane U ND 193 578 ug/kg 50
finyl acetate U ND 193 578 ug/kg 50
linyl chloride U ND 38.5 116 ug/kg 50
Cylenes (total) U ND 116 347 ug/kg 50
is(2-Chloro-1-methylethypether u ND 193 578 ug/kg 50
is-1,2-Dichloroethylene U ND 38.5 116 ug/kg 50
is-1,3-Dichloropropylene u ND 38.5 116 ug/kg 50
is-1,4-Dichloro-2-butene U ND 193 578 ug/kg 50
age 18 of 52
GEL LABORATORIES LLI
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis Report Date: May 15, 2015
Company :
Address : URI, Inc. 641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
rolatile Organics
/Wailes SW846 8260B Solid "Dry Weight Corrected"
1,p-Xy1enes U ND 77.0 231 ug/kg 50
-Butyl alcohol U ND 1930 5780 ug/kg 50
-Butylbenzene U ND 38.5 116 ug/kg 50
-Propylbenzene U ND 38.5 116 ug/kg 50
-Xylene u ND 38.5 116 ug/kg 50
tc-Butylbenzene U ND 38.5 116 ug/kg 50
:rt-Butyl Alcohol U ND 1930 5780 ug/kg 50
:rt-Butyl methyl ether U ND 38.5 116 ug/kg 50
xt-Butylbenzene U ND 38.5 116 ug/kg 50
.ans-1,2-Dichloroethylene U ND 38.5 116 ug/kg 50
ans-1,3-Dichloropropylene U ND 38.5 116 ug/kg 50
•ans-1,4-Dichloro-2-butene U ND 193 578 ug/kg 50
le following Prep Methods were performed:
/lethod Description Analyst Date Time Prep Batch
W846 3050B ICP-MS 3050BS PREP JP1 04/24/15 1130 1473730
W846 3050B SW846 3050B Prep for 6010C JP1 04/23/15 1956 1473746
W846 3541 Prep Method 3541 8270D BNA for Soil MXD2 04/28/15 1230 1474499
W846 5030 Volatile 5030 Solid Prep JEB 05/06/15 0918 1476573
W846 7471B Prep SW846 7471B Mercury Prep Soil AXS5 04/28/15 1521 1474669
The following Analytical Methods were performed:
vlethod Description Analyst Comments
SW846 7471B
SW846 3050B/6010C
SW846 3050B/6010C
SW846 3050B/6020A
SW846 3050B/6020A
SW846 3050B/6020A
SW846 3541/8270D
SW846 3541/8270D
5W846 8260B
4.urogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
-Fluorobiphenyl 8270D/3541 BNA Soil Automated Soxhlet "Dry 2360 ug/kg 4200 56.3 (25%400%) Weight Corrected"
age 19 of 52
GEL LABORATORIES Lit
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Report Date: May 15, 2015
Company :
Address : URI, Inc.
641 East FM 1118
Kingsville, Texas 78363
Contact: Joshua Holland
Project: Iron Cake Analysis
Client Sample ID: Feed Sample 2 Project: URII00115
Sample ID: 371623002 Client ID: URII001
litrobenzene-d5 8270D/3541 BNA Soil Automated Soxhlet "Dry
Weight Corrected"
2300 ug/kg 4200 54.8 (21%403%)
-Terphenyl-d14 8270D/3541 BNA Soil Automated Soxhlet "Dry
Weight Corrected" 3200 ug/kg 4200 76.3 (31%424%)
,4,6-Tribromophenol 8270D/3541 BNA Soil Automated Soxhlet "Dry
Weight Corrected" 6220 ug/kg 8390 74.1 (20%-122%)
-Fluorophenol 8270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected" 5330 ug/kg 8390 63.5 (23%-107%)
henol-d5 8270D/3541 BNA Soil Automated Soxhlet "Dry Weight Corrected" 6020 ug/kg 8390 71.7 (25°/0-108%)
,2-Dichloroethane-d4 Volatiles SW846 8260B Solid "Dry Weight Corrected" 6290 ug/kg 50.0 109 (700/o-428%)
1romof1uorobenzene Volatiles 5W846 8260B Solid "Dry Weight Corrected" 6100 ug/kg 50.0 106 (63%438%)
'oluene-d8 Volatiles 5W846 8260B Solid "Dry Weight Corrected" 6020 ug/kg 50.0 104 (8004420%)
4otes:
age 20 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
URI, Inc.
641 East FM 1118
Kingsville, Texas
Contact: Joshua Holland
Workorder: 371623
QC Summary Report Date: May 15, 2015
Page 1 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
4eta1s Analysis - ICPMS
latch 1473731
QC1203305841 371623001 DUP
:ron 360000000 286000000 ug/kg 23.1* (0%-20%) BCD1 04/29/15 22:2
Molybdenum 5120000 4180000 ug/kg 20.4* (0%-20%)
Jranium 142000000 134000000 ug/kg 6.41 (0%-20%) 05/05/15 14:5
Zirconium 11500 9130 ug/kg 22.5 A (+/-5130) 05/01/15 22:0
QC1203305840 LCS
[ron 198000 196000 ug/kg 99 (80%420%) 04/29/15 22:0
Molybdenum 4940 4650 ug/kg 94.1 (80%420%)
Uranium 4940 5530 ug/kg 112 (80°/0-120%) 05/05/15 14:5,
Zirconium 4940 5110 ug/kg 103 (80°/o-120%) 05/01/15 21:0'
QC1203305839 MB
lron U ND ug/kg 04/29/15 22:0,
Molybdenum U ND ug/kg
Uranium J 17.1 ug/kg 05/05/15 14:4
Zirconium U ND ug/kg 05/01/15 21:0
QC1203305842 371623001 MS
Iron 501000 360000000 312000000 ug/kg N/A (79/0-125%) 04/29/15 22:2
Molybdenum 12500 5120000 4260000 ug/kg N/A (75%-125%)
Uranium 12500 142000000 134000000 ug/kg N/A (75%425%) 05/05/15 15:0
Zirconium 12500 11500 21000 ug/kg 76.4 (75%425%) 05/01/15 22:0
QC1203305843 371623001 SDILT
Iron 35600 7390 ug/L 3.7 (0%-10%) 04/29/15 22:3,
Molybdenum 507 103 ug/L 1.77 (0°/0-10%)
age 21 of 52
410 GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 2 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
vletals Analysis - ICPMS
latch 1473731
Uranium
Zirconium
detals Analysis-ICP
3atch 1473747
2820
22.7 J
532
4.16
ug/L
ug/I,
5.59
8.12
(0%-10%)
(0%40%) BCD1
05/05/15 15:0
05/01/15 22:1
QC1203305878 371623001 DUP
Arsenic 3910000 3460000 ug/kg 12.2 (0°/0-20%) LS 04/27/15 15:5,
Barium 49700 39700 ug/kg 22.3 A (+/-12600)
Cadmium U ND U ND ug/kg N/A 04/28/15 11:0
Chromium 495000 390000 ug/kg 23.8* (0%-20%)
Lead 187000 142000 ug/kg 27.8 A (+1-126000)
Selenium 341000 107000 ug/kg 105*A ([phone]/27/15 15:5,
Silver U ND U ND ug/kg N/A 04/28/15 11:0
QC1203305877 LCS
Arsenic 47900 48300 ug/kg 101 (80%-120%) 04/27/15 15:2,
Barium 47900 47300 ug/kg 98.8 (80%-120%)
Cadmium 47900 48500 ug/kg 101 (80%-120%)
Chromium 47900 46900 uWkg 97.8 (80%420%)
Lead 47900 48900 ug/kg 102 (80%420%)
Selenium 47900 54500 ug/kg 114 (80%-120%)
Silver 47900 46900 ug/kg 97.8 (80°/0-120%)
QC1203305876 MB
Arsenic U ND ug/kg 04/27/15 15:2
Barium U ND ug/kg
Cadmium U ND ug/kg
Chromium U ND ug/kg
age 22 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 3 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anist Date Time
vletals Analysis-ICP
Iatch 1473747
Lead U ND ug/kg
Selenium U ND ug/kg LS 04/27/15 15:2
Silver U ND ug/kg
QC 1203305879 371623001 MS
krsenic 129000 3910000 3830000 ug/kg N/A (75%-125%) 04/27/15 15:5
Barium 129000 49700 176000 ug/kg 98.3 (75%-125%)
Cadmium 129000 U ND 102000 ug/kg 78.9 (75%-125%) 04/28/15 11:0
Chromium 129000 495000 564000 ug/kg 53.4* (75%-125%)
Lead 129000 187000 N 272000 ug/kg 66* (75%-125%)
Selenium 129000 341000 N 286000 ug/kg 0* (75%425%) 04/27/15 15:5
Silver 129000 U ND N 66300 ug/kg 51.4* (75%-125%) 04/28/15 11:0
QC1203308327 371623001 PS
Chromium 500 38.6 522 ug/L 96.7 (80%420%) 04/28/15 15:0
Lead 500 14.6 401 ug/L 77.3* (80%420%)
Selenium 500 133 583 ug/L 90 (80%-120%) 04/28/15 14:5
Silver 500 U ND 467 ug/L 93.3 (80%420%) 04/28/15 15:0
QC1203305880 371623001 SDILT
Arsenic 1520 295 ug/L 3.03 (0°/0-10%) 04/27/15 15:5.
Barium 19.4 J 3.77 ug/L 2.51 (0/0-10%)
Cadmium U ND U ND ug/L N/A (0%40%) 04/28/15 11:1,
Chromium 38.6 7.55 ug/L 2.21 (0%40%)
Lead 14.6 U ND ug/L N/A (0°4-10%)
Selenium 133 J 29.7 ug/L 11.7 (0%40%) 04/27/15 15:5,
Silver U ND U ND ug/L N/A (0°/0-10%) 04/28/15 11:1,
age 23 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 4 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
vIetals Analysis-Mercury
Iatch 1474670
QC1203308223 371622001 DUP
Vlercury 14.3 14.5 ug/kg 0.886 A (+1-14.0) MTM1 04/29/15 11:0
QC1203308222 LCS
Vlercury 106 105 ug/kg 99.2 (80%420%) 04/29/15 10:5'
QC1203308221 MB
Vlercury u ND ug/kg 04/29/15 10:5
QC1203308224 371622001 MS
V1ercury 123 14.3 143 ug/kg 104 (80%-120%) 04/29/15 11:0'
QC1203308225 371622001 SDILT
Vlercury 0.205 U ND ug/L N/A (0%40%) 04/29/15 11:1
;emi-Volatile-GC/MS
3atch 1474500
QC1203307810 LCS
1,2,4-Trichlorobenzene 1660 1150 ug/kg 69 (37%-98%) RMB 04/28/15 23:0
1,4-Dichlorobenzene 1660 1200 ug/kg 71.9 (40%410%)
2,4-Dinitrotoluene 1660 1530 ug/kg 91.8 (43°/o-109%)
2-Chlorophenol 1660 1360 ug/kg 81.9 (38%400%)
4-Ch1oro-3-methy1pheno1 1660 1380 ug/kg 82.7 (35%-104%)
4-Nitropheno1 1660 917 ug/kg 55.1 (23%414%)
Acenaphthene 1660 1300 ug/kg 78.1 (36%405%)
NI-NiVosodipropylamine 1660 1220 ug/kg 73.5 (34°/0-106%)
Pentachlorophenol 1660 992 ug/kg 59.6 (31%-93%)
Phenol 1660 1400 ug/kg 84.2 (38%-98%)
Pyrene 1660 1300 ug/kg 77.9 (33%-99%)
2,4,6-Tribromophenol 3330 2740 ug/kg 82.2 (20%-122%)
2-Fluorobiphenyl 1660 1150 ug/kg 69.2 (25%400%)
2-Fluorophenol 3330 2480 ug/kg 74.5 (23%-107%)
age 24 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 5 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
;emi-Volatile-GC/MS
Mtch 1474500
\1itrobenzene-d5 1660 1140 ug/kg 68.4 (21%403%)
3henol-d5 3330 2730 ug/kg 82 (25%-108%) RMB 04/28/15 23:0
)-Terphenyl-d14 1660 1500 ug/kg 90.3 (31%-124%)
QC1203307809 MB
1,1'-Biphenyl U ND ug/kg 04/28/15 22:3
1,2,4,5-Tetrachlorobenzene U ND ug/kg
1,2,4-Trichlorobenzene U ND ug/kg
1,2-Dichlorobenzene U ND ug/kg
1,2-Diphenylhydrazine U ND ug/kg
1,3,5-Trinitrobenzene U ND ug/kg
1,3-Dichlorobenzene U ND ug/kg
1,4-Dichlorobenzene U ND ug/kg
1,4-Dinitrobenzene U ND ug/kg
1,4-Dioxane U ND ug/kg
1,4-Naphthoquinone U ND ug/kg
1-Methylnaphthalene U ND ug/kg
1-Naphthylamine U ND ug/kg
2,3,4,6-Tetrachlorophenol U ND ug/kg
2,3-Di chloroaniline U ND ug/kg
2,4,5-Trichlorophenol U ND ug/kg
2,4,6-Trichlorophenol U ND ug/kg
2,4-Dichlorophenol U ND ug/kg
2,4-Dimethylphenol U ND ug/kg
age 25 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.geLcom
QC Summary
Workorder: 371623 Page 6 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
1emi-Volatile-GC/MS
latch 1474500
RMB 04/28/15 22:3 2,4-Dinitrophenol U ND ug/kg
2,4-Dinitrotoluene U ND ug/kg
2,6-Dichlorophenol U ND ug/kg
2,6-Dinitrotoluene U ND ug/kg
2-Acetylaminofluorene U ND ug/kg
2-Chloronaphthalene U ND ug/kg
2-Chlorophenol U ND ug/kg
2-Ethoxyethanol U ND ug/kg
2-Methy1-4,6-dinitrophenol U ND ug/kg
2-Methylnaphthalene U ND ug/kg
2-Naphthylamine U ND ug/kg
2-Nitrophenol U ND ug/kg
2-Picoline U ND ug/kg
3,3'-Dichlorobenzidine U ND ug/kg
3,3'-Dimethylbenzidine U ND ug/kg
3-Methylcholanthrene U ND ug/kg
4,4'-Methylenebis(2- U ND ug/kg
chloroaniline)
4-Aminobiphenyl U ND ug/kg
4-Bromophenylphenylether U ND ug/kg
4-Chloro-3-methylphenol U ND ug/kg
4-Chloroaniline U ND ug/kg
age 26 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 7 of 2
'arm name NOM Sample Qual QC Units RPD% REC% Range An lst Date Time
;emi-Volatile-GC/MS
1atch 1474500
1-Chlorophenylphenylether U ND ug/kg
1-Nitrophenol U ND ug/kg RMB 04/28/15 22:3
1-Nitroquinoline-1-oxide U ND ug/kg
5-Nitro-o-toluidine U ND ug/kg
7,12-Dimethylbenz(a)anthracene U ND ug/kg
tkcenaphthene U ND ug/kg
Acenaphthylene U ND ug/kg
4cetophenone U ND ug/kg
Aniline U ND ug/kg
hinthracene U ND ug/kg
kramite U ND ug/kg
ktrazine U ND ug/kg
Benzaldehyde U ND ug/kg
Benzo(a)anthracene U ND ug/kg
Benzo(a)pyrene U ND ug/kg
Benzo(b)fluoranthene U ND ug/kg
Benzo(ghi)perylene U ND ug/kg
Benzo(k)fluoranthene U ND ug/kg
Benzoic acid U ND ug/kg AGS1 04/28/15 22:1
Benzyl alcohol U ND ug/kg RMB 04/28/15 22:3
Butylbenzylphthalate U ND ug/kg
Caprolactam U ND ug/kg
age 27 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 8 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
;emi-Volati1e-GC/MS
1atch 1474500
arbazole U ND ug/kg
211orobenzilate U ND ug/kg
::hrysene U ND ug/kg
Di-n-butylphthalate U ND ug/kg
Di-n-octylphthalate U ND ug/kg
Diallate U ND ug/kg
Dibenzo(a,e)pyrene U ND ug/kg
Dibenzo(a,h)anthracene U ND ug/kg
Dibenzofuran U ND ug/kg
Diethylphthalate U ND ug/kg
Dimethoate U ND ug/kg
Dimethylphthalate U ND ug/kg
Dinoseb U ND ug/kg
Diphenylamine U ND ug/kg
Disulfoton U ND ug/kg
Ethyl Methanesulfonate U ND ug/kg
Ethyl methacrylate U ND ug/kg
Famphur U ND ug/kg
Fluoranthene U ND ug/kg
Fluorene U ND ug/kg
Hexachlorobenzene U ND ug/kg
Hexachlorobutadiene U ND ug/kg
RIVIB 04/28/15 22:3
age 28 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 9 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
emi-Volatile-GC/MS
tech 1474500
-lexachlorocyclopentadiene U ND ug/kg
-lexachloroethane U ND ug/kg RMB 04/28/15 22:3
lexachlorophene U ND ug/kg AGS I 04/28/15 22:3.
-lexachloropropene U ND ug/kg RMB 04/28/15 22:3
-Iydroxymethyl phthalimide U ND ug/kg
ndeno(1,2,3-cd)pyrene U ND ug/kg
sodrin U ND ug/kg
sophorone U ND ug/kg
sosafrole U ND ug/kg
(pone U ND ug/kg
Vlethapyrilene U ND ug/kg
Vlethoxychlor U ND ug/kg
Vlethyl methacrylate U ND ug/kg
Vlethyl methanesulfonate U ND ug/kg
V1ethyl parathion U ND ug/kg
\T-Methy1-N-nitrosomethy1amine U ND ug/kg
\1-Nitrosodi-n-buty1amine U ND ug/kg
\T-Nitrosodiethylamine U ND ug/kg
\i-Nitrosodipropy1amine U ND ug/kg
5.1-Nitrosomethy1ethy1amine U ND ug/kg
\I-Nitrosomorpholine U ND ug/kg
\1-Nitrosopiperidine U ND ug/kg
age 29 of 52
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QC Summary
Workorder: 371623 Page 10 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
;emi-Volatile-GC/MS
1atch 1474500
N-Nitrosopyrrolidine u ND ug/kg
Naphthalene U ND ug/kg
Nitrobenzene U ND ug/kg
Parathion u ND ug/kg
Pentachlorobenzene U ND ug/kg
Pentachloroethane u ND ug/kg
Pentachloronitrobenzene u ND ug/kg
Pentachlorophenol u ND ug/kg
Phenacetin u ND ug/kg
Phenanthrene u ND ug/kg
Phenol u ND ug/kg
Phorate u ND ug/kg
Phthalic Anhydride u ND ug/kg
Pronamide U ND ug/kg
Pyrene u ND ug/kg
Pyridine U ND ug/kg
Safrole u ND ug/kg
Sulfotepp U ND ug/kg
Thionazin U ND ug/kg
Tributylphosphate U ND ug/kg
Triethylphosphorothioate U ND ug/kg
a,a-Dimethylphenethylamine U ND ug/kg
RMB 04/28/15 22:3
age 30 of 52
• GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 11 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
;emi-volatile-GC/MS
3atch 1474500
3.1pha-Terpineo1 U ND ug/kg
Dis(2-Chloro-1-methylethypether U ND ug/kg RMB 04/28/15 22:3
Dis(2-Chloroethoxy)methane U ND ug/kg
Dis(2-Chloroethyl) ether U ND ug/kg
bis(2-Ethylhexyl)phthalate U ND ug/kg
m,p-Cresols U ND ug/kg
rn-Dinitrobenzene U ND ug/kg
rn-Nitroaniline U ND ug/kg
tn-Toluidine U ND ug/kg
n-Decane U ND ug/kg
n-Octadecane U ND ug/kg
D-Cresol U ND ug/kg
D-Nitroaniline U ND ug/kg
p-Toluidine U ND ug/kg
p-(Dimethylamino)azobenzene U ND ug/kg
p-Benzoquinone U ND ug/kg
p-Nitroaniline U ND ug/kg
p-Phenylenediamine U ND ug/kg
p-Toluidine U ND ug/kg
2,4,6-Tribromophenol 3330 2170 ug/kg 65.2 (20%-122%)
2-Fluorobiphenyl 1670 1210 ug/kg 73 (25%-100%)
2-Fluorophenol 3330 2300 ug/kg 69 (23%407%)
age 31 of 52
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QC Summary
Workorder: 371623 Page 12 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
kmi-Volatile-GC/MS
latch 1474500
Nitrobenzene-d5 1670 1140 ug/kg 68.5 (21%403%)
Phenol-d5 3330 1960 ug/kg 58.7 (25%-108%) RMB 04/28/15 22:3
p-Terphenyl-d14 1670 1640 ug/kg 98.7 (31%424%)
QC1203307811 371696001 MS
1,2,4-Trichlorobenzene 2540 U ND 1700 ug/kg 67.1 (25°/0-102%) 04/29/15 02:3
1,4-Dichlorobenzene 2540 U ND 1570 ug/kg 61.7 (24°4-97%)
2,4-Dinitrotoluene 2540 U ND 2160 ug/kg 85.2 (36%-115%)
2-Chlorophenol 2540 U ND 2040 ug/kg 80.2 (28%-108%)
4-Chloro-3-methylphenol 2540 U ND 2300 ug/kg 90.5 (32')/0-112%)
4-Nitrophenol 2540 U ND 1510 ug/kg 59.6 (12%-128%)
Acenaphthene 2540 U ND 1810 ug/kg 71.1 (28%-102%)
N-Nitrosodipropylamine 2540 U ND 1770 ug/kg 69.8 (23%-117%)
Pentachlorophenol 2540 U ND 1610 ug/kg 63.2 (22%-108%)
Phenol 2540 U ND 2110 ug/kg 83 (28%408%)
Pyrene 2540 67.3 1970 ug/kg 75 (25%-119%)
2,4,6-Tribromophenol 5080 3130 3570 ug/kg 70.4 (20%422%)
2-Fluorobiphenyl 2540 1180 1230 ug/kg 48.4 (25%-100%)
2-Fluorophenol 5080 2610 3350 ug/kg 65.9 (23%-107%)
Nitrobenzene-d5 2540 1120 1380 ug/kg 54.5 (21°4-103%)
Phenol-d5 5080 2960 3920 ug/kg 77.1 (25%408%)
p-Terphenyl-d14 2540 1690 2200 ug/kg 86.8 (31%-124%)
QC 1203307812 371696001 MSD
1,2,4-Trich1orobenzene 2540 U ND 1290 ug/kg 27.3 51 (0°/0-30%) 04/29/15 03:0
1,4-Dichlorobenzene 2540 U ND 1280 ug/kg 19.9 50.6 (0%-30%)
age 32 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 13 of 2
'arm nam e NOM Sample Qual QC Units RPD% REC% Range Anist Date Time
kmi-Volatile-GC/MS 3atch 1474500
2,4-Dinitrotoluene 2540 U ND 1920 ug/kg 12.2 75.5 (0%-30%) RMB 04/29/15 03:0
2-Chlorophenol 2540 U ND 1570 ug/kg 25.6 62 (0%-30%)
4-Chloro-3-methylphenol 2540 U ND 1760 ug/kg 26.4 69.4 (0%-30%)
4-Nitrophenol 2540 U ND 1280 ug/kg 16.6 50.5 (0%-30%)
Acenaphthene 2540 U ND 1500 ug/kg 18.7 59 (0%-30%)
N-Nitrosodipropylamine 2540 U ND 1410 ug/kg 22.7 55.6 (0%-30%)
Pentachlorophenol 2540 U ND 1320 ug/kg 19.2 52.2 (0%-30%)
Phenol 2540 U ND 1670 ug/kg 23.1 65.9 (0°/0-30%)
Pyrene 2540 67.3 1650 ug/kg 17.8 62.3 (0%-30%)
2,4,6-Tribromophenol 5080 3130 3390 ug/kg 66.8 (20%422%)
2-Fluorobiphenyl 2540 1180 1200 ug/kg 47.3 (25%-100%)
2-Fluorophenol 5080 2610 2640 ug/kg 52 (23%-107%)
Nitrobenzene-d5 2540 1120 1130 ug/kg 44.7 (21%-103%)
Phenol-d5 5080 2960 3050 ug/kg 60.2 (25%-108%)
p-Terphenyl-d14 2540 1690 1860 ug/kg 73.5 (31%-124%)
Volatile-GC/MS
3atch 1476574
QC1203313766 HB
1,1,1,2-Tetrachloroethane ND ug/kg GRB2 05/06/15 17:1•
1,1,1-Trichloroethane U ND ug/kg
1,1,2,2-Tetrachloroethane U ND ug/kg
1,1,2-Trichloroethane u ND ug/kg
1,1-Dichloroethane u ND ug/kg
age 33 of 52
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QC Summary
Workorder: 371623 Page 14 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
iolatile-GC/MS
3atch 1476574
1,1-Dichloroethylene U ND ug/kg GRB2 05/06/15 17:1
1,1-Dichloropropene U ND ug/kg
1,2,3-Trichlorobenzene u ND ug/kg
1,2,3-Trichloropropane u ND ug/kg
1,2,4-Trichlorobenzene u ND ug/kg
1,2,4-Trimethylbenzene u ND ug/kg
1,2-Dibromo-3-chloropropane u ND ug/kg
1,2-Dibromoethane u ND ug/kg
1,2-Dichlorobenzene u ND ug/kg
1,2-Dichloroethane u ND ug/kg
1,2-Dichloropropane u ND ug/kg
1,3,5-Trimethylbenzene U ND ug/kg
1,3-Dichlorobenzene U ND ug/kg
1,3-Dichloropropane U ND ug/kg
1,4-Dichlorobenzene U ND ug/kg
1,4-Dioxane u ND ug/kg
2,2-Dichloropropane u ND ug/kg
2-Butanone u ND ug/kg
2-Chloro-1,3-butadiene U ND ug/kg
2-Chloroethylvinyl ether U ND ug/kg
2-Chlorotoluene u ND ug/kg
age 34 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 15 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
/olatile-GC/MS
latch 1476574
2-Hexanone U ND ug/kg
2-Nitropropane U ND ug/kg
2-Pentanone U ND ug/kg
1-Chlorotoluene U ND ug/kg
1-Isopropylto1uene U ND ug/kg
1-Methy1-2-pentanone U ND ug/kg
kcetone U ND ug/kg
aicetonitrile U ND ug/kg
4crolein U ND ug/kg
aicrylonitrile U ND ug/kg
klly1 chloride U ND ug/kg
3enzene U ND ug/kg
3enzyl chloride U ND ug/kg
3romobenzene U ND ug/kg
3romochloromethane U ND ug/kg
3romodichloromethane U ND ug/kg
3romoform U ND ug/kg
3romomethane U ND ug/kg
.:arbon disulfide U ND ug/kg
2arbon tetrachloride U ND ug/kg
.Thlorobenzene U ND ug/kg
21iloroethane U ND ug/kg
GRB2 05/06/15 17:1
age 35 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 16 of 2
Iarmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Volatile-GC/MS
3atch 1476574
Chloroform U ND ug/kg
Chloromethane U ND ug/kg
Cyclohexane U ND ug/kg
Cyclohexanone U ND ug/kg
Dibromochloromethane U ND ug/kg
Dibromomethane U ND ug/kg
Dichlorodifluoromethane U ND ug/kg
Ethyl acetate U ND ug/kg
Ethyl ether J 31.5 ug/kg
Ethyl methacrylate U ND ug/kg
Ethylbenzene U ND ug/kg
Flexachlorobutadiene U ND ug/kg
lodomethane U ND ug/kg
lsobutyl alcohol U ND ug/kg
isopropylbenzene U ND ug/kg
Methacrylonitrile U ND ug/kg
Methyl acetate U ND ug/kg
Methyl methacrylate U ND ug/kg
Methylcyclohexane U ND ug/kg
Methylene chloride U ND ug/kg
Nlaphthalene U ND ug/kg
Pentachloroethane U ND ug/kg
GRB2 05/06/15 17:1
age 36 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 17 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Tolatile-GC/MS
latch 1476574
3ropionitri1e U ND ug/kg
ityrene U ND ug/kg GRB2 05/06/15 17:1
retrachloroethylene U ND ug/kg
retrahydrofuran U ND ug/kg
roluene U ND ug/kg
frichloroethylene U ND ug/kg
frichlorofluoromethane U ND ug/kg
frichlorotrifluoroethane U ND ug/kg
Vinyl acetate U ND ug/kg
Vinyl chloride U ND ug/kg
Kylenes (total) U ND ug/kg
)is(2-Chloro-1-methylethyl)ether U ND ug/kg
:is-1,2-Dichloroethylene U ND ug/kg
Hs-1,3-Dichloropropylene U ND ug/kg
:is-1,4-Dichloro-2-butene U ND ug/kg
n,p-Xylenes U ND ug/kg
1-Buty1 alcohol U ND ug/kg
-1-Butylbenzene U ND ug/kg
t-Propylbenzene U ND ug/kg
)-Xylene U ND ug/kg
;ec-Butylbenzene U ND ug/kg
ert-Butyl Alcohol U ND ug/kg
age 37 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 18 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Tolatile-GC/MS
latch 1476574
ert-Butyl methyl ether u ND ug/kg
ert-Butylbenzene
rans-1,2-Dichloroethylene
rans-1,3-Dichloropropylene
sans-1,4-Dichloro-2-butene
u
U
u
u
ND
ND
ND
ND
ug/kg
ug/kg
ug/kg
ug/kg
GRB2 05/06/15 17:1
1,2-Dichloroethane-d4 50.0 53.3 ug/L 107 (70%-128%)
komofluorobenzene 50.0 53.9 ug/L 108 (63%-138%)
Toluene-d8 50.0 53.3 ug/L 107 (80%-120%)
QC1203312912 LCS
1,1-Dichloroethylene 50.0 48.6 ug/kg 97.2 (68%-125%) 05/06/15 14:1
Benzene 50.0 47.2 ug/kg 94.5 (72%-120%)
alorobenzene 50.0 47.2 ug/kg 94.4 (76%420%)
Toluene 50.0 46.1 ug/kg 92.3 (75%-120%)
Trichloroethylene 50.0 48.6 ug/kg 97.2 (75%-122%)
1,2-Dichloroethane-d4 50.0 58.5 ug/L 117 (70%428%)
Bromofluorobenzene 50.0 53.1 ug/L 106 (63%-138%)
Toluene-d8 50.0 52.4 ug/L 105 (80%420%)
QC1203312911 MB
1,1,1,2-Tetrachloroethane
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethylene
U
U
U
U
U
U
ND
ND
ND
ND
ND
ND
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
05/06/15 16:1
age 38 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 19 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
folatile-GC/MS
3atch 1476574
1,1-Dichloropropene U ND ug/kg GRB2 05/06/15 16:1
1,2,3-Trichlorobenzene U ND ug/kg
1,2,3-Trichloropropane U ND ug/kg
1,2,4-Trichlorobenzene U ND ug/kg
1,2,4-Trimethylbenzene U ND ug/kg
1,2-Dibromo-3-chloropropane U ND ug/kg
1,2-Dibromoethane U ND ug/kg
1,2-Dichlorobenzene U ND ug/kg
1,2-Dichloroethane U ND ug/kg
1,2-Dichloropropane U ND ug/kg
1,3,5-Trimethylbenzene U ND ug/kg
1,3-Dichlorobenzene U ND ug/kg
1,3-Dichloropropane U ND ug/kg
1,4-Dichlorobenzene U ND ug/kg
1,4-Dioxane U ND ug/kg
2,2-Dichloropropane U ND ug/kg
2-Butanone U ND ug/kg
2-Chloro-1,3-butadiene U ND ug/kg
2-Chloroethylvinyl ether U ND ug/kg
2-Chlorotoluene U ND ug/kg
2-Hexanone U ND ug/kg
age 39 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 20 of 1
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Jolatile-GC/MS
3atch 1476574
2-Nitropropane U ND ug/kg
2-Pentanone U ND ug/kg GRB2 05/06/15 16:1
t-Chlorotoluene U ND ug/kg
1-Isopropy1to1uene U ND ug/kg
1-Methy1-2-pentanone U ND ug/kg
Acetone U ND ug/kg
Acetonitrile U ND ug/kg
Acrolein U ND ug/kg
Acrylonitrile U ND ug/kg
Allyl chloride U ND ug/kg
Benzene U ND ug/kg
Benzyl chloride U ND ug/kg
Bromobenzene U ND ug/kg
Bromochloromethane U ND ug/kg
Bromodichloromethane U ND ug/kg
Bromoform U ND ug/kg
Bromomethane U ND ug/kg
Carbon disulfide U ND ug/kg
Carbon tetrachloride U ND ug/kg
Chlorobenzene U ND ug/kg
Chloroethane U ND ug/kg
Chloroform U ND ug/kg
age 40 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 1'age 21 of 2
'arm name NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Volatile-GC/MS
3atch 1476574
Chloromethane U ND ug/kg
Cyclohexane U ND ug/kg
Cyclohexanone U ND ug/kg
Dibromochloromethane U ND ug/kg
Dibromomethane U ND ug/kg
Dichlorodifluoromethane U ND ug/kg
Ethyl acetate U ND ug/kg
Ethyl ether U ND ug/kg
Ethyl methacrylate U ND ug(kg
Ethylbenzene U ND ug/kg
Hexachlorobutadiene U ND ug/kg
Iodomethane U ND ug/kg
Isobutyl alcohol U ND ug/kg
Isopropylbenzene U ND ug/kg
Methacrylonitrile U ND ug/kg
Methyl acetate U ND ug/kg
Methyl methacrylate U ND ug/kg
Methylcyclohexane U ND ug/kg
Methylene chloride U ND ug/kg
Naphthalene J 0.380 ug/kg
Pentachloroethane U ND ug/kg
Propionitrile U ND ug/kg
GRB2 05/06/15 16:1
age 41 of 52
GEL LABORATORIES LLC
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QC Summary
Workorder: 371623 Page 22 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
7olatile-GC/MS
latch 1476574
ityrene U ND ug/kg
Tetrachloroethylene U ND ug/kg GRB2 05/06/15 16:1
Tetrahydrofuran U ND ug/kg
Toluene U ND ug/kg
Trichloroethylene U ND ug/kg
Trichlorofluoromethane U ND ug/kg
Trichlorotrifluoroethane U ND ug/kg
Vinyl acetate U ND ug/kg
Vinyl chloride U ND ug/kg
Kylenes (total) U ND ug/kg
3is(2-Chloro-1-methylethyl)ether J 2.20 ug/kg
.is-1,2-Dich1oroethy1ene U ND ug/kg
-:is-1,3-Dich1oropropy1ene U ND ug/kg
Hs-1,4-Dich1oro-2-butene U ND ug/kg
al,p-Xylenes U ND ug/kg
a-Butyl alcohol U ND ug/kg
a-Butylbenzene U ND ug/kg
a-Propylbenzene U ND ug/kg
a-Xylene U ND ug/kg
3ec-Buty1benzene U ND ug/kg
tert-Butyl Alcohol U ND ug/kg
tert-Butyl methyl ether U ND ug/kg
age 42 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 23 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
/Waffle-GC/MS
3atch 1476574
.ert-Butylbenzene
rans-1,2-Dich1oroethy1ene
rans-1,3-Dichloropropylene
rans-1,4-Dichloro-2-butene
U
U
U
U
ND
ND
ND
ND
ug/kg
ug/kg
ug/kg
ug/kg
GRB2 05/06/15 16:1
1,2-Dichloroethane-d4 50.0 55.3 ug/L 111 (70%428%)
Bromofluorobenzene 50.0 53.3 ug/L 107 (63%-138%)
Toluene-d8 50.0 51.9 ug/L 104 (80%-120%)
QC1203312913 372243003 PS
1,1-Dichloroethylene 50.0 U ND 50.6 ug/L 101 (59%-134%) 05/06/15 20:0
Benzene 50.0 U ND 48.5 ug/L 97.1 (63%424%)
Chlorobenzene 50.0 U ND 44.5 ug/L 89 (60%426%)
Toluene 50.0 U ND 45.9 ug/L 91.7 (58%-128%)
Trichloroethylene 50.0 U ND 47.7 ug/L 95.4 (60%435%)
1,2-Dichloroethane-d4 50.0 53.3 53.9 ug/L 108 (70%428%)
Bromofluorobenzene 50.0 52.3 52.6 ug/L 105 (63%-138%)
Toluene-d8 50.0 51.2 52.5 ug/L 105 (80%-120%)
QC1203312914 372243003 PSD
1,1-Dichloroethylene 50.0 U ND 53.8 ug/L 6.24 108 (0°/0-20%) 05/06/15 20:3
Benzene 50.0 U ND 51.6 ug/L 6.09 103 (0%-20%)
Chlorobenzene 50.0 U ND 51.0 ug/L 13.7 102 (0%-20%)
Toluene 50.0 U ND 51.2 ug/L 10.9 102 (0%-20%)
Trichloroethylene 50.0 U ND 52.2 ug/L 9.04 104 (0°/0-20%)
1,2-Dichloroethane-d4 50.0 53.3 51.7 ug/L 103 (70%428%)
Bromofluorobenzene 50.0 52.3 52.5 ug/L 105 (63°4138%)
age 43 of 52
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 371623 Page 24 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Tolatile-GC/MS
latch 1476574
Toluene-d8 50.0 51.2 52.6 ug/L 105 (80%-120%) GRB2 05/06/15 20:3
Notes:
The Qualifiers in this report are defined as follows:
** Analyte is a Tracer compound
*4. Analyte is a surrogate compound
< Result is less than value reported
> Result is greater than value reported
A The TIC is a suspected aldol-condensation product
B The target analyte was detected in the associated blank.
BD Results are either below the MDC or tracer recovery is low
C Analyte has been confirmed by GC/MS analysis
D Results are reported from a diluted aliquot of the sample
E %difference of sample and SD is >10%. Sample concentration must meet flagging criteria
E Concentration of the target analyte exceeds the instrument calibration range
FA Failed analysis.
FB Mercury was found present at quantifiable concentrations in field blanks received with these samples. Data associated with the blank are deemed
invalid for reporting to regulatory agencies
H Analytical holding time was exceeded
Value is estimated
JNX Non Calibrated Compound
K Analyte present. Reported value may be biased high. Actual value is expected to be lower.
L Analyte present. Reported value may be biased low. Actual value is expected to be higher.
M M if above MDC and less than LLD
M REMP Result > MDC/CL and < RDL
N Metals--The Matrix spike sample recovery is not within specified control limits
N Organics--Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte (TIC). Quantitation is based
on nearest internal standard response factor
N Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte (TIC). Quantitation is based on nearest
internal standard response factor
N/A RPD or %Recovery limits do not apply.
N1 See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
P Organics--The concentrations between the primary and confirmation columns/detectors is >40% different. For HPLC, the difference is >70%.
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QC Summary
Workorder: 371623 Page 25 of 2
'armname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Q One or more quality control criteria have not been met. Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for, but not detected above the MDL, MDA, or LOD.
UI Gamma Spectroscopy--Uncertain identification
UJ Compound cannot be extracted
UJ Gamma Spectroscopy--Uncertain identification
UL Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.
X Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results. Consult case narrative.
Y QC Samples were not spiked with this compound
A RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc. by a factor of 4 or more or %RPD not applicable.
A The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than
five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +/- the
RL is used to evaluate the DUP result.
* Indicates that a Quality Control parameter was not within specifications. For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations.
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
age 45 of 52
GEL Laboratories LLC DER Report No.: 1406134
Form GEL-DER Revision No.: 1
DATA EXCEPTION REPORT
Mo.Day Yr.
30-APR-15 Division: Industrial Quality Criteria: Specifications
Type:
Process
Instrument Type: SEMIVOA GCMS Test / Method: SW846 3541/8270D Matrix Type: Solid Client Code: CARE, OLAB, UCOR, URli
Batch ID:
1474500 Sample Numbers: See Below
Potentially affected work order(s)(SDG):371570(EUI-9911),371572(EUI-9912),371623,371696,371808(X504295)
Application Issues:
Failed Recovery for MS/MSD, or PS/PSD
Failed RPD for MS/MSD, or PS/PSD
Failed Recovery for LCS/LCSD
Failed Yield for Surrogates
Specification and Requirements Exception Description: DER Disposition:
1. CARE sample 371570001 failed surrogate recovery.
2. The 1203307810LCS failed spike recovery.
3. The 1203307812MSD failed spike recovery.
4. The RPD values between the 1203307811MS and 1203307812MSD were not within the acceptance limits.
1. Sample was re-extracted as part of batch 1475177. Re-extraction
results confirmed surrogate failure and were attributed to sample matrix interference. The original extraction results are reported.
2. The LCS and/or LCSD (See Below) did not meet spike recovery acceptance criteria. Since target analytes were not detected in the
associated samples above the reporting limits, the positive bias had no
adverse impact on the data. 1203307810 (LCS) Benzyl alcohol [96.2* (35%-95%)].
3. The MS or MSD (See Below) recovered spiked analytes outside of the
established acceptance limits. As similar recoveries were displayed in the
MS and MSD, the failures were attributed to sample matrix interference and the data were reported.
1203307812 (5212S0048AMSD) 3,3'-Dichlorobenzidine [27.9* (28%-
105%)] and Hexachlorocyclopentadiene [9.18* (12%-106%)].
4. The relative percent differences (RPD) for the MS and MSD, (See
Below), were not within the acceptance limits. The failures were attributed
to matrix interference. The data were reported.
1203307811MS and 1203307812MSD (5212S0048A) 2,4-Dichlorophenol
[30.3* (0%-30%)], 2-Nitrophenol [31.1* (0%-30%)], 3,3'-Dichlorobenzidine [42.5* (0%-30%)], Aniline [43.2* (0%-30%)], Benzoic acid [46* (0%-30%)] and Naphthalene [30.3* (0%-30%)1.
Originator's Name: Data Validator/Group Leader:
Anne Salter 30-APR-15 Herbert Maier 04-MAY-15
age 46 of 52
GEL Laboratories LLC DER Report No.: 1407797 Form GEL-DER Revision No.: 2
DATA EXCEPTION REPORT
Mo.Day Yr. 06-MAY-15 Division: Industrial Quality Criteria: Specifications Type: Process
Instrument Type: ICP/MS Test / Method: SW846 3050B/6020A Matrix Type: Solid
Client Code:
URII
Batch ID: 1473731 Sample Numbers: See Below
Potentially affected work order(s)(SDG): 371623
Application Issues:
Failed RPD for DUP
Failed Recovery for PS/PSD
Specification and Requirements
Exception Description:
DER Disposition:
1. Failed RPD for DUP:
QC 1203305841(Feed Sample 1)DUP
1. Not all the applicable analyte RPD values were within the acceptance criteria. 1203305841 (Feed Sample 1DUP) lron [23.1* (0%-20%)] and Molybdenum [20.4* (0%-20%)].
,
Originator's Name: Data Validator/Group Leader:
Bryan Davis 06-MAY-15 Jamie Johnson 15-MAY-15
age 47 of 52
GEL Laboratories LLC DER Report No.: 1407961 Form GEL-DER Revision No.: 1
DATA EXCEPTION REPORT
Mo.Day Yr.
06-MAY-15 Division: Industrial Quality Criteria: Specifications Type: Process
Instrument Type:
ICP
Test / Method:
5W846 3050B/6010C
Matrix Type:
Solid
Client Code:
URII
Batch ID:
1473747 Sample Numbers: See Below
Potentially affected work order(s)(SDG): 371623
Application Issues:
Failed Recovery for MS/MSD, or PS/PSD
Failed RPD for DUP
Failed Recovery for PS/PSD
Specification and Requirements Exception Description: DER Disposition:
1. Failed RPD for DUP:
QC 1203305878(Feed Sample 1)DUP
2. Failed Recovery for MS/MSD, or PS/PSD:
QC 1203305879(Feed Sample 1)MS
3. Failed Recovery for PS/PSD:
QC 1203308327(Feed Sample 1)PS
•
1. Not all the applicable analyte RPD values were within the acceptance
criteria.
1203305878 (Feed Sample 1DUP) Chromium [23.8* (0%-20%)] and
Selenium [105* (0.0%-20.0%)].
2. The MS/MSD (See Below) did not meet the recommended quality control acceptance criteria for percent recoveries for the following
applicable analyte. The post spike recovery was within the required
control limits. This verifies the absence of a matrix interference in the post-
spike digested sample. The recovery may be attributed to possible sample matrix interference and/or non-homogeneity.
1203305879 (Feed Sample 1MS) Chromium [53.4* (75%-125%)], Selenium [-43* (75%-125%)] and Silver [514* (75%-125%)1.
The MS/MSD (See Below) did not meet the recommended quality control
acceptance criteria for percent recoveries for the following applicable
analyte. The post spike also did not meet the required control limits; thus, confirming matrix interferences and/or sample non-homogeneity. 1203305879 (Feed Sample 1MS) Lead [66* (75%-125%)].
3. The PS did not meet the recommended quality control acceptance criteria for percent recoveries for all applicable analytes and verifies the
presence of matrix interferences.
1203308327 (Feed Sample 1PS) Lead [77.3* (80%-120%)].
Originator's Name: Data Validator/Group Leader:
Jerry Wigfall 06-MAY-15 Jamie Johnson 15-MAY-15
age 48 of 52
GEL Laboratories LLC DER Report No.: 1408186
Form GEL-DER Revision No.:
DATA EXCEPTION REPORT
Mo.Day Yr. 07-MAY-15 Division: Industrial Quality Criteria: Specifications Type: Process
Instrument Type: VOA GC/MS Test / Method: SW846 8260B
Matrix Type:
Solid
Client Code: BETf, URII
Batch ID: 1476574 Sample Numbers: See Below
Potentially affected work order(s)(SDG):371623,372243
Application Issues:
Failed Recovery for MS/MSD, or PS/PSD
Specification and Requirements Exception Description: DER Disposition:
Failed Recovery for MS/MSD, or PS/PSD:
QC 1203312914MSD
The recovery in (See Below) was within the acceptance limiis for the method specified spiking analytes. However, other analytes of interest did not pass recoveries. The results are reported.
Bromomethane 1203312914 (15-0220-003PSD) [23.8* (30%-135%)].
Originator's Name: Data Validator/Group Leader:
Gelester Baskett 07-MAY-15 Erin Haubert 07-MAY-15
age 49 of 52
Airbill 3
I.) Chain of Custody Number = Client Determined
2.) QC Codes: N = Normal Sample, TB = Trip Blank, FD Field Duplicate. ED = Equipmen( Blank. MS = Matrix Spike Sample, MSD = Matrix Spike Duplicate Sample, C = Grab, C = Composite
3.) Field Filtered: For liquid matrices, indica(e with a - Y - for yes the sample was field filtered or - N - for sample was not field filtered.
4.) Matrix Codes: DW=Drinking Water, GW=Groundwater, SW=Surface Water. WW=Waste Water, W=Water, SO=Soil, SD=Sediment. SL=Sludge, SS=Solid Waste. 0--,041. F=Filter, P=Wipe. U=Urine, F=Fecal. N=Nasal
5.) Sample Analysis Requested: Analytical method requested (i.e. 82608, 6010Bf/470A ) and number of containers provided for each (i.e. 82608 • 3, 60108/74704 • I).
6.) Preservative Type: NA = Hydrochloric Acid. NI = Nitric Acid. SH = Sodium Hydroxide. SA = Sulftiric Acid. AA = Ascorbic Acid, HX Hexane. ST = Sodium Thiosulfate, If no preservative is added = leave field blank
etre I 15551 0111J11 .... ne'lker
aQ co 8'age: of
OProject #:
(JOEL Quote #:
t‘t0C Number (11:
PO Number: k — sv:s
Client Name: u11,1 c.
Project/Site Name: k v ..0
Address: 6.2/ 8
Collected by: VI 14. 2-osm
Sample ID
" For composites - indicate start and stop date/time
Fe sAM Lk 1
ALT FE--c-D Sm-tpt ,2_
GEL Chain of Custody and Analytical Request
C4i/.22/1
61/zil/c
V X0514 )0-LITGINWriste{ Jukti rfoni
'Time *Date Collected Collected QC Code Field Sample
(Milken) (3) Filtered (3) Matrix (3) (inan-dd-yy) (hhmm)
Phone 4:36 976"...57Ti
Fax #: 36/0., 5-95-. 0103
09:19
Of Lc'
Gi
C
I 02,3
50
Should this
sample be
considered:
OA-
r4A
7
GEL Laboratories, LLC
2040 Savage Road
Charleston, SC 29407
Phone: [phone]
Fax: [phone]
Sample Analysis Requested (5) (Fill in the number of containers for each test)
7
To
ta
l
n
um
be
r

o
f
c
o
n
ta
in
er
s

o
Comments
Note: extra sample is
required for santple
specific QC
Preservative Type (6)
GEL Work Order Number:
km143 VA/ Pc — 7 %TM h cg Lc. /03 17 (3411C~C We-3,44m Send Results To:
TAT Requested: Normal: V Rush: Specify: (Subject (o Surcharge) I Fax Results: Yes
Remarks: Are there any known hazards applicable to these samples? If so, please list the hazards
ileAV)' MeThy )142itep Na“-r.
Chain of Custody Signatures
Relinquished By (Signed) Date Time Rece. ed by (signed) Date Time
47,SW
I 4 .focyq 041246-- 1?:04 A,
2 2
Circle Deliverable: C of A / QC Summary / Level 1 / Level 2 / Level 3 / Level 4
Sample Collection Time Zone
Eastern Pacific
Other
NA A
Mountain
Sample Shipping and Del'very Details
Method of Shipment: in AkA/PA Y /4/1( Date Shipped: nil
Airbill #: I ZriAl 37a 0/ ci 2 oci
GEL PM:
Far Lab Receiving Use Only
GL-CHL-SR-001 Rev 1 Date Page I of PM (or PMA) review: Initials
age 51 of 52
Laboratories ac SAMPLE RECEIPT & REVIEW FORM GEL
Client: U Lti SDG/ARICOC/Work Order: 2i4 I 112....
Received By: C., b,,ls,,, rn4 Cik Date Received: 1 .- 23 -i S-- '7-'02 b
Suspected Hazard Information 4
>"
0
4
*If Net Counts > 100cpm on samples not marked "radioactive", contact the Radiation Safety Group for further
investigation.
COC/Samples marked as radioactive? ''''''' Maximum Net Counts Observed* (Observed Counts - Area Background Counts): 2%
Classified Radioactive 11 or 111 by RSO? If yes, Were swipes taken of sample contatiners < action levels?
COC/Samples marked containing PCBs? ••••••• Package, COC, and/or Samples marked as
beryllium or asbestos cow:timing? ****-' If yes, samples are to be segregated as Safety Controlled Samples, and opened by the GEL Safety Group.
Shipped as a DOT Hazardous? ..-- Hazard Class Shipped: UM:
Samples identified as Foreign Soil? —
Sample Receipt Criteria a ...g . ›. z z Comments/Qualillers (Required for Non-Conforming Items)
1 Shipping containers received intact
and sealed?
Circle Applicable:
Seals broken Damaged container Leaking container Other (describe)
2 Samples requiring cold preservation
within (0 < 6 deg. C)?* --- Preservation Method: Ice bags Blue ice Dry ice None Other (describe) d call temperatures are recorded in Celsius
2a Daily check performed and passed on
IR temperature gun?
Temperature Device Serial re
Secondary Temperature Device Serial # (If Applicable), 9 2c,zyciy 7
3 Chain of custody documents included
with shipment?
4 Sample containers intact and sealed? e.- Circle Applicable:
Seals broken Damaged container Leaking container Other (describe)
S Samples requiring chemical
preservation at proper pH?
Sample ID's, containers affected and observed pH:
If Preservation added. Lot#:
6
Do Low Level Perchlorate samples
(EPA 6850) have headspace as
required?
Sample ID's and containers affected:
7 VOA vials free of headspace (defined
as < 6mm bubble)?
Sample ID's and containers affected:
8 Are Encore containers present? .0"--
(If yes, immediately deliver to Volatiles laboratory)
9 Samples received within holding
time? e"--
ID's and tests affected:
10 Sample ID's on COC match ID's on
bottles?
Sample 1D's and containers affected:
11 Date & time on COC match date &
time on bottles? • Sample ID's affected:
12 Number of containers received match
number indicated on COC?
Sample 1D's affected:
13 Are sample containers identifiable as
GEL provided? g.,-.
14 COC form is properly signed in ....,- relinquished/received sections?
15 Carrier and tracking number.
Circle Applicable:
FedEx Air FedEx Ground jjES Field Services Courier Other
I 2—.37° SiC, ol clzy ,23T1'
Comments (Use Continuation Form if needed):
IL a .... • i I — ' . li 1- I 1
List of current GEL Certifications as of 15 May 2015
State Certification
Alaska UST-110
Arkansas 88-0651
CLIA 42D0904046
California 2940 Interim
Colorado SC00012
Connecticut PH-0169
Delaware SC000122013-10
DoD ELAP/ IS017025 A2LA 2567.01
Florida NELAP E87156
Foreign Soils Permit P330-12-00283, P330-12-00284
Georgia SC00012
Georgia SDWA 967
Hawaii SC000122013-10
Idaho Chemistry SC00012
Idaho Radiochemistry SC00012
Illinois NELAP 200029
Indiana C—SC-01
Kansas NELAP E-10332
Kentucky SDWA 90129
Kentucky Wastewater 90129
Louisiana NELAP 03046 (AI33904)
Louisiana SDWA LA150001
Maryland 270
Massachusetts M—SC012
Michigan 9976
Mississippi SC000122013-10
Nebraska NE—OS-26-13
Nevada SC000122014-1
New Hampshire NELAP 2054
New Jersey NELAP SC002
New Mexico SC00012
New York NELAP 11501
North Carolina 233
North Carolina SDWA 45709
Oklahoma 9904
Pennsylvania NELAP 68-00485
Plant Material Permit PDEP-12-00260
S.Carolina Radchem 10120002
South Carolina Chemistry 10120001
Tennessee TN 02934
Texas NELAP T104704235-15-10
Utah NELAP SC000122015-17
Vermont VT87156
Virginia NELAP 460202
Washington C780
age 52 of 52
ATTACHMENT 2
Comparison of Constituents in Uranium Precipitate to Other Feed Materials Processed at the Mill
Table 1:
Comparison of URI Precipitate to ASTM Standards for Yellowcake
ASTM limit
without penalty
(mass % uranium
basis)
ASTM limit without
rejection (mass %
uranium basis)
2015 Feed
Sample 1 (%)
2015 Feed
Sample 2 (%)
Arsenic 0.05 0.1 0.391 0.319
Barium 0.005 0.1 0.00497 0.00584
Chromium NS NS 0.05 0.04
iron 0.15 1 36 31.5
Lead NS NS 0.019 0.014
Molybdenum 0.1 0.3 0.512 0.436
Selenium NS NS 0.034 0.035
Uranium >65 >65 1.4.2 12.6
Zirconium 0.01 0.1 0.00115 0.000967
Na/H20/0 5.112 4.536
56.3 49.5 % of Total
NOTES
Uranium is in the form of sodium diuranate. Na, H20, and 0 are present in stoichiometric ratio of 0.36 to U
Per URI, remainder of material mass is sediment (mud and sand) from pond.
NS: No standard or limit is stated in ASTM C967-08
TABLE 2: COMPARISON OF URI PRECIPITATE TO OTHER APPROVED FEEDS
Analyte Units
URI Feed
Sample 1
URI Feed
Sample 2
URI Feed
max
Honeywell Molycorp
Drum Pond
URI Feed Shreds Precipitates
average (max) (max)
FMRI Pond
Precipitates
(max)
Cabot
Precipitates
(max)
Arsenic mg/kg 3,910 3,190 3,910 3,550 249 61.7 581 20,000
Barium mg/kg 49.7 58.4 58 54 161 36,244 3000 NA
Cadmium mg/kg ND (<12.8) ND (<12.4) ND (<12.8) ND (<12.6) 5 24 59,000 NA
Chromium mg/kg 495 405 495 450 43 58 2,000 NA
Iron mg/kg 360,000 315,000 360,000 337,500 11,300 NA 54,000 200,000
Lead mg/kg 187 138 187 163 331 262,410 2,040 1000
Mercury mg/kg ND (<0.0087) 0.281 0 3 0.1 3 2 4.6 NA
Molybdenum mg/kg 5,120 4,360 5,120 4,740 4,842 56 9,800 NA
Selenium mg/kg 341 351 351 346 2,286 11.2 4.3 NA
Silver mg/kg ND (<12.8) ND (<12.4) ND (<12.8) ND (<12.6) 11 174.2 7.1 NA
Uranium
(Unat) mg/kg 142,000 126,000 142,000 134,000 1,374,140 4,900 1,510 15000
Zirconium mg/kg 12 9.67 12 10.6 1,535 NA 51,000 7,440
Note:
NA=No Analysis Available
ND=Non-detectable
All Volatiles analyzed by SW846 8270D were non-detectable in both samples.
All Semivolatiles analyzed by SW846 8260B were non-detectable in both samples.
ENERGY FUELS
VIA EMAIL AND OVERNIGHT DELIVERY
April 22, 2020
Mr. Phil Goble
Uranium Mills and Radioactive Materials Section Manager
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
Div of Waste Management and Radiation Control
MAY - 6 2020
Re: Energy Fuels Resources (USA) Inc. Notification of Rescheduling for the Radon Flux
Measurements for Tailings Impoundment 2 at the White Mesa Mill
Dear Mr. Goble:
On March 2, 2020 Energy Fuels Resources (USA) Inc. ("EFRI") submitted a 30-day notice regarding
plans to perform a sampling event for NESHAPs Radon Flux measurements for the first half of 2020 at
Tailings Impoundment 2 at the White Mesa Mill from April 6 — April 9, 2020.
On March 26, 2020 EFRI submitted a cancellation notice for the Tailings Impoundment 2 sampling
scheduled for April 6 — April 9, 2020 due to public health concerns associated with COVID-19.
The semi-annual sampling event has been rescheduled to April 28, - 30, 2020. Due to scheduling issues
associated with delays caused by COVID-19 EFRI is unable to provide a 30-day notice for this
rescheduled sampling event.
As noted in the previous letters, pursuant to the letter from the Utah Division of Waste Management and
Radiation Control ("DWMRC") dated, July 23, 2014, EFRI is required to measure radon flux at Tailings
Impoundment 2 ("Cell 2") at the White Mesa Mill (the "Mill") semi-annually in accordance with 40 CFR
61, Appendix B, Method 115. The measured results are included in the Semi-Annual Effluent Reports for
that reporting period.
If you have any questions or require assistance, please contact me at 303-389-4134; or Mr. Teny Slade,
Radiation Safety Officer, at 435-678-4128.
Yours very truly,
.esdy )(4)-K4-1.
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: D.Frydenlund, L. Shumway, P. Goranson, T. Slade,
E Ally Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
D RC- 20 20 -00 9 71 5 www.energyfuels.com
Y FUELS
Energy Fuels Resources (USA) lnc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com ZOZO -00 9716
VIA EMAIL AND OVERNIGHT DELIVERY
April 22, 2020
Mr. Bryce C. Bird
Division Director
Utah Department of Environmental Quality
Air Quality Division
195 North 1950 West
Salt Lake City, Utah 84116
Div of Waste Management
and Radiation Control
MAY 6 2020
Re: Energy Fuels Resources (USA) Inc. Notification of Rescheduling of NESHAPs Radon
Flux Measurements for Tailings Impoundment 3 at the White Mesa Mill
Dear Mr. Bird:
On March 2, Energy Fuels Resources (USA) Inc. ("EFRI") submitted a 30-day notice regarding
plans to perform a sampling event for NESHAPs Radon Flux measurements for the first half of
2020 at Tailings Impoundment 3 at the White Mesa Mill from April 6 — April 9, 2020.
On March 26, 2020 EFRI submitted a cancellation notice for the Tailings Impoundment 3
sampling scheduled for April 6 — April 9, 2020 due to public health concerns associated with
COVID-19.
The semi-annual sampling event has been rescheduled to April 28, - 30, 2020. Due to scheduling
issues associated with delays caused by COVID-19 EFRI is unable to provide a 30-day notice for
this rescheduled sampling event.
As stated in the previous letters, per 40 CFR 61.253, EFRI is permitted to monitor Radon Flux
one or more times per year. In the March 2, 2020 letter EFRI stated that Tailings Impoundment 3
would be sampled on a semi-annual frequency in 2020. However, since the first quarter
sampling has been cancelled due to weather conditions beyond our control, EFRI will change the
planned 2019 sampling frequency on Tailings Impoundment 3 to three times in 2019, with one
sampling event in each 4-month period in 2019 (January — April, May through August, and
September through December).
EFRI will provide safety and radiological orientation for any Utah Department of Air Quality
personnel observing this event. This orientation will be required before any individual enters the
Mill Restricted Area. Individuals monitoring this event should bring their own mandatory
Personnel Protective Equipment as required at the Mill, specifically, safety glasses, hardhats, and
steel-toed shoes.
If you have any questions or require assistance, please contact me at 303-389-4134; or Mr. Terry
Slade, Radiation Safety Officer, at 435-678-4128.
Yours very truly,
f Y(...,t
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Phil Goble, Utah Division Waste Management and Radiation Control
Director, Air and Toxics Technical Enforcement Program, U.S. Environmental Protection Agency
D. Frydenlund, L. Shumway, T. •Slade, S. Bakken, P. Goranson (EFRI)
Y FUELS
Energy F'uels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140 DEC-20X - 0059 www.enerfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
March 26, 2020
Mr. Bryce C. Bird
Division Director
Utah Department of Environmental Quality
Air Quality Division
195 North 1950 West
Salt Lake City, Utah 84116
Dv C and RathatIon Control
APR C I LO
Re: Energy Fuels Resources (USA) Inc. Postponement of NESHAPs Radon Flux
Measurements for Tailings Impoundment 3 at the White Mesa Mill
Dear Mr. Bird:
On March 2, 2020, Energy Fuels Resources (USA) Inc. ("EFRI") submitted a 30-day notice
regarding a radon flux sampling event for Tailings Impoundment 3 ("Cell 3") at the White Mesa
Mill (the "Mill") that was scheduled to be conducted from April 6 - 9, 2020. However, due to the
public health concerns associated with COVID-19 and social distancing suggestions, EFRI is
postponing the sampling event until further notice. The sampling event will be scheduled as
soon as possible, when it is safe to do so.
Per 40 CFR 61.253, EFRI is permitted to monitor Radon Flux one or more times per year. In the
March 2, 2020 letter, EFRI stated that Tailings Impoundment 3 would be sampled on a semi-
annual frequency in 2020. EFRI will strive to meet this schedule, and will monitor the health
recommendations and reschedule the event based on those recommendations.
EFRI will provide notice upon rescheduling of the Tailings Impoundment 3 event.
If you have any questions or require assistance, please contact me at 303-389-4134; or Mr. Terry
Slade, Radiation Safety Officer, at 435-678-4128.
Yours very truly,
ci'ç'tAkg. Lx_d
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Phil Goble, Utah Division Waste Management and Radiation Control
Director, Air and Toxics Technical Enforcement Program, U.S. Environmental Protection Agency
D. Frydenlund, L. Shumway, T. Slade, S. Bakken, P. Goranson (EFRI)
DRC-gozo- DO 59 2_ ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energ‘fuels.coni
VIA EMAIL AND EXPEDITED DELIVERY
March 26, 2020
Mr. Phil Goble
Uranium Mills and Radioactive Materials Section Manager
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
DR( of Waste Management
and Radiation Control
APR 0 1 2.07.0
Re: Energy Fuels Resources (USA) Inc. Postponement of the Radon Flux Measurements
for Tailings Impoundment 2 at the White Mesa Mill
Dear Mr. Goble:
On March 2, 2020, Energy Fuels Resources (USA) Inc. ("EFRI") submitted a 30-day notice
regarding a radon flux sampling event for Tailings Impoundment 2 ("Cell 2") at the White Mesa
Mill (the "Mill") that was scheduled to be conducted from April 6 - 9, 2020. However, due to the
public health concerns associated with COVID-19 and social distancing suggestions, EFRI is
postponing the sampling event until further notice. The sampling event will be scheduled as
soon as possible when it is safe to do so. EFRI will provide notification of the rescheduled dates
when available.
As noted in the March 2, 2020 submittal, pursuant to the letter from the Utah Division of Waste
Management and Radiation Control ("DWMRC") dated, July 23, 2014, EFRI is required to
measure radon flux at Tailings Impoundment 2 ("Cell 2") at the White Mesa Mill (the "Mill")
semi-annually in accordance with 40 CFR 61, Appendix B, Method 115. EFRI will strive to meet
this schedule, and will monitor the health recommendations and reschedule the event based on
those recommendations. As stated above, notification will be provided after the event has been
rescheduled.
If you have any questions or require assistance, please contact me at 303-389-4134 or Mr. Terry
Slade at 435-678-4128.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: D.Frydenlund, L. Shumway, F. Goranson, T. Slade,
P. Goble (DWMRC)
ENERGY FUELS
VIA EMAIL AND OVERNIGHT DELIVERY
March 2, 2020
Mr. Bryce C. Bird
Division Director
Utah Department of Environmental Quality
Air Quality Division
195 North 1950 West
Salt Lake City, Utah 84116
Div of Waste Management
and Radiation Control
MAR 0 4 2020
Re: Energy Fuels Resources (USA) Inc. Notification of NESHAPs Radon Flux Measurements for
Tailings Impoundment 3 at the White Mesa Mill
Dear Mr. Bird:
Energy Fuels Resources (USA) Inc. ("EFRI") plans to perform a sampling event for NESHAPs Radon
Flux measurements for the first half of 2020 at Tailings Impoundment 3 at the White Mesa Mill from
April 6, 2020 through April 9, 2020. Per 40 CFR 61.253, EFRI is permitted to monitor Radon Flux one or
more times per year. EFRI will sample Tailings Impoundment 3 on a semi-annual frequency in 2020.
Tellco Environmental of Grand Junction, Colorado ("Tellco") will perform approximately 100
measurements on the beach and cover area of Tailings Impoundment 3 during the sampling event. These
measurements will be performed in accordance with methods and procedures set forth in 40 CFR Part 61,
Appendix B, Method 115. Provided that there are no rainouts or events that require remobilization or a
delay in measurement, the sampling event for Tailings Impoundment 3 is expected to conclude on April
9, 2020.
EFRI will provide safety and radiological orientation for any Utah Department of Air Quality personnel
observing this event. This orientation will be required before any individual enters the Mill Restricted
Area. Individuals monitoring this event should bring their own mandatory Personnel Protective
Equipment as required at the Mill, specifically, safety glasses, hardhats, and steel-toed shoes.
If you have any questions or require assistance, please contact me at 303-389-4134; or Mr. Garrin Palmer,
at 435-678-4114.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Phil Goble, Utah Division Waste Management and Radiation Control
Director, Air and Toxics Technical Enforcement Program, U.S. Environmental Protection Agency
D. Frydenlund, L. Shumway, T. Slade, Paul Goranson, S. Bakken, G. Palmer (EFRI)
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DFC-ZD2o- 004766 www.energyfuels.com
ENERGYFUELS
Agy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DR.C.-2020— 0047b5 www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY DR/ c',Alas Management
and RadiatIon Control
March 2, 2020
MAR - 4 2020
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: Energy Fuels Resources (USA) Inc. Sampling Notice for the Radon Flux Measurements for
Tailings Impoundment 2 at the White Mesa Mill
Dear Mr. Howard:
Pursuant to the letter from the Utah Division of Waste Management and Radiation Control ("DWMRC")
dated, July 23, 2014, Energy Fuels Resources (USA) Inc. ("EFRI") is required to measure radon flux at
Tailings Impoundment 2 ("Cell 2") at the White Mesa Mill (the "Mill") semi-annually in accordance with
40 CFR 61, Appendix B, Method 115. EFRI is providing 30 day notice to DWMRC that the semi-annual
sampling event for the first half of 2020 for Cell 2 will be conducted at the Mill from April 6 - 9, 2020.
The measured results will be included in the January through June 2020 Semi-Annual Effluent Report,
due September 1, 2020.
Tellco Environmental of Grand Junction, Colorado will perform approximately 100 measurements on the
cover area of Cell 2 during the sampling event. Provided that there are no rainouts or events that require
remobilization or a delay in measurement, the sampling event is expected to conclude on April 9, 2020.
EFRI will provide safety and radiological orientation for any DWIVIRC personnel observing this event.
This orientation will be required before any individual enters the Mill Restricted Area. Individuals
monitoring this event should bring their own mandatory Personnel Protective Equipment as required at
the Mill, specifically, safety glasses, hardhats, and steel-toed shoes.
If you have any questions or require assistance, please contact me at 303-389-4134 or Mr. Garrin Palmer,
at 435-678-4114.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: D.Frydenlund, L. Shumway, T. Slade, S. Bakken, Paul Goranson, G. Palmer (EFRI)