DRC-2020-011981 - 0901a06880ccb64c

ENERGYFUELS
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
Div of Waste Management
and Radiation Control
JUN 2 9 2020
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.
1. 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.
Energy Fuels Resources (USA) inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
ID 13C-202o- 011961 www.energyfuels.com
'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. Chernours also refers to the clean mineral sand as clean mineral
concentrate ("CMC"), because the sands have been washed and the tree sturnps, 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 thy 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
Chernours' 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 sluny 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 slurry 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.
Letter 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 "Alternate 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,
itt il------
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)
onstel \Excavated
Hauled
Sand
Screened
Sand mixed
• with water &
pumped
Cyclone
Sand/Water
Separauon
Sand
ATTACHMENT B
Mining Schernatic
Figure Mineral Sand Mining Schematic
Watt- and
s
{
14Jnate removed hom
Organics
water
--r—
Clean
Mineral
Concentrate
Mr neral Concentrate Mineral Quartz rejected
agitated to remove Concentrate usi ng spira I
organic surface mixed with water separators&
roaring rinsed pumped water

Chemours-
Sand
Quartz
Rejected Ustrig
UCC (Density
Senaratior.l
Nonconioartars
peals. UCC, Wet
Table, Dryer.
Electrostatic and
Magnetic Pnyucal
Separations
Electrostatic &
Magnetic Physical
Separations
Minerals
Dried &
Heated
ATTACHMENT C
Separation Schematic
Figure 2: Offerman Mineral Sand Separation Schematic
Peon-magnet cs
Midinite Sand Spirals, UCC. &
Shaking table
Physical Serrations
ttee.‘ti
.1111•1•11
Funher Density.
Electrostatic, and
Magnetk Physical
Separations
Rare Earth' ...ttim2Ls, Dryer. Electrostatic
and Magnetic
Physk.al Separat ions Mineral
Sand
Concentrate
itelEfilta -
UCC - Upward Carrerir Class,ifier
Chemours-
A e i
ATTACHMENT D
Typical Ore Composition Data
Mineral Concentration
(%)
SiO2 5.22
Zr02 9.19
P205 18.33
U308 0.26
Th02 2.59
HfO2 0.34
Other oxides 2.11
Other minerals 8.18
Ce02 25.10
Dy203 0.56
Er203 0.13
Eu203 0.14
Gd203 1.19
Ho203 0.07
La203 10.58
Lu203 0.00
Nd203 9.24
Pr60ii 2.69
Sc203 0.01
Sm203 1.69
Tb407 0.17
Y203 2.12
Yb203 0.10
SUM 100%