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HomeMy WebLinkAboutDRC-2020-005216 - 0901a06880c24f29Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 DRC-2o2o-oo5216 www.energyfuels.com Die of War;le r47,nagement March 18, 2020 and Radiation Control Sent VIA EXPRESS DELIVERY AND E-MAIL MAR 2 0 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: White Mesa Uranium Mill- RML UT1900479 Safety and Environmental Review Panel ("SERP") Annual Report Dear Mr. Howard: Condition 9.4 D of the White Mesa Mill, State of Utah Radioactive Materials License No. UT 1900479 ("RML"), requires that Energy Fuels Resources (USA) Inc. ("EFRI") submit an annual Safety and Environmental Review Panel ("SERP") Report. Attached is the annual 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 the Division of Waste Management and Radiation Control ("DWMRC") on December 17, 2019. If you should have any questions regarding this report please contact me at 303-389-4134. Yours very truly, tc4-1_,e 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 in the License, or impair the licensee's ability to meet all applicable regulations. b) There is no degradation in the essential safety or environmental commitments in the License application or provided by the approved reclamation plan. c) The change, test or experiment is consistent with the conclusions of actions analyzed and selected in the Environmental Assessment dated February 1997 (the "1997 Environmental Assessment). 2.1. SERP Report No. 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 contamination 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 Rev. No.: R-0 Date: May 17, 2019 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: Mini SX (DEHPA 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 uranium 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 Rev. No.: R-0 Date: May 17, 2019 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES 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 IMPORTANT TO ENSURE THAT THE ORGANIC FROM THE MlNI 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 Rev. No.: R-0 Date: May 17, 2019 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES 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 Date: May 17, 2019 ENERGY FUELS RESOURCES (USA) 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 Rev. No.: R-0 Date: May 17, 2019 ENERGY FUELS RESOURCES (USA) 1NC. STANDARD OPERATING PROCEDURES 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.