DRC-2015-002189 - 0901a06880522af2

CF
Wf ENE
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
ENERG Y FUELS 303 974 2140
www.energyfuels.com
April 16,2015
Sent VIA E-MAIL AND OVERNIGHT DELIVERY DRC"201 5-0021 89
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: Follow-up to Utah Division of Radiation Control ("DRC") Discussion regarding
Processing of an Equivalent Feed from Cotter Corporation's Schwartzwalder Mine at
Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Mill (the "Mill")
Dear Mr. Lundberg:
This letter is a follow-up to discussions earlier this year between EFRI and DRC Staff, regarding
processing of uranium loaded ion exchange resin media ("ULR"), from Cotter Corporation's
Schwartzwalder Mine, as an equivalent feed. DRC Staff requested that EFRI prepare a letter and
provide information regarding justification and background for the equivalent feed.
Under the proposed transaction, EFRI would receive ULR from the Cotter Corporation's
Schwartzwalder Mine. The ULR was used to treat mine water from the Schwartzwalder Mine, which
was developed as a multi-level, hard rock underground mine. Based on long-term forecasts for a weak
uranium market, the decision has been made to place the Schwartzwalder Mine on temporary standby
and begin reclamation of the property. Currently, Cotter is dewatering the Schwartzwalder Mine as
part of these reclamation activities. As part of the proposed transaction, EFRI would receive 1,500
cubic feet ("CF") of currently stockpiled ULR containing approximately 5,000 pounds (2.5 tons) of
yellowcake. EFRI anticipated receiving up to an additional 1,000 CF per year for each year that
dewatering continues. Modes of transportation, storage at the Mill after receipt, and disposal of the
processed ULR are discussed below.
EFRI is proposing to accept the ULR as an equivalent feed material 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 A to this letter.
RIS 2012-06 states that "...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
Letter to Rusty Lundberg
April 16, 2015
Page 2 of 4
source material that is normally 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 [Enclosure 2]. Equivalent feed can originate at a
["Community Water System"] CWS or mine dewatering operation. In addition, equivalent feed can
also include ULR originating from another licensed uranium recovery facility." RIS 2012-06 further
states that "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."
Enclosure 2 to RIS 2-012-06 provides the procedures for accepting equivalent feed materials. EFRI
has documented below that the ULR has met the equivalent feed criteria specified in Enclosure 2.
Procedures for Accepting Equivalent Feed
NRC requires "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 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 Schwartzwalder Mine ULR meets the criteria is presented below each NRC-
specified criteria (shown in italics).
(1) chemically and physically essentially the same as the resins processed at the facility;
The Mill has used ion exchange resins and technology previously to recover uranium from low grade
uranium bearing acidic solutions. The Mill utilized DOWEX 2IK XLT anion exchange resin. Cotter
utilizes RESINTECH SBG1 for the Schwartzwalder Mine dewatering treatment. The RESINTECH
SBG1 is essentially the same in composition and function to the DOWEX 21K XLT. A comparison of
the two products follows:
• Both are strong base, type 1, anion exchange resin;
• The composition of both is trimethylamine functionalized chloromethylated copolymer of
styrene and divinylbenzene;
• The physical form of both is resin beads with essentially the same weight;
• The RESINTECH SBG1 is available in similar bead-size range to that of the DOWEX 21K
XLT;
• Both products are selective for uranium.
(2) using existing equipment, processed 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 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.
Letter to Rusty Lundberg
April 16, 2015
Page 3 of 4
(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 processing of the ULR, which will result in approximately 2.5 tons of yellowcake, will not cause
the Mill to exceed the Utah Radioactive Materials License ("RML") production limit of 4380 tons of
yellowcake per year.
Processing the Schwartzwalder Mine ULR 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.
As previously stated, the chemical and physical composition of the resin is the same as the resins used
and processed at the Mill. To characterize the ULR for processing purposes, EFRI requested
analytical data from Cotter. The Table in Attachment B shows the analytical data and a historic
summary of maximum concentrations of the analytes in other licensed materials received and
processed at the Mill. As can be seen from the data in Attachment B, the Schwartzwalder Mine ULR
concentrations are well below other materials licensed for processing at the Mill.
The number of trucks associated with transporting the ULR to the Mill will be slightly less than 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.
Other Considerations
Transport and Storage
As stated above, the number of trucks required to transport the ULR will be slightly less than the
number of trucks required to transport the quantity of ore needed to produce the same mass of
yellowcake. The ULR will be transported to the Mill in closed drums. EFRI plans to feed the material
directly into the Mill process upon receipt. Should the ULR need to be stored at the Mill prior to
processing, it will remain in the sealed drums, which will be stored on the Ore Storage Pad.
Disposal
RIS 2012-06 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
Letter to Rusty Lundberg
April 16, 2015
Page 4 of 4
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 1 le.(2) byproduct material and must be
disposed in accordance with NRC regulations." In accordance with RIS 2012-06, EFRI will return the
resin to Cotter for reuse at the Schwartzwalder Mine, reuse the resin at the Mill, or dispose of the
unusable, spent resin in the Mill's tailings impoundments.
If you should have any questions regarding this submittal please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Scott A. Bakken
ATTACHMENT A
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"1 (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.
' 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 11e.(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 11e.(2)
byproduct material under the Atomic Energy Act (AEA) and must be disposed of according to
NRC regulations.
The NRC staffs 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 11e(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."4 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 11e.(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 11e.(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-
92®) 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-92® 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
http://www.nrc.qov/readinq-rm/doc-collections/commission/secvs/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
CONTACT
RIS 2012-06
Page 7 of 7
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
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4/03/12 4/09/12 4/16/12 04/16/12
OFFICIA
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 11e.(2) byproduct material and must be disposed in accordance with
NRC regulations.
ATTACHMENT B
ANAYLTICAL DATA COMPARISON
Analytical Data Summary Schwartzwalder ULR
Component
Cone, in Ores and
Other Licensed
Materials (ppm)1
Cotter
Schwartzwalder
Mine Analytical
Results (mg/kg)
Arsenic (As) 3.5-16,130 ND
Beryllium (Be) 1-105 ND
Cadmium (Cd) 0.004-16 ND
Calcium (Ca) up to 217,000 1320
Cobalt (Co) 9-350,400 1.9
Chromium (Cr) 8-16,000 ND
Copper (Cu) Unknown 32 8
Iron (Fe) up to 46,000 320
Lead(Pb) 9-236,000 ND
Manganese (Mn) 172-3,070 1680
Mercury (Hg) 0.0004-14 ND
Molybdenum (Mo) 12-17,000 40 9
Nickel (Ni) 7-450,000 13.0
Selenium (Se) 0.02-710 1 0
Silver (Ag) 0.007-80 ND
Thallium (Tl) 0.02-960 ND
Tin (Sn) 20,900-116,000 ND
Vanadium (V) 10-25,000 ND
Zinc (Zn) 8-14,500 50.9
Pb-210(pCi/g) 39-173 3.5
Ra-226 (pCi/g) 156.0-989 5.3
Th-230 (pCi/g) 2550 - 23800 17
Th-232 (pCi/g) N/A ND
1 The concentration in other feeds represents some
selected concentrations for constituents found in
characterization data for other feed materials licensed for
processing at the Mill, for comparison purposes
ND = Not Detected