DRC-2015-004862 - 0901a0688055532f

UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTI ON MODULE RADMOD- SERP-O I
SAFETY AND ENVIRONMENTAL REVIEW PANEL ANNUAL REPORT REVIEW
ENERGY FUELS RESOURCES- WHITE MESA URANIIA4 MILL
RADIOACTIVE MATERIAL LICENSE UT I9OO47 9
References: Utah Administrative Code RML UT 1900479 License Condition 9.4
l) Describe what subject(s) were reviewed by the Mill's SERP.
Subject l: Energy Fuels Resources Inc. (EFRI) is in the process of evaluating uranium recovery
approaches and design for a proposed heap leaching facility to process natural uranium ores at EFRI's
Sheep Mountain Wyoming site. The proposed heap leach design required the collection of perfornance
data from a two-column pilot test, referred to as the "Test", to approximate conditions in a heap leach pile
at the Sheep Mountain Wyoming site. The proposed Test was to be conducted at White Mesa Mill (the
"Mill"). Any collected liquors from the test which were not shipped off-site for analysis would be
processed in the Mill's uranium recovery circuit. Residuals (tailings) from the column test would be
disposed in the Mill's tailings system.
Subject 2: The Mill has an existing License amendment to process KF altemate feed material from
Cameco Corporation, and proposes to modifu the recovery process as reflected in revisions to KF Node
Worksheets 3, 5, and 6. The Mill has previously processed KF alternate feed material in the main
Mill circuit by acid leaching prior to 2012, and by alkaline leaching following the process revision
approved in the June 2012 SERP evaluation (SERP 2012-04).
The previous process performed caustic digestion under conditions selected to digest uranium, and
perfbrmed the solid/liquid separation before caustic precipitation. The proposed revised process involves
washing the solids for removal of fluoride, alkaline/carbonate leaching, and steam addition for
temperature adjustment and removal of any fluoride values. Following fluoride removal, the produced
solids will undergo an additional sulfuric acid leaching step for recovery of uranium values. These
proposed modifications to the alkaline/carbonate leach process as evaluated in this SERP are expected to
produce higher uranium recoveries and require use of a smaller quantity of reagents.
Subject 3: EFRI planned to purify and concentrate hardened uranium ("yellowcake") attached to drum
shreds, which have been shipped in 85 gallon overpack drums, from the Honeywell Metropolis, Illinois
conversion facility. The proposed process is a modification of processes in practice at the Mill as
described in the Mill's 2007 license renewal application and existing EA documents. The proposed system
will re-dissolve yellowcake by attaching a processing lid to the overpack drum, placing it on a drum roller,
adding sulfuric acid and sodium chlorate, mixing, and draining of solution to a holding tank for
reintroduction into the Mill's solvent extraction circuit
2) Did the subject(s) meet the criteria found in License Condition 9.4.A? Yes X No
Explain:
Subject 1: The SERP reviewed the Test protocols, and the February 25,2013 Technical Memorandum by
Jo Ann Tischler describing the test process and materials, and determined that:
o If the recovered column solutions from the Test are to be processed in the Mill, the yellowcake
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Year Renorted Date of Report Date of Review
2013 March 31.2014 Julv 2l .2015
recovered will be minimal.o The quantity of leached ore from the Test to tre disposed in the Mill's tailings will be
immeasurably small compared to the capacitl of the Mill's tailings system.
o The test will not involve any new chemicals c,r ony new or increased emissions.o Procedures for personnel training, monitoring and personnel protective equipment are already in
place for Mill employees and contractors whc would be involved in the Test.
Subject 2: The SERP reviewed the Procedure described above and the July 1 ,2013 Jo Ann Tischler
Technical Memorandum evaluating the KF Process C hange, and determined that:
o The process will use the same carbonate, caustic and acid reagents already used at the Mill for
processing conventional ores and other alternate feed materials. The process will use a variation on
the flocculant from the same family of anionir: flocculants already used at the Mill.
o Although the potential for generation of HF fiom exposure of fluoride minerals to sulfuric acid
would be minimized as a result of the KF Pror:ess Change, Mill safety personnel will continue to
monitor for HF in the process area.o There are no changes proposed to the storage, unloading/dumping, or washing steps of KF
processing. The leached and washed process lrquids containing uranium will be transferred to the
existing SX, precipitation, drying and packagi,ng areas with no modifications required.
o As a result, no new Personnel Protective Equirlment ("PPE") would be required, no changes to
derived air concentration ("DACs") would be r:equired, and no new radiation or safety issues
would be produced by the KF Process Change.
o There would be no increase in environmental ,,:missions and no change in the nature or volume of
tailings due to the Change. The volumes of so utions and solid tailings that would be transferred to
the tailings cells will remain the same. There rvould be no new pathways of exposure to workers or
the public.
Subject 3: The SERP reviewed the proposed Node \foorksheets, engineering drawings, containment pad
photographs, and November 13,2013 Jo Ann Tischle ' Technical Memorandum describing the proposed
Drum Shred Process and determined that:o The material could be received as a licensee-tcr-licensee transfer of source material and could be
purified and concentrated at the Mill.o The SERP assessed that there would be no dust or vapor emissions of any significance from the
process, and no wastes other than those typically produced by the Mill's existing solvent extraction
and drying processes.
o The re-digested yellowcake will produce the sirme quantity of emissions as any other yellowcake
in the Mill circuit. Because the process does not involve storage of ores or bulk fbed materials, it
will produce fewer fugitive emissions/dusts than would be generated by producing the same
quantity of yellowcake from conventional ores or other alternate feed materials
o The Drum Shred Process does not require the rnodification of the Mill's Air Approval Order or any
other approved management plans. Approved procedures are already in place for the disposal of
crushed drums in the Mill's tailings cells.o Although the yellowcake encrusted on drum strreds is not an alternate feed material or other ore,
the volume of tailings that will be generated dtrring re-processing of the yellowcake will be
significantly less than the tailings that would b,) generated by producing the same amount of
yellowcake from ore
DWMRC Staff Review: Subject I was a test or experiment not presented in the application, Subject 2
was a change in an existing procedure and Subject 3 '*as a change in a process. Therefore, the subjects
reviewed by the SERP meet the criteria in License Condition 9.4.A.
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3) Did the subject(s) meet the criteria found in License Condition 9.4.8?
Explain:
Subject 1: The SERP concluded that:
o The Test does not conflict with any requirements, such as yellowcake production,
specifically stated in the license. Because it has no effect on Mill feeds or emissions, it
does not affect Mill operations in any aspect addressed by any of the Mill's permits or any
regulations.o Because the Test does not involve any new feeds, wastes, process materials or operating
conditions, it will not produce any degradation in the essential safety or environmental
commitments in the License application and will not produce any environmental impacts
beyond those assessed in the EA dated February 1997.. The test will have no effect on reclamation commitments, and will not cause the Mill to
exceed its approved tailings capacity.
Subject 2: The SERP concluded that:
o The KF SOP, as amended by the KF Process Change, does not conflict with any requirements
specifically stated in the license, or impair EFRI's ability to meet all applicable regulations. The
material to be processed is already covered by an existing license amendment and has previously
been processed according to the conditions of the license amendment and License Condition 10.11.
The Mill has remained in compliance with the License and other regulatory requirements while
running a comparable process, and fully expects to remain in compliance with the same
requirements when running the revised process.
o The KF Process Change will not produce any degradation in the essential safety or environmental
commitments in the License application, or provided by the approved reclamation plan. The KF
Process Change involves a feed already processed previously at the Mill, and involves no new
reagents, chemical or radiolo gical hazards or environmental emissions.
o The KF Process Change will have no effect on the Reclamation Plan. The volumes of solutions
and solid tailings that would be transferred to tailings would be the same whether the KF Material
were processed by the existing SOP or the proposed Change to the SOP. It would have no effect on
the volume or nature of tailings.
o The Yellowcake recovered from the KF alternate feed material will not cause the Mill to exceed
the yellowcake production limit under the Mill's license.
o The KF alternate feed material processing is addressed by an existing approved license amendment
and its scope is within the envelope of environmental conditions assumed in the EA.
Subject 3: The SERP concluded that:
o The Drum Shred Process is consistent with the plans and SOPs referenced in the approved License
and its renewal application. The Mill is already approved to process, purify, and concentrate
yellowcake and to dispose of crushed empty drums in the tailings system, which the Mill has
followed on a routine basis.
The drum handling and drum rolling area was designed consistent with requirements of the
Discharge Minimization Technology plan and Stormwater Best Management Practices Plan.
The Drum Shred Process will have no effect on the Reclamation Plan. The volumes of solutions
and solid tailings that would be transferred to tailings will be significantly less than those that
would be generated by producing the same amount of yellowcake fiom conventional ore or
alternate feed materials.
The Drum Shred Process 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.
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Paee 3 ol'4
Yes X No
DWMRC Staff Review: Each of the three subiects r,,:viewed by the SERP meet the criteria in License
Condition 9.4.8.
4) Did the SERP members meet the expertise criterit found in License Condition 9.4.C? Yes
No
Person and/or Job Title
erial and Financial Not documented
ions and/or Construction Not documented
Radiation Safet Not documented
Other:
Other
DWMRC Staff Review: Members of the SERP were not documented in the report. Therefore, Staff was
unable to verifv comnliance with the reouirement fourrd in License Condition 9.4.D.
5) Did the SERP Annual Report meet the criteria found in License Condition 9.4.D? Yes No X
Explain:
DWMRC Staff Review: The SERP report was submitted prior to March 3 I of the following year.
Changes to existing and new procedures were not attached to the report. The SERP followed the Mills
operating procedure for SERP reviews. Therefore, thr: SERP report does not meet all of the criteria in
License Condition 9.4.D. Staff will verify that records are being maintained in a future site inspection.
Identifi ed Deficiencies :
The following deficiencies were identified:
. Members of the SERP, as defined in License (londition 9.4.C., were not documented in the report;
ando Changes to existing and new procedures were not attached as required in License Condition 9.4.D.
ftlliJr.o u", Ryan Johnson 9-/o -/f
(Print Name)
Phil Goble
(Date)
(Print Name)(Signature)
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Supervisory
Review By:4-AZ
(Date)