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HomeMy WebLinkAboutDRC-2009-001003 - 0901a0688010f4d6DENISO MINES March 31, 2009 J>h 0\lC'^0O^'^-OOl0C5 Denison IHines (USA) Corp. 10S017th Street, Suite 990 Denver, CO 80269 USA Tet: 303 628-7798 Fax: 303 389-4129 www.denisonniines.com VIA PDF AND FEDERAL EXPRESS Mr. Dane L. Finerfrock Executive Secretary Utah Radiation Confrol Board State ofUtah Department ofEnvironmental Quality 168 North 1950 West Sah Lake City, UT 84114-4850 Re: White Mesa Uranium Mill; Radioactive Materials License No. UT 1900479 - Safety and Environmental Review Panel ("SERP") 2008 Annual Report Dear Mr. Finerfrock: Enclosed please find the 2008 Annual SERF Report for the White Mesa Mill, which is being submitted in compliance with condition 9.4 C of State of Utah Radioactive Materials License No. UT 1900479 (the "License"). We note that License condition 9.4 C does not stipulate a date by which the Annual SERF Report is to be submitted each year. However, the Mill's SERF Standard Operating Procedure (PBL-1 Rev. No.: R-4, Febmary 25, 2007) states that the Annual SERF Report is to be filed within 60 days after the calendar year end. We are bringing this to your attention, because we just realized that we inadvertently missed that filing date. By mistake, we followed the practices of previous years and are filing this report within 90 days after calendar year end. We will note the 60-day filing requirement for next year's filing. If you have any questions or require any further information, please contact the undersigned. Yours tmly. ^^^^^/^•.^•^IA— David C. Frydenlund Vice President Regulatory Affairs and Counsel cc: Ron F. Hochstein Harold R. Roberts Steven D. Landau David E. Turk WHITE MESA MILL SAFETY AND ENVIRONMENTAL REVIEW PANEL (SERF) 2008 ANNUAL REPORT March 30, 2009 Submitted to the Utah Department of Environmental Quality Division of Radiation Control Submitted by: White Mesa Uranium Mill License No. UT 1900479 1. INTRODUCTION This report is being submitted by Denison Mines (USA) Corp. ("DUSA"), licensee of the White Mesa Uranium Mill (the "Mill"), to the Utah Division of Radiation Control ("DRC") in compliance with condition 9.4 C of State of Utah Radioactive Materials License No. UT 1900479 (the "License"). There were four Safety and Environmental Review Panel ("SERF") evaluations conducted for the period of January 1, 2008 through December 31, 2008. Each SERF evaluation and review was conducted in accordance with SERF procedures set forth in the Mill's Standard Operating Procedure PBL-1, Rev. No. R-4 (the "SERF SOP"). The evaluations are summarized below in Section 2. 2. SUMMARY OF EVALUATIONS This section describes the changes, tests or experiments evaluated by the SERF pursuant to License condition 9.4, and summarizes the evaluations performed and actions taken by the SERF relative to each. In each case, the SERF consisted of those individuals specified in License condition 9.4 C, with additional members included as appropriate, to address technical aspects. The SERF followed the SERF SOP as it performed its evaluations, to ensure that the actions taken satisfy the following 3 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 Febmary 1997 (the "1997 Environmental Assessment"). 2.1. SERF Report No. 2008-01 March 3, 2008 2.1.1. Proposed Acrion Review and approve PBL-20 Rev. No.: R-0, SX Organic Reconditioning Process (the "SX Reconditioning Procedure"). 2.1.2. Description of Change. Tests or Experiment The Mill uses kerosene solvent as the hydrocarbon extraction organic in its solvent exfraction circuit. Over its service life, the solvent in the circuit can accumulate organic impurities and breakdown products in the form of esters, soaps, and complexes. In order to improve the ability of this solvent to extract uranium or vanadium and to prolong its usefijl life, an SX Reconditioning Procedure can be applied from time to time as a process step to strip impurities from the kerosene, primarily through contact with a polar solvent, methanol. After completion of this process step, the methanol and other associated wastes containing the transferred impurities and trace radionuclides will be disposed ofin the Mill's taihngs cells. For the 2008 reporting period, the SERF considered SX reconditioning and reviewed a reconditioning process for the vanadium SX circuit. Similarly, in 2009 the SERF will consider modification ofthe SX Reconditioning Procedure to accommodate the reconditioning of kerosene used in uranium SX circuit as well. 2.1.3. Safetv and Environmental Evaluation ofthis SERF action The SERF concluded that: a) The SX Reconditioning Procedure for kerosene in the vanadium circuit does not conflict with any requirement specifically stated in the License, or impair DUSA's ability to meet all applicable regulations. In fact, implementation of the SX Reconditioning Procedure satisfies the requirement of the Mill's License condition 9.6 that standard operating procedures shall be established and followed for all operational process activities involving radioactive materials that are handled, processed or stored. The procedures set out in the SX Reconditioning Procedure are intended to be performed from time to time in order to enhance recoveries at the Mill and to prolong the use of process reagents. These procedures will be performed in accordance with all applicable regulations and the Mill's License. b) There will be no degradation in the essential safety or environmental commitments in the License application or provided by the approved reclamation plan as a result of performing the process steps set out in the SX Reconditioning Procedure. The vanadium SX Reconditioning Procedure was reviewed by DUSA's independent chemical engineer to ensure that there would be no significant health or safety concems with the process. Based on this review, the SERF concluded that: 1) the SX Reconditioning Process will not result in any emissions to the atmosphere; 2) the procedure can be followed safely without the need for any additional engineering confrols, using existing radiation and occupational safety precautions and procedures at the site; and 3) the processes are not inconsistent with the evaluations contained in the environmental commitments in the Mill's License. Based on the evaluation conducted by DUSA's consultant, the SERP concluded that in performing the process steps set out in the procedure, there would be no expected reactions with other compounds in the Mill's process or contained in the tailings cell, given standard precautions typically taken at the site, and that the tailings cell liner would be unaffected by the process. c) The use of this SX Reconditioning Procedure is consistent with the conclusions of actions analyzed and selected in the 1997 Environmental Assessment. There are no expected emissions from implementation of the process. Further, to the extent that the process prolongs the life of the kerosene used in the Mill's SX circuit, it reduces the amount of kerosene ultimately discharged to the Mill's tailings cells. The Mill has historically used methanol on site as a laboratory chemical and also uses other alcohols and polar oxygenated volatile organic compounds, such as ketones, which have higher toxicity, greater volatility, as well as comparable solubility, density and biodegradability. 2.1.4. SERP Action The SERP concluded that the SX Reconditioning Procedure met the criteria set forth in the SERP SOP for approval, and was approved for immediate implementation. This SERP action resulted in no changes to any pages ofthe 1997 License Renewal Application or the Mill's Reclamation Plan. 2.2. SERP Report No. 2008-02 August 21, 2008 2.2.1. Proposed Action Review and approve modifications to the Radiation Protection Manual regarding access control and personnel scanning. 2.2.2. Description of Change. Tests or Experiment New language was added to Section 1.2.3 ofthe Mill's Radiation Protection Manual (PBL-RP-1, Rev. No. DUSA-2) (the "Radiation Protection Manual") as follows: • Adding new paragraph 7 which sets certain restrictions on the entry/exit access points to the Mill's Restricted Area that may be utilized by various categories of workers; and • Adding new paragraph 8 which requires that a Radiation Technician be positioned at certain access points at certain times to monitor personnel scanning at such points, or that a fiill body scanning portal be located at such access points. These changes to the Radiation Protection Manual were made in response to a Notice of Violation (the "NOV") dated June 9, 2008 issued by the Executive Secretary ofthe State ofUtah Radiation Control Board. 2.2.3. Safetv and Environmental Evaluation ofthis SERP action The SERP reviewed the changes to the Radiation Protection Manual described above and made the following conclusions: a) The changes reflect commitments made to the Executive Secretary in response to the NOV, and are intended to improve the ability of the Mill to comply with its License and all applicable regulatory requirements. Accordingly, the SERP concluded that the changes to the Radiation Protection Manual will not conflict with any requirement specifically stated in the license, or impair DUSA's ability to meet all applicable regulations. b) The changes effect improvements to worker health and safety by improving DUSA's ability to control and monitor personnel scatming and do not have any environmental impacts. Therefore, the SERP determined that approval ofthe changes to the Radiation Protection Manual would produce no degradation in the essential safety or environmental commitments in the license application, or provided by the approved reclamation plan. c) As the changes effect improvements to worker health and safety by improving DUSA's ability to control and monitor persormel scarming and do not have any environmental impacts, the SERP concluded that the changes to the Radiation Protection Manual are expected to produce no environmental impacts beyond those assessed in the 1997 Environmental Assessment, and are consistent with the conclusions regarding actions analyzed in the 1997 Environmental Assessment. 2.2.4. SERP Action The SERP concluded that the changes to the Radiation Protection Manual meet the criteria in the SERP SOP for approval, and approved the changes. The SERP action resulted in a change to the Mill's Radiation Protection Manual. Attached is a revised Section 1.2.3 ofthe Mill's Radiation Protection Manual, marked to indicate the changes. 2.3. SERP Report No. 2008-03 October 24, 2008 2.3.1. Proposed Action Review and approve changes to update the Mill's standard operating procedure relating to the disposal of lle.(2) byproduct material ("Byproduct Material") received from in-situ leach ("ISL") uranium recovery facilities (PBL-10, Rev. No. R-0) (the "1 le.(2) Procedure") 2.3.2. Description of Change. Tests or Experiment The purpose ofthis SERP action was to review the following proposed changes to update the 1 le.(2) Procedure: • Change references to Intemational Uranium (USA) Corporation to be references to Denison Mines (USA) Corp.; • Expand the list of radionuclides to be included in pre-receipt characterization data. The 11 e.(2) Procedure required that pre-receipt characterization data include analytical results for Unat as the only radionuclide. The proposed changes included the requirement to obtain pre-receipt characterization data for Ra-226, Th-230 and Pb- 210 in addition to Unat; • Change the marmer in which organics are addressed by eliminating semi volatile organic compounds ("SVOCs") from the list of required pre-receipt characterization data and by prescribing additional procedures to be followed upon the measurement of any volatile organic compounds ("VOCs") post receipt; • Clarify wording to expressly acknowledge the appropriateness of reliance on analytical sample results for previous shipments if they are representative or current shipments; and • Make several other administrative corrections and improvements to the lle.(2) Procedure. 2.3.3. Safetv and Environmental Evaluation ofthis SERP action The SERP reviewed the proposed changes to the lle.(2) Procedure and made the following conclusions: a) The changes are intended to improve the ability of the Mill to comply with its License and all applicable regulatory requirements, by allowing Mill persoimel to focus attention more closely on the primary issues of health and safety. Additional characterization data for radionuclides and additional procedures relating to VOCs have been added, which address health and safety concems, while other provisions that do not impact health and safety have been eliminated. Accordingly, the SERP concluded that the changes to the lle.(2) Procedure will not conflict with any requirement specifically stated in the license, or impair DUSA's ability to meet all applicable regulations. b) The changes effect improvements to worker health and safety by focusing attention on the potential radiological hazards associated with the receipt and handling of Byproduct Material, which are the primary hazards associated with Byproduct Material. In addition procedures relating to managing any V[OCs that may be associated with Byproduct Material, which could potentially give rise to worker health and safety concems, have been added. The other changes to the Procedure are either administrative in nature or serve to eliminate provisions of the Procedure that have no significant impact on public health, safety or the environment. There 'are no health and safety issues impacted by the presence of SVOCs in Byproduct Material that are different from any other precautions normally taken at the Mill site for such materials. Mill persormel routinely handle compounds at the Mill that contain SVOCs. For these and other reasons, the requirement to obtain pre-receipt characterization data for SVOCs was eliminated. As a result, the SERP determined that approval ofthe changes to the 1 le.(2) Procedure would produce no degradation in the essential I safety or environmental commitments in the license application, or provided by the approved reclamation plan. c) As the changes effect improvements to worker health and safety and do not have any environmental impacts, the SERP concluded that the changes to the lle.(2) Procedure are expected to produce no environmental impacts beyond those assessed in the 1997 Environmental Assessment, and are consistent with the conclusions regarding actions analyzed in the 1997 Environmental Assessment. 2.3.4. SERP Action The SERP concluded that the changes to the 1 le.(2) Procedure meet the criteria set forth in the SERP SOP for approval, and approved the changes. This SERP action resulted in no changes to any pages ofthe 1997 License Renewal Application or the Mill's Reclamation Plan. 2.4 SERP Report No. 2008-04 October 28, 2008 2.4.1 Proposed Action Review and approve changes made to update the Mill's standard operating procedure at PBL-7, Rev. No. R-0 (the "Mill Waste Disposal Procedure") relating to the disposal of non-tailings waste generated at or from the Mill site facilities. 2.4.2 Description of Change, Tests or Experiment The SERP reviewed and approved the following changes made to update the Mill Waste Disposal Procedure: • Consolidate the Mill Waste Disposal Procedure, which previously had been comprised of two separate and somewhat conflicting submissions to the Nuclear Regulatory Commission (NRC"), into a single document, and in so doing update the format ofthe Procedure; • Make certain minor changes and improvements to the Mill Waste Disposal Procedure to reflect changes in Mill practices over the years; and • Make several other administrative corrections and improvements to the Mill Waste Disposal Procedure. The Mill Waste Disposal Procedure in its current form was adopted in 1995 and was comprised of two submissions made by Energy Fuels Nuclear, Inc., a former operator of the Mill: a submission to the NRC dated December 12, 1994, with Attachment A thereto entitled "Procedure: Radioactive Contaminated Waste Disposal"; and a submission from Energy Fuels to the NRC dated May 23, 1995, which expanded the scope ofthe December 12, 1994 to, among other things, extend the scope of the Mill Waste disposal activities to include Mill Waste that is not radioactively contaminated. Current condition 10.4 ofthe Mill's State ofUtah Radioactive Materials License states that: 10.4 "Disposal of Material and equipment generated at the mill site shall be conducted as described in the licensee's submittals to the NRC dated December 12, 1994 and May 23, 1995, with the following addition: A. The maximum lift thickness for materials placed over tailings shall be less than 4-feet thick. Subsequent lifts shall be less than 2-feet thick. Each lift shall be compacted by tracking of heavy equipment, such as a Cat D-6, at least 4 times prior to placement of subsequent lifts." The Mill Waste Disposal Procedure has continued to date as a compilation of the commitments contained in the December 12, 1994 and May 23, 1995 letters, and has never been compiled into one document and introduced into the Mill's document control system. The SERP concluded that it would be appropriate to update the Mill Waste Disposal Procedure to reflect current Mill practices, to compile the Mill Waste Disposal Procedure into one document and to add the revised Mill Waste Disposal Procedure to the Mill's document control system. 2.4.3 Safety and Environmental Evaluation ofthis SERP action The SERP reviewed the Mill's waste disposal practices and the commitment letters described above and made the following conclusions: a) The consolidation of disposal practices into a single Mill Waste Disposal Procedure does not conflict with any requirement specifically stated in the License, or impair the licensee's ability to meet all applicable regulations. Consohdation of the Mill's non- tailing disposal practices is an improvement to the Mill's disposal program, bringing all requirements into one procedure. b) The consolidation of disposal practices into a single Mill Waste Disposal Procedure will not cause degradation in the essential safety or environmental commitments in the License application or provided by the approved reclamation plan. By consolidating the disposal practices into a single procedure, the practices are more understandable by Mill personnel and there is less chance for errors or mistakes in disposal activities. c) The consolidation of disposal practices into a single Mill Waste disposal Procedure is consistent with the conclusions of actions analyzed and selected in the 1997 Environmental Assessment. The proposed Mill Waste Procedure effects improvements to non-tailings disposal and is within the scope of the prior assessment of the facility's impact. 2.4.4 SERP Action The SERP concluded that updating the Mill Waste Disposal Procedure to reflect current Mill practices and compiling the Mill Waste Disposal Procedure into one document meets the criteria set forth in the SERP SOP for approval, and that the updated and consolidated Mill Waste Disposal Procedure be approved. This SERP action resulted in no changes to any pages ofthe 1997 License Renewal Application or the Mill's Reclamation Plan. ATTACHMENT 1 1.2.3 Monitoring Procedures The monitoring procedure includes the following steps: 1. The alarm rate meter is adjusted within the range of 500 to 750 dpm/100 cm to ensure a margin of 250 dpm/100 cm' due to the low efficiency of this instmmentation. 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 VA 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. 6. Individual surveys are to be logged and initialed. 7. Access to and from the Mill's Restricted Area bv all Mill workers, contractors and deliverv personnel, other than Radiation. Safety and Environmental Staff Senior Laboratorv personnel. Mill Management and Mill Supervisory personnel and others as mav 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 scanning 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 incoiporate the use and maintenance of such portal or portals.