DRC-2015-004859 - 0901a0688055532a

UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD.SERP-O 1
SAFETY AND ENVIRONMENTAL REVIEW PANEL ANNUAL REPORT REVIEW
ENERGY FUELS RESOURCES. WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT I9OO479
References: Utah Administrative Code RML UT 1900479 License Condition 9.4
1) Describe what subject(s) were reviewed by the Mill's SERP.
Subject 1: Review and approve modifrcations to the Uranium Solvent Extraction ("SX") circuit
configuration and revisions to the Standard Operating Procedure for the Uranium SX circuit (the Uranium
SX SOP"), SOP Book 4 Sections 2 and3.
Subject 2: Review and approve revisions (the "Calcined Change") to the Calcined altemate feed material
("Calcined Material") Standard Operating Procedure (the "SOP" or "Calcined Material SOP") for
processing of Calcined Material from Cameco Corporation's Blind River Facility. PBL-13, Nodes 1
through 3 (the "Procedure")
Subject 3: Review and approve modifications to the Calcined alternate feed material ("Calcined
Material") drum unloading arealfeed addition area for feeding of Calcined material from Cameco
Comoration's Blind River Facility (the "Drum Unloading Change").
Subject 4: Review and approve revisions (the "KF Change") to the KF alternate feed material ("KF
Material" or "KF") Standard Operating Procedure (the "SOP" or "KF SOP") for processing of KF Material
from Cameco Corporation's Port Hope Facility.
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 proposed revision and determined that:
o Since the Change was limited to re-arrangement of piping, it involved no new feeds, reagents or
other materials, or changes to rates of addition.
o The Change does not generate any new radiation or occupational safety issues.
o The Change has no impact on environmental emissions or on the tailings system
Subject 2: The SERP reviewed the Procedure described above and concluded that:
o The Calcined Change will eliminate the use of two reagents (ammonia and caustic) for this feed,
and will reduce the concentration of sulfuric acid required for this feed.
o The process will use the same solvent extraction and drying and packaging nodes as used for ores
and previously used for this alternate feed. .
o As a result, no new Personnel Protective Equipment ("PPE") would be required, no changes to
derived air concentration ("DACs") would be requiredo and no new radiation or safety issues
would be produced by the Calcined Change.
o There would be no increase in environmental emissions and no change in nature or volume of
tailings due to the Calcined Change
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Year Renorted Date of Renort Date of Review
20t2 March 29,2013 Julv 21. 2015
Subject 3: The SERP evaluated information and correspondence related to the proposed Drum Unloading
Change and determined that the change is limited to an extension of an existing concrete pad and involves
no process, feed, or material change whatsoever.
Therefore, there are no anticipated new environmental emissions or emission sources, no additional
impacts on existing worker safety and no effects on the process or the tailings system. The Drum
Unloading Change will allow the transfer truck to pull closer to the emptying station, and will provide a
means to prevent any contact between residual wash water in the drums with the ground surface
Subject 4: The SERP evaluated the proposed KF Change and determined that:
• Based on a radiological characterization of a composite from a number of drums, the KF material
is comparable to previous KF material received and processed at the Mill.
• The proposed KF Change to the SOP will provide improved management of fluoride ion from the
KF. The KF Change will remove the fluoride ion in a water environment, leach the uranium in a
carbonate environment, and eliminate any opportunity for fluoride exposure to sulfuric acid.
• The processing will not require the use of any additional chemicals beyond those already in storage
and use at the Mill, and due to the elimination of sulfuric acid from the processing will use fewer
chemicals and fewer process steps. Therefore, there will be no new emissions or emissions
sources, no new sources of exposure to workers or the public, and no changes in DACs or PPE
re uired
DWMRC Staff Review: Each of the four subjects reviewed by the SERP were changes in procedures and
processes. Therefore, the subjects reviewed by the SERP meet the criteria in License Condition 9.4.A.
3) Did the subject(s) meet the criteria found in License Condition 9.4.B? Yes _x_ No
Ex lain:
Subject 1: The SERP concluded that:
• The Change, 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.
• The Change will not produce any degradation in the essential safety or environmental
commitments in the License application, its scope is within the envelope of environmental
conditions assumed in the EA, and it has no effect on reclamation commitments. The Change will
not modify types or rates of feed, will not produce any new environmental emissions, and has no
effect on tailings.
• The Change does not involve any new feeds, wastes, process material or operating conditions, and
would therefore produce no environmental impact beyond those assessed in the EA dated February
1997.
Subject 2: The SERP concluded that:
• The Procedure, as amended by the Calcined Change, does not conflict with any requirements
specifically stated in the license, or impair EFRI's ability to meet all applicable regulations. The
material is already covered by an existing license amendment. The Mill has remained in
compliance with the License and other regulatory requirements while running this and other feeds
requiring more processing stages and reagents than the revised Procedure.
• The Calcined 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
Calcined Change involves a feed already processed previously at the Mill, and involves no new
reagents, chemical or radiological hazards or environmental emissions. It would have no effect on
the volume or nature of tailings.
• The Calcined Change is not expected to produce any environmental impacts beyond those assessed
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in the EA dated February 1997, and is consistent with the conclusions regarding actions analyzed
in the EA. The Calcined Change would use fewer and/or lower concentration of reagents than
assumed in the EA, and produce no new environmental emissions. The volumes of solutions and
solid tailings that would be transferred to the tailings cells will remain the same. There would be
no new pathways of exposure to workers or the public.
Subject 3: The SERP concluded that:o The Drum Unloading Change does not conflict with any requirements specifically stated in the
license, or impair EFRI's ability to meet all applicable regulations. It will improve EFRI's ability to
comply with Part I.D.I l.d of the Mill's Groundwater Discharge Permit.
The Drum Unloading Change will not produce any degradation in the essential safety or
environmental commitments in the License application, or provided by the approved reclamation
plan, and therefore this criterion is met. The reclamation surety estimate already addresses removal
and disposal of surface concrete and the additional volume of concrete resulting from the Drum
Unloading Change is too small to affect the estimate.
The Drum Unloading Change has no effect on any assumption or condition assumed in the EA
dated February 1997. Therefore, the Drum Unloading Change is not expected to produce any
environmental impacts beyond those assessed in the EA, and is consistent with the conclusions
regarding actions analyzed in the EA.
Subject 4: The SERP concluded that:
o The KF Change does not conflict with any requirements specifically stated in the License, or
impair EFRI's ability to meet all applicable regulations. Processing of the feed is already covered
by an existing license condition. The Mill has remained in compliance with the License and other
regulatory requirements while running a comparable process as will be required under the KF
Change. The yellowcake recovered from the KF material will not cause the Mill to exceed the
yellowcake production limit under the License.
o The KF Change (increase in volume) will not produce any degradation in the essential safety or
environmental commitments in the License application, or provided by the approved reclamation
plan, and therefore this criterion is met. The KF Change will not affect the volume of tailings,
which would be the same whether the former or proposed process is used.o The KF Change 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. All reagents proposed in the change are within the envelope of materials considered in the
EA.
DWMRC Staff Review: Each of the four subjects reviewed by the SERP were changes in procedures and
processes. Therefore, the subjects reviewed by the SERP meet the criteria in License Condition 9.4.8.
4) Did the SERP members meet the expertise criteria found in License Condition 9.4.C? Yes
No
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Person and/or Job Title
Manaserial and Financial Not documented
Ooerations and/or Construction Not documented
Radiation Safety Not documented
Other:
Other:
Other
Explain:
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DWMRC Staff Review: Members of the SERP wer( not documented in the report. Therefore Staft was
unable to verify compliance with the requirement found in License Condition 9.4.D.
5) Did the SERP Annual Report meet the criteria fotrnd in License Condition 9.4.D? Yes X No
Explain:
DWMRC Staff Review: The SERP report was submitted prior to March 3lof the following year.
Changes to procedures were attached to the report. The SERP followed the Mills operating procedure for
SERP reviews. Therefore, the SERP report meets the criteria in License Condition 9.4.D. Staff will
verify that records are being maintained in a future sir.e inspection.
Identified Deficiencies:
The following deficiency was identified:. Members of the SERP, as defined in License t.londition 9.4.C., were not documented in the report
Report
Reviewed
Supervisory
Review By:
Rvan JohnsonItv:
(Print Name)
Phil Goble
{-/c: - /f
(Date)rz/?(Y/"/, f
(Print Name)(Signature)(Date)
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