DRC-2015-004864 - 0901a06880555331

UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-SERP-O I
SAFETY AND ENVIRONMENTAL REVIEW PANEL ANNUAL RE,PORT REVIEW
ENERGY FUELS RESOURCES- WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT I9OO47 9
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: The Mill has an existing License amendment to process KOH alternate feed materials from
Honeywell, (formerly known as Allied Signal Corporation, Metropolis Illinois), and proposes to modify
the recovery process. The Mill has previously processed KOH alternate feed materials through the
addition of water to the drums manually, by Mill personnel, prior to dumping. The previous leach process
used this water leach process to remove sodium and potassium salts followed by acid leaching and an
ammonium sulfate precipitation step.
The revised process does not add water to the drum prior to dumping, but uses an automated dumping
system that submerges the drums in water prior to dumping. The revised process eliminates the water
leach process and ammonium sulfate precipitation step because neither the water leach nor the ammonium
sulfate precipitation appreciably increase the uranium recovery. The proposed modifications to the process
are expected to reduce the potential for worker exposure through the submerged dumping station and to
produce higher uranium recoveries and require the use of less water and fewer reagents, specifically the
ammonium sulfate reagent, than the process approved in the previous SOP.
2) Did the subject(s) meet the criteria found in License Condition 9.4.A?
Explain:
Yes X No
Subject l:. The SERP reviewed the Procedure described above and determined that:o The Change will not require the use of any new chemicals, but will eliminate the use of additional
water and ammonium sulfate, thus reducing the amount of chemicals used in the production
processes.
The Change will not produce any additional respiratory hazards beyond those already managed at
the Mill in connection with other leach processes. There will be no new chemical reactions or ofT-
gasses associated with processing KOH under the SOP, as amended by the Change, that haven't
been experienced and handled safely by the Mill in connection with processing other alternate feed
materials. Specifically, the KOH SOP has been modified to introduce the material while
submerged, eliminating any dust.
There are no changes proposed to the storage, or washing steps of KOH processing. The leached
and washed process liquids containing uranium will be transferred to the existing SX,
precipitation, drying and packaging areas with no modifications required.
No new Personnel Protective Equipment ("PPE") would be required, no changes to derived air
concentration ("DACs") would be required, and no new radiation or safety issues would be
produced by the KOH Process Change.
o There would be no lncrease ln envlrorunental emissions and no chanse in the nature or volume of
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Year Renorted Date of Renort Date of Review
2014 March 19.2015 Julv 21. 201 5
tailings due to the Change. The volumes of solutions and solid tailings that would be transferred to
the tailings cells will remain the same. There 'xould be no new pathways of exposure to workers or
the public.
DWMRC Staff Review: Subject I was a change in en existing procedure. Therefore, the subject
reviewed by the SERP met the criteria in License Corrdition 9.4.A.
3) Did the subject(s) meet the criteria found in Licerrse Condition 9.4.8?
Explain:
Subject 1: The SERP concluded that:o The KOH SOP, as amended by the KOH Process Change, does not conflict with any requirements
specifically stated in the license, or impair EFRTs ability to meet all applicable regulations. The
material to be processed is already covered b1 an existing license amendment and has previously
been processed according to the conditions of the license amendment. The Mill has remained in
compliance with the License and other regularory requirements while running a comparable
process, and fully expects to remain in compliance with the same requirements when running the
revised process.
o The KOH Process Change will not produce arr.y degradation in the essential safety or
environmental commitments in the License ap'plication, or provided by the approved reclamation
plan. The KOH Process Change involves a fet::d already processed previously at the Mill, and
involves no new reagents, chemical or radiologicalhazards or environmental emissions.o The KOH 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 KOH
Material were processed by the existing SOP ,lr the proposed Change to the SOP. It would have no
effect on the volume or nature of tailings.
o The Yellowcake recovered from the KOH alte rnate feed material will not cause the Mill to exceed
the yellowcake production limit under the Mills license.o The KOH alternate feed material processing ir, addressed by an existing approved license
amendment and its scope is within the envelope of environmental conditions assumed in the EA.
DWMRC Staff Review: The subiect reviewed by thr: SERP met the criteria in License Condition 9.4.B.
4) Did the SERP members meet the expertise criterirr. found in License Condition 9.4.C? Yes
No
5) Did the SERP Annual Report meet the criteria fbund in License Condition 9.4.D? Yes _ No X
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Yes X No
Person andior Job Title
Manaserial and Financial Not documented
Operations andl or Construction Not documented
Radiation Safety Not documented
Other:
Other:
Other
Fvnlqin'
unable to verify compliance with the requirement fourrd in License Condition 9.4.C.
Explain:
DWMRC Staff Review: The SERP report was submitted prior to March 3lof the following year.
Changes to the existing procedure was not attached to the report. The SERP followed the Mills operating
procedure for SERP reviews. Therefore, the 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.
Identified Deficiencies:
The following deficiencies were identified:o Members of the SERP, as defined in License Condition 9.4.C., were not documented in the report;
ando Changes to existing and new procedures were not attached as required in License Condition9.4.D.
ltPgtt Rvan JohnsonReviewed Bv: ^tJ 8+a--/)-
(Date)
Supervisory
Review By:
(Print Name)
Phil Goble
(Print Name)(Signature)(Date)
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