DRC-2015-001884 - 0901a06880513fe3

f ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
March 19,2015 DRC-2015-001884
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill - RML UT1900479
Transmittal of Safety and Environmental Review Panel ("SERP") Annual Report
Dear Mr. Lundberg:
Enclosed please find the 2014 Annual SERP 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.
If you have any questions, please contact me at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Harold R. Roberts
David Turk
Scott Bakken
Attachments
WHITE MESA MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL ("SERP")
2014 ANNUAL REPORT
Submitted to the Utah Department of Environmental Quality
Division of Radiation Control
Submitted by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 19,2015
1. INTRODUCTION
This report is being submitted by Energy Fuels Resources (USA) Inc. ("EFRI"), licensee of the
White Mesa Uranium Mill (the "Mill") to the Utah Division of Radiation Control ("DRC") in
compliance with condition 9.4D of State of Utah Radioactive Materials License No. UT 1900479
(the "License").
There was one Safety and Environmental Review Panel ("SERP") evaluation conducted for the
period of January 1, 2014 through December 31, 2014. The SERP evaluation and review was
conducted in accordance with SERP procedures set forth in the Mill's Standard Operating
Procedure PBL-1, Rev. No. R-6 (the "SERP SOP"). The evaluation is summarized below in
Section 2.
2. SUMMARY OF EVALUATIONS
This section describes the change, test, or experiment evaluated by the SERP pursuant to License
condition 9.4, and summarizes the evaluations performed and actions taken by the SERP relative
to each.
In each case, the SERP consisted of those individuals specified in License condition 9.4 C, with
additional members included as appropriate, to address specific technical issues.
The SERP followed the SERP SOP as it performed its evaluations, to ensure that the actions
taken satisfy the following three 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 February 1997 (the "1997
Environmental Assessment).
2.1. SERP Report No. 2014-01 December 18, 2014
KOH Process SOP
2.1.1. Proposed Action
Review and approve revisions (the "KOH Process Change") to the existing Standard
Operating Procedure ("SOP" or "Procedure") for processing Honeywell, (formerly
known as Allied Signal Corporation, Metropolis Illinois) alternate feed materials.
2.1.2. Descriptions of Change. Tests or Experiments
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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.
2.1.3 Safety and Environmental Evaluation of this SERP Action
The SERP reviewed the Procedure described above and determined that:
a) 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.
b) 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 off-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.
c) 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.
d) 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.
e) There would be no increase in environmental emissions and no change in the nature or
volume of 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 would be no new
pathways of exposure to workers or the public.
2.1.4 SERP Action
The SERP concluded that:
a) 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 by 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
regulatory requirements while running a comparable process, and fully expects to remain
in compliance with the same requirements when running the revised process.
b) The KOH 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 KOH Process Change involves a feed already processed
previously at the Mill, and involves no new reagents, chemical or radiological hazards or
environmental emissions.
c) 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 or the proposed Change
to the SOP. It would have no effect on the volume or nature of tailings.
d) The Yellowcake recovered from the KOH alternate feed material will not cause the Mill
to exceed the yellowcake production limit under the Mills license.
e) The KOH 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
The SERP concluded that the Procedure meets the criteria set forth in the SERP SOP for
approval, and approved the revised KOH Procedure.
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