DRC-2015-004804 - 0901a06880554e57

State of Utah
CARYR. HERBERT
Governor
SPENCERJ. COX
Lieutetnnt Governor
Department of
Environmental Quality
Alan Matheson
Exccative Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
August 12,2015
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Radioactive Material License (RML) Number UT1900479: Health Physics Inspection
RADMOD-SERP-02 Annual SERP Report Review
Dear Ms. Weinel:
The Division of Waste Management and Radiation Control has completed its review of the Annual
Safety and Environmental Review Panel (SERP) reports for the yearc2012,2013, and 2014. The
purpose of the review was to determine compliance with the requirements of License Condition 9.4 of
your facility's Radioactive Material License Ln 1900479. 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 that were reviewed by the SERP were not attached to
two of the annual SERP reports as required in License Condition 9.4.D.
These deficiencies are considered minor in nature and are not a safety or environmental concern.
However, the Division expects the required information to be included in future SERP reports. Please
find enclosed copies of the report reviews.
Ifyou have any questions, please call Ryan Johnson at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Contol
STAIRMJ/ka
195 North 1950 West. Salt lake City, UT
Mailing Address: P.O. Box 1,14880 . Salt l:ke City, UT E4l144880
Telephone [phone]. Fax (801) s364222. T.D.D. (801) 5364414
wwn'.deq.utah.gov
Printed on 100% recycled paper
DRC-2015404804
Page2
Enclosures: Report Reviews
c: Worthy Glover, Health Officer, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Deparfrnent
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD.SERP.O I
SAFETY AND E}WIRONMENTAL REVIEW PANEL AI{NUAL REPORT REVIEW
ENERGY FI.JELS RESOURCES- WHITE MESA I.JRAI{II,JM MILL
RADIOACTIVE MATERIAL LICENSE UTI9OO479
References: Utah Administrative Code RML UT 1900479 License Condition 9.4
l) Describe what subjec(s) were reviewed by the Mill's SERP.
Subject l: Review and approve modifications to the Uranirm Solvent Extraction ("SX') circuit
configrration and rcvisions to the Sandard Operating Procedure for the Uranium SX circuit (the Uranium
SX SOP"). SOP Book 4 Sections 2 and 3.
Subject 2: Review and approve revisions (the "Calcined Change') to the Calcined altemate feed material
('Calcined Material') Standard Operating Procedure (the I'SOP" or "Calcined Material SOP") for
processing of Calcined Material from Cameco Corporation's Blind River Facility. PBL-I3, Nodes I
through 3 (the "Procedure')
Subject 3: Review and approve modifications to the Calcined alternate feed material ("Calcined
Material") drum urloading area/feed addition area for feeding of Calcined material from Cameco
Corporation's Blind River Facility (the'Drum Unloading Change").
Subject 4: Review and approve revisions (the "KF Change") to the KF alternate feed materid ('KF
Materialn or nKF") Standard Operating Procedure (the 'SOP' or "KF SOP') for proccssing of KF Material
from Cameco Corpora{on's Port Hope Facility.
2) Did the subject(s) meet the criteria found in License Condition 9.4.A? Yes X No
Exolain:
Subject l: The SERP reviewed the proposed revision and determined that:
o Since the Change was limited to r€-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 Chanee has no impact on environmental emissions or on thqtai[lqgryyge4q
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 concentation of sulfuric acid requircd for this fbed.
o The prrocess will use the sarne solvent extaction and drying and packaging nodes as used for ores
and previously used for this alternate feed. .
o Asa result, 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 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 Reported Date of Reoort Date of Revierw
2012 March 29,2013 JulY 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 existingconcrete pad and involvei
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 tansfer truck to pull closer to the emptying statioq and will provide a
mqpr.ts to Prevent antconlact belveen residual wash water in the drums with the ground surface
subject 4: The SERP evaluated the proposed KF change and determined that:o 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 provid,e 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 environmenf and eliminate any oppodunity for fluoride exposure to sulfuric acid.o The processing will not require the use of any additional chemicals beyond those alr,eady in storage
and use at the Mill, and due to the eliminatiron 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
DWMRC Staff Review: Each of the four subjects reviewed by the SERP were changes in procedures and
processes. Therefore, the subjects reviewed by the SERII meet the criteria in License Condition 9,4.A.
3) Did the subject(s) meet the criteria found in License ition 9.4.8?Yes X_No
Subject 1: The SERP concluded that:o The Change, does not conflict with any requi such as yellowcake production, specifically
stated in the license. Because it has no effect on
operations in any aspect addressed by any ofthe
feeds or emissions, it does not affect Mill
permits or any regulations.o The Change will not produce any degradation in lhe essential safety or environmental
commitments in the License application, its is within the envelope of environmental
conditions assumed in the EA, and it has no effedt on reclamation commitments. The Change will
not modify t)?es or rates of feed, will not produce any new environmental emissions, and has no
effect on tailings.o The Change does not involve any new feeds, wastes, process material or operating conditions, and
would therefore produce nd environmental impact beyond those assessed in the EA dated February
t997.
Subject 2: The SERP concluded that:o 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 regulatorl, requirements while running this and other feeds
requiring more prccessing stages and reagents tlurn the revised Procedure.o The Calcined Change will not produce any degradation in the essential safety or environmental
commitnents in the License applicatioq 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. Ii would have no effect on
the volume or nature of tailings.o The Calcined Change is not expected to produce Ery environmental impacts beyond those assessed
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in the EA dated Febnrary 1997, and is consistent with the conclusions regarding actions analped
in the EA. The Calcined Changd 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 ransferred 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 Growrdwater Discharge Permit.r The Drum Unloading Change will not prduo€ any degndation in the essential safety or
environmental commitnents in the License application, or provided by the approved reclamation
plan, and thenefore this criterion is met. The reclamation surety estimate alrcady addresses removal
and disposal of surface concrpte and the additional volume of concrete resulting from the Drum
Unloading Change is too small to affect the estimate.o The Drurn Unloading Change has no effect on any assumption or condition aszumed 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.
Subiect 4: The SERP concluded that:o The KF Change does not conllict with any requirements specifically stated in the License, or
impair EFRI's ability to meet all applicable rcgulations. 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 rururing a comparable process as will be rcquired 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 commitnents 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 tbe forrrer or proposed process is used.o The KF Change is not expected to producc 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 r€agents proposed in the change are within the envelope of materials considered in the
EA.
DWMRC StafrReview: 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.B.
4) Did the SERP members meet the expertise critcria found in License Condition 9.4.C? Yes
-No
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PrgP 3 of4
Person and/or Job Title
Manacerial and Financial Not documented
Operations and/or Constnrction Not documented
Radiation Safety Not documented
Other:
Other:
Other
Exolain:
DWMRC StaffReview: Members of the SERP
unable to verifu compliance with the
not documented in the report Therefore Staffwas
in License Condition 9.4.D.
5) Did the SERP Annual Report meet the criteria found in License Condition 9.4.D? Yes X No
Explain:
DWMRC StaffReview: The SERP report was submittpd prior to March 31of the following year.
Changes to procedures were atached 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. Statrwill
verify that records are being maintained in a future sire inspection.
Identilied Defi ciencies :
The following deficiency was identified:e Members of the SERP, as defined in License Condition 9.4.C., were not documented in the report
Report
Reviewed By:
Supervisory
Review By:
Ryan Johnson
(Print Nanre)
Phil Goble
{-/ct {
(Date)
r/"/, r
(Print Name)(Signatwe)(Date)
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UTAH DIVISION OT RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD,SERP-O 1
SAFEry AND E}.IVIRONMENTAL RE\rIEW PANEL A}INUAL REPORT REVIEW
ENERGY FUELS RESOURCES. WHITE MESA URANIUM MILL
RADIOACTTVE MATERIAL LICENSE UT 1 900479
References: Utah Administrative Code RML UT 1900479 License Condition 9.4
l) Describe what subject(s) were reviewed by the Mill's SERP,
Subject 1: Energy Fuels Resources Inc. (EFRD 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 performance
data from a two-column pilot test, referred to as the "Test", to approximate conditions in a heap leach pile
at the Sheep Mounuin Wyoming site. The proposed Test was to be conducted at White Mesa Mill (the
'Mill"). Any collected liquors frsm the test which were not shipped off-site for analysis would be
processed in the Mill's uranium recovery circuit. Residuals (tailings) from &e column test would be
disposed in the Mill's tailings system.
Subject2: The"Mill has an existing License amendmentto process KF altemarc feed material from
Camecn Corporation, and proposes to modi& the rccovery process as reflected in revisions to KF Node
Worksheets 3, 5, and 6. The Mill has previouslyprocessed KF alternate feed material in the main
Mill circuit by acid leaching prior to 2012, and by alkaline leaching following the process revision
apprwed in the Jrure 2012 SERP evaluation (SERP 2012-04r.
The previous process pcrformed caustic digestion under conditions selected to digest urudum, and
perfonned 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 adjusbment 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 modific*ions to the alkaline/carbonate leach process as evaluated in this SERP are expected to
_pqqCWJ higbg! qlaqlllql recoveries and require use of a smaller quantity of reagents.
Subiect 3; EFRI planned to puriS. and concentrate hardened uranium ("ycllowcake") 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 p,ractice at the Mill as
described in the Mill's 2007 license renewal application and existing EA documents. The proposed system
will redissolve yellowcake by attaching I processing lid to the overpack drum, placing it on a drum roller,
adding sulfuric acid and sodiucr shlorate, mixing and draining of solution to a holding tank for
reintroduction into the Mill's solvent extraction circuit
2) Didthe zubject(s) meet the criteria fomd in License Condition 9.4.X1
Explain:
Subject l: Thc SERP reviewed the Test protoeols, and the Fcbruary 25,2Al3 Technical Memorandum by
Jo Ann Tischler describing the test process and materials, and determined that:r If the recovered solumn solutions from the Test are to be processed in the Mill, the yellowcake
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Yes X No
Year Reported Date of Report Date of Review
2013 March 31,2014 Julv 21. 2015
r The test will not involve any new chemicals ar aFry new or increased emissions.
o Procedures for personnel training, monitoring ar{d personnel protective equipment are already in
forMill em and conftactors who be involved in the Test.
Subject 2: The SERP reviewed the Procedure above and the July 1,2013 Jo Ann Tischler
Technical Memorandum evaluating the KF Process , and determined that:
o The process will use the same carbonate,,and acid reagen* 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 sarne farnily of anionic flocculants already used at the Mill.
Although the potential for generation of HF ftorp exposure of fluoride minerals to sul$ric acid
would be minimized as a result of the KFProsess Change, Mill safety personnel will continue to
monitorfor HF in the process area-
There are no changes proposed to the storage, unloading/dumping, or washing steps of KF
processing. The leached and washed process liquids containing uranium win be transfened to the
existing SX, precipitation, drying and packaging, areas with no modifications required,
As a result, no new Personnel Protective Equipnrent ("PPE') would be required, no changes to
derived air concentration ("DACs") would be reluiredn and no new radiation or safety issues
would be produced by the KF Process Change.
There would be no insrease in environmental endssions and no change in the nature or volume of
tailings due to the Change. The volumes of solutions and solid tailings that would be transferred to
the tailings cells will remain the same. There would be no new pathways of exposure to workers or
the public.
Subjint 3: The SERP reviewed the proposed Node rW'or:ksheets, engineering drawings, conlainmeut pad
photographs, and November 13, 2013 Jo Ann Tischler Technical Memorandum describing the proposed
Drum Shred Process and detennined that:r The material could be received as a licensee-to-licensee transfer of source material and could be
purified and concentrated at the Mill.r The SERP assessed that there would b no du$ 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 processe$,
r The re-digested yellowcake will producethe ssme quantity of emissions as any other yellowcake
in the Mill circuit. Because ttre process does not,involve storage of ores ot bulk feed materials, it
will produce fewer fugitive esrissions/dusts thaq would be generated by producing the same
quantily of yellowcake from conventional ores o[ other alternate feed materials
o The Drum Shred Process does not require the rnpdifioation of the Mill's Air Approval Order or any
other approved management plans. Approved prpcedures are already in place for the disposal of
crushed drums in the Mill's tailings cells. l
r Although the yellowcake encrusted on drum shrods is not an alternate feed material or other ore,
the volume of tailings that will be generated during re-processing of the yellowcake wiil b
significantly less than the tailings that would be generated by pro&rcing the same amount of
vellowcake from ore
DWMRC Staff Review: Subject I was a test or experirpent not presented in the application, Subject 2
was a change in an existing procedure and Subject 3 \*at a change in a process. Therefore, the subjects
reviewed by the SERP meet the cdteria in License
I
I
recovered will be minimal. tIr The qustrty of leached ore from the Test to {e disposed in the Mill's tailings will be
immeasurably small compared to the capacitSiof the Mills tailings system.
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3) Did the subjeet(s) meet the criteria found in License Condition 9.4.3?
Explain:
Yes X No
Subject 1: The SERP coneluded that:o Tbe 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.r Because the Test does not involve any ncw 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 2r The SERP soncluded 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 h processed is already covered by an existing license amendment and has previously
beerr processed according to the conditions of the license amendment and Licerse Condition l0.l L
The Mill has remained in compliance with the License and other regulatory requirements while
running a comparable process, and fully expects to rernain 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
commiments in the License application, or provided by the approved reclamation plan. The KF
hocess Change involves a feed already processed previously at the Mill, and involves no new
. reagents, chemical or radiological hazards or environmental emissions.o The KF Process Change will have no effect on the Reclamuion Plan. The volumes of solutions
and solid tailings that would be transfened 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 effeet on
the volume or nature of tailings.o The Yellowcake recovered from the KF altemate feed materid will not cause thc 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, puriry, and concentrate
yellowcake and to dispose of cnrshed 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 yolumes of solutions
and solid tailings that would be transferred to tailings will be significantly less than those that
would be generated by producing the sa$le amount of yellowcake from eonventional ore or
alternate feed materials"
The Drum Shred Process is nol expected to produce any environmental impacts beyond those
assessed in the EA dated February 1997, and is consistent with the conclusions regarding actions
analvzed in the EA.
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il
DWMRC StaffReview: Each of the three subjects revibwed by the SERP meetthe criteria in License
Condition 9.4.8.
Person andlor Job Title
Managerial and Financial . Nlot documented
Opemtions and/or Construction Not documented
Radiation Safety Not documented
Other:
Other:
Other
Explain:
DWMRC SteffReview: Members of the SERP were not documented in the report. Therefore, Statrwas
unable to verifu compliance with the requirement found in License Condition 9.4.D.
4) Did the SERP members meet the expertise criteria fuund in License Condition 9.4.C? Yes
No
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 3lof the following year.
Changes to existing and new procedwes were not attachred to the report. The SERP followed the Mills
operating procedure for SERP reviews. Thercfore, the SERP report does not meet all of the criteria in
Lisense Condition 9.4.D. Staffwill veri$ that records ine being maintained in a future site inspection.
Identified lleliciencies:
The following deficiencies were identified:r Members of the SERP, as defined in License Cofrditiou g. .C.,wsre not documented in the report;
andr Changes to existing and new procedures were not attached as required in License Condition 9.4.D.
Renort
nrli.*"a gur RYan Johnson *rc: '/f
Supervisory
Review By:
(PrintName)
Phil Goble
(Print Name)(Signature)
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@ate)
(Date)
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-SERP-O I
SAFETY AND EN\/IRONMENTAL REVIEW PANEL ANNUAL REPORT REVIEW
ENERGY FUELS RESOURCES. WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTI 90M79
References: Utah Administrative Code RML UT 1900479 Licerrse Condition 9.4
l) Describe what subjec(s) were reviewed by the Mill's SERP.
Subject l: The Mill has an existing License amendment to process KOH alternate feed materials from
Honeywell, (formerly known as Allied Signal Corporation, Metropolis lllinois), and proposes to modi$
the recovery process. The Mill has previously processed KOH alternate feed materialsth,rough the
addition of water to the drums manually, by Mill personnel, prior to dumping. The previous leach process
used this water leach pnocess 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 proc€ss 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 tbrough the submerged dumping station and to
produce higher wanium 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 Lisense Condition 9.4.A?
Explain:
Subject 1:. The SERP reviewed the Procedure described above and deterrrined that:
r 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
pI€cesses.o 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 ehemical reactions or oft
gasses associated with processing KOH under the SOP, as amended by the Change, that haven't
been experienced and handled safety by the Mill in connection with processing other alternate feed
materials. Specifically, the KOH SOP has been modified to intoduce the material while
submerged, eliminating any dust.r There are no changes proposed to the storage, or washing steps of KOH processing. The leached
and washed process liquids containing uranium will be transferre.d to the existing SX,
precipitation, drying and packaging areas with no modifrcations required.
r No new Personnel Protectiye Equipment ("PPE') would be required, no changes to derived air
concentration ("DACs") would be required, and no new radiation or safety issrres would be
produced by the KOH Process Change.
t There wou[d be no inqgqg_14 s4vironmental elqissions an$" r]g change in the *glqr.e or vol]u-ne 9f
Yes X No
Year Reported Date of Report Date of Review
2014 March 19,2015 Julv 21,2015
tailings due to the Change. The volumes of solutions and sotid tailings that would be transferred rc
the ailings sells will remain the sarne. There would be no new pathways of exposure to workers or
the public.
DWMRC StaffReview: Subject 1 was achange in an existing procedure. Therefore, the subject
reviewed by the SERP met the criteria in License Condiition 9.4"A.
3) Did the subject(s) meet the criteria found in License Condition 9.4.8?Yes X No
Subject 1: The SERP concluded that:r 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 bl 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 compli:ance with the same requirements when running the
revised process.
r 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 radiologiml hazards or environmental emissions.r 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 wer€ 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 KOH alternate feed material will not cause the Mill to exceed
the yellowcake production limit under the Mills license.o The KOH alternate feed material processing is addressed by an existing approved license
4) Did the SERP members meet the expertise criteria found in License Condition 9.4.C? yes
No
5) Did the SERP Annual Report meet the criteria forg,{ in License Cordition 9.4.D? yes _ No__X_
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pg.docr, page 2 of3
pf envtronmentat con*t ed in the EA.
DTyYMRC StaffReview: The subject reviewed by thg l$ERp
Person and/or Job Title
Managerial and Financial I ot documented
Operations and./or Constructi on .I\ot documented
Radiation Safety h ot documented
Other:
Other:
Other
Explain:
DWMRC StaffReview: Members oftG SERP l'rere
unable to veri& compliance with the requirement fou{[l in License Qondition g"q.C.
Supervisory
Review By:
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.
Identilied 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;
andr Changes to existing and new procedures were not attached as required in License Condition 9.4.D.
*:9.^, -... RyanJohnson 81d'/)*Reviewed By:
(Print Name)
Phil Goble
(DaH
(Print Name)(Signature)(Date)
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