DRC-2014-002601 - 0901a0688041c62a

VIA EMAIL AND OVERNIGHT DELIVER
fl ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
March 31, 2014 DRC-2014-002601
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 2013 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
Ronnie Nieves
Harold R. Roberts
David Turk
Attachments
N:\WMM\Required Reports\SERP Reports\2013 SERP ReportsVAnnual Report\03.31.14 trnsmtl 2013 SERP Ann
report.doc
WHITE MESA MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL ("SERP")
2013 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 31, 2014
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 were three Safety and Environmental Review Panel ("SERP") evaluations conducted for
the period of January 1, 2013 through December 31, 2013. Each 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-5 (the "SERP SOP"). The evaluations are summarized below in
Section 2.
2. SUMMARY OF EVALUATIONS
This section describes the changes, tests, or experiments 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. 2013-01 March 1, 2013
Leach Column Test for Sheep Mountain Ore
2.1.1. Proposed Action
Review and approve a proposed ore leaching column test on agglomerated and non-
agglomerated natural uranium ores from the Sheep Mountain ore stockpile.
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2.1.2. Description of Change, Tests or Experiments
EFRI 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
Mountain Wyoming site. The proposed Test was to be conducted at White Mesa Mill (the
"Mill"). Any collected liquors from the test which were not shipped off-site for analysis would
be processed in the Mill's uranium recovery circuit. Residuals (tailings) from the column test
would be disposed in the Mill's tailings system.
2.1.3. Safety and Environmental Evaluation of this SERP Action
The SERP reviewed the Test protocols, and the February 25, 2013 Technical Memorandum by
Jo Ann Tischler describing the test process and materials, and determined that:
• If the recovered column solutions from the Test are to be processed in the Mill, the
yellowcake recovered will be minimal.
• The quantity of leached ore from the Test to be disposed in the Mill's tailings will be
immeasurably small compared to the capacity of the Mill's tailings system.
• The test will not involve any new chemicals or any new or increased emissions.
• Procedures for personnel training, monitoring and personnel protective equipment are
already in place for Mill employees and contractors who would be involved in the Test.
The SERP concluded that:
a) The 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.
b) Because the Test does not involve any new 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.
c) The test will have no effect on reclamation commitments, and will not cause the Mill
to exceed its approved tailings capacity.
2.1.4. SERP Action
The SERP concluded that the Test meets the criteria set forth in the SERP SOP for approval, and
approved the Test.
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2.2. SERP Report No. 2013-02 July 1, 2013
Review and Approval of SOP for Potassium Fluoride ("KF") Processing
2.2.1. Proposed Action
Review and approve revisions (the "KF Process Change") to the existing Standard
Operating Procedure ("SOP" or "Procedure") for processing Cameco KF alternate feed
material from Cameco Corporation's Blind River Facility.
2.2.2. Descriptions of Change, Tests or Experiments
The Mill has an existing License amendment to process KF alternate feed material from Cameco
Corporation, and proposes to modify the recovery process as reflected in revisions to KF Node
Worksheets 3, 5 and 6. The Mill has previously processed KF alternate feed material in the main
Mill circuit by acid leaching prior to 2012, and by alkaline leaching following the process
revision approved in the June 2012 SERP evaluation (SERP 2012-04).
The previous process performed caustic digestion under conditions selected to digest uranium,
and performed 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 adjustment 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 modifications to the alkaline/carbonate leach
process as evaluated in this SERP are expected to produce higher uranium recoveries and require
use of a smaller quantity of reagents.
2.2.3 Safety and Environmental Evaluation of this SERP Action
The SERP reviewed the Procedure described above and the July 1, 2013 Jo Ann Tischler
Technical Memorandum evaluating the KF Process Change, and determined that:
a) The process will use the same carbonate, caustic and acid reagents 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 same family of anionic flocculants already
used at the Mill.
b) Although the potential for generation of HF from exposure of fluoride minerals to
sulfuric acid would be minimized as a result of the KF Process Change, Mill safety
personnel will continue to monitor for HF in the process area.
c) There are no changes proposed to the storage, unloading/dumping, or washing steps of
KF 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) As a result, no new Personnel Protective Equipment ("PPE") would be required, no
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changes to derived air concentration ("DACs") would be required, and no new radiation
or safety issues would be produced by the KF 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.
2.2.4 SERP Action
The SERP concluded that:
a) 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 be processed is already covered by an existing
license amendment and has previously been processed according to the conditions of the
license amendment and License Condition 10.11. 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 KF 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 KF 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 KF 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 KF 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 KF alternate feed material will not cause the Mill to
exceed the yellowcake production limit under the Mill's license.
e) 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
theEA
The SERP concluded that the Procedure meets the criteria set forth in the SERP SOP for
approval, and approved the revised KF Procedure.
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2.3 SERP Report No. 2013-03 November 14, 2013
Review and Approval of SOP for Purifying and Concentrating Yellowcake Adhered
to Drum Shreds
2.3.1 Proposed Action
Review and approve a proposed SOP for purifying and concentrating yellowcake
encrusted on drum shreds (the "Drum Shred Process"), from Honeywell, Metropolis
Works.
2.3.2 Descriptions of Change. Tests or Experiments
EFRI planned to purify and concentrate hardened uranium ("yellowcake") 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 practice at
the Mill as described in the Mill's 2007 license renewal application and existing EA documents.
The proposed system will re-dissolve yellowcake by attaching a processing lid to the overpack
drum, placing it on a drum roller, adding sulfuric acid and sodium chlorate, mixing, and draining
of solution to a holding tank for reintroduction into the Mill's solvent extraction circuit.
2.3.3 Safety and Environmental Evaluation of this SERP Action
The SERP reviewed the proposed Node Worksheets, engineering drawings, containment pad
photographs, and November 13, 2013 Jo Ann Tischler Technical Memorandum describing the
proposed Drum Shred Process and determined that:
a) The material could be received as a licensee-to-licensee transfer of source material and
could be purified and concentrated at the Mill.
b) The SERP assessed that there would be no dust 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 processes.
c) The re-digested yellowcake will produce the same quantity of emissions as any other
yellowcake in the Mill circuit. Because the process does not involve storage of ores or
bulk feed materials, it will produce fewer fugitive emissions/dusts than would be
generated by producing the same quantity of yellowcake from conventional ores or other
alternate feed materials
d) The Drum Shred Process does not require the modification of the Mill's Air Approval
Order or any other approved management plans. Approved procedures are already in
place for the disposal of crushed drums in the Mill's tailings cells.
e) Although the yellowcake encrusted on drum shreds is not an alternate feed material or
other ore, the volume of tailings that will be generated during re-processing of the
yellowcake will be significantly less than the tailings that would be generated by
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producing the same amount of yellowcake from ore.
2.3.4 SERP Action
The SERP concluded that:
a) 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, purify, and concentrate yellowcake and to dispose of crushed empty drums in
the tailings system, which the Mill has followed on a routine basis.
b) The drum handling and drum rolling area was designed consistent with requirements
of the Discharge Minimization Technology plan and Stormwater Best Management
Practices Plan.
c) The Drum Shred Process will have no effect on the Reclamation Plan. The volumes
of solutions and solid tailings that would be transferred to tailings will be
significantly less than those that would be generated by producing the same amount
of yellowcake from conventional ore or alternate feed materials.
d) The Drum Shred Process 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.
The SERP concluded that the proposed Process for Purifying and Concentrating Yellowcake
Adhered to Drum Shreds meets the criteria set forth in the SERP SOP for approval, and
approved the Drum Shred Process. The SERP authorized immediate implementation of the
Drum Shred Process.
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