DRC-2015-001764 - 0901a0688050f8c0

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director DRC-2015-001764
Spencer J. Cox
Lieutenant Governor
MEMORANDUM
TO: File C-2015-54
DATE:
THROUGH:
FROM:
SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material February 6,
2015. Radioactive Materials License UT 1900479 (License) - Energy Fuels Resources
(USA) Inc. (EFR) White Mesa Mill, Blanding, Utah
On February 6, 2015, I traveled to the White Mesa Mill to perform an inspection of in-situ leach (ISL)
waste disposal operations on behalf of the Utah Division of Radiation Control (DRC). This inspection
responds to a 11e.(2) Byproduct Receipt Notification from EFR, dated January 28, 2015. EFR is allowed
to dispose this byproduct material in Tailings Cell 3 only, which is allowed by License Condition 10.5 of
the EFR Radioactive Materials License.
On January 30, 2015 the DRC received notice that EFR would receive two loads of 1 le.(2) byproduct
material, and intended to dispose of that waste in Cell 3 on February 6, 2015. Two loads were ultimately
received prior to the commencement of the burial activity.
I checked in at the White Mesa mill at 8:20 a.m. on February 6, 2015, and asked to see David Turk. Other
staff that typically observe the placement of ISL waste were not working that day, so David Turk was
overseeing the waste disposal operation. When I arrived, the operation was nearly complete, and with Mr.
Turk overseeing the activities, I was unable to coordinate with him until he returned to the office at
approximately 8:40 a.m. Upon meeting Mr. Turk, we proceeded to the disposal site.
I questioned Mr. Turk about the processes used. His representations comport with practices I had observed
in previous inspections. I requested paperwork and photographs to complete the file. These documents also
provide some evidence of the processes employed and standards followed.
The field crew used the appropriate paperwork, i.e. Revision 3.3 of Procedure PBL-10, to guide the
operation.
Material disposed consisted of:
• Chipped pipe from Cameco, Smith Ranch, in Douglas, Wyoming, shipped by Greenfield Logistics,
bearing Shipper Number 1/15-4; and,
168 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Kax (801) 5334097 • T.D.D. (801) 5364414
www. deq. ulah.gov
Printed on 100% recycled paper
Page 2
• Soil, drums and miscellaneous decommissioning product from South Texas Mining (UEC) in
Hobson, Texas, shipped by Cosby Trucking, bearing Shipper Number HOB-140.
The bill of lading for each of these loads appears in the attachments to this report.
The work crew executed the waste disposal in two excavations that extended into the tailings sands.
Mr. Turk, with assistance from one of the equipment operators, surveyed the level at the bottom of the
excavation prior to waste placement. Using a front-end loader and a small dozer, crews placed the waste in
the excavations and tamped it down. Mr. Turk then surveyed the elevation of the top of the waste, and the
crews filled the excavation to the top with soil. The crew track-walked the capping fill to a point where it
exhibited no yielding. I observed the final passes made with the dozer.
EFR appears compliant with Part 10.5.E.(2) of the RML with respect to the elevation of burial. It appeared
that all provisions of the approved disposal SOP were followed during placement and burial of the bulk
waste.
Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial
operation.
Recommendation: I recommend closing out the inspection of February 6, 2015.
Attachments: Receipt Notification dated January 28, 2015, Bill of Lading and Disposal Documentation for
each load disposed on February 6, 2015, photos of the disposal operation provided by the licensee.
r
ENERGYFUELS
DRC-2015-001283
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
January 28, 2015
VIA Electronic Mail (PDF) and UPS
Mr. Rusty Lundberg ,,. v
Division Director of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144830
Salt Lake City, UT 84114-4820
Dear Mr. Lundberg,
Re: 11 e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Radiation Control that the White Mesa Uranium Mill will be
receiving and disposing of two loads of 1 le.(2) byproduct materials on February 6, 2015.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.2221.
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: i\-z<\[\£
Name of employee receiving the load: freurr*^. PA.1^WV-
Generator of the Byproduct Material: /La^^c^) - ^^t4-U. R^xv^^s
Shipper's Manifest or Bill of Lading number: 11 IS~ M
Was the State of Utah given notice to the receipt/disposal activities associated with this load?^Yesj>r
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? A/Ar
Have all drums with void spaces been filled with tailings sands or soil? A/A
Which tailings cell was the material placed in? cCsAl _>
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
)kl
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #:
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
'TIS"
'V 3 l/<Z> fat*ej<t
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
_£
Was the shipment properly covered?
V<J
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Manifest or BOL #: i I |S-*4
Are additional settlement monitors required to be placed for this generator?
A/h
If required, where were settlement markers were placed?
A/A
Radiological receipt survey measurements:
Page 13 of 13
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yeso/'Nov
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/^e^ or No
Page 1 of 1_
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics
Shipper No/
Carrier No.
Date
(Nana of Carrier! (SCAC) //&/'>
an CoDact on Dellvwy rfilpmorm, 9m mVmt COO mmtapp—baftneonilgnes'inainaari
othan*lMpiDV*MdinlMm430, Sac 1
To: Consignee Energy Fuels
Street 8425 South HWY 191
City Blandlna State UT Zip Code 84511
From: Shipper CAMECO RESOURCES. INC.
Street: 762 ROSS ROAD
City DOUGLAS State WY Zip Code 82833
24 hr. Emergency Contact Tel. No: 905-885-8745
Route: Vehicle:
Number
No of unto &
container type HM Basic Description
Proper Shipping Name, Hazard Class,
Number (UN or NA), Packing Group, per 172.101.172.202,172.203
Total Quantity
(Weight, Volume.
Gallons, etc)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll off XX UN2912, RADIOACTIVE MATERIAL, Surface Contaminated Object
(SCO), HAZARD CLASS 7 27.82m* (36.4yd')
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED
DAUGHTER PRODUCTS
PHYSICAL FORM: SOUD
CHEMICAL FORM: NATURAL URANIUM OXIDE UO«-2H,0
TOTAL ACTIVITY: 4.3E7Bq (0.001 Cl)
TRANSPORT INDEX: N/A AS PER 49cfr172.203(dX6)
PLACARDS: RADIOACTIVE 7
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF Cameco
RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.425 (B)
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE
PLACARDS TENDERED: YES: X NO J REMIT COD. TO:
ADDRESS
Noio^i) iMwv AS flfli b dopaodMl M MOJO, OMBBM on nodfOB" to BMO opocMcsly on
MMMOSioaomdtt••clojid votaoorejopropony.oiMbMO Tlioopnodflfdoclono'Mliio
of ftopnoony In boraby ipocMcotjpotobMl by Bw flriipor b bo not
l_ll»llb>t»«#p«HI>l»H»p»f„>Ml lllllll
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bo o» moiUd ond nrllgul polo—oo nil IOM|WIOIIIII «•• tirlwiafrOH—MB,
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•i T rf mm wdOn ff Mi tffemtf • k
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coo ne
PRcVMO couacT *
TOTAL
CHARGES i
FREIGHT CHARGES
0M0Md M hOafiffJlSd KbOT WABAMU CtntW 0hS TM*d I
prapwty, Iwt nwy •entot Mi lw pavfeiiMd Neraundcf sfwfl
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bofcoj undonlDod ttnophoid Hi omfeocl onMofrinpooy ponofl Of ooiponbon In pooMoriM of floi (Mportj
• adldoaMoo lUn^Mi*»tmim*mchan&al*oi*qal.**ptcim*mmt*ttmipaitm<ll
b»oob»dloojl^bBolloo>ab^iii^co^
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•rcaMMorp
uiobof«, HIM«» com n l» I poici »l lllrny •> ffoM oiolnoJon. 1
iloililiiilnii»nd»»t»«»ctipoilr»l«^l>o«>'li'i»li'l>'««»ronroaM
SHIPPER: CAMECO RESOURCES, INC. CARRIER: G D LOGISTICS
_ 7"
PER tfU fa
DATE
PER
DATE
nergy Fuels Rcasources
•hi"be Mesa Mill
425 8. Highway 191
Handing UT 84511.
<USA> Corp..
Transaction No.
50462
•ehiele IDs
railer IDs
iccount IDs
i-rder IK):
iwner IDr
later ial ID:
•est; in. IDs
lldOK WYO DOUGLAS, WYOMING
Date Time Scale
Ins 01/29/5015 07s54 1
OubE 01/29/2015 06:28 1
Grosss 51880 lb <M>
Tares 42960 lb
Nets 9820 lb
il(e)2 Mat 11(e)2 Material Receipt
BLANDING
•ommentss R/Ott 12
iperators 4
ignature!
Charge by Weight
/
50462 01/29/2015 07:54 51880 lb
4 01/29/2015 08:28 42060 lb
1. <e>2 WYO 9820 lb
Ke>2 Mat Net Chq: 0 Tot Chq:
Generator of Byproduct material: Smith Ranch
Controled Elevation used (Cell 3) 5612.27
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5606.11
Bottom of trench 5601.11
Initial shot used for material
Too of material in trench 5604.97
4.5
10.66
15.66
4.6
11.9
Top of cell 3 Liner 5608.5
Feet below liner 3.53
4-
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I
6
4.
4*
0
mrf
73 H^-'
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No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: \lz*l [S'
Name of employee receiving the load: ir«vrr^ P>/X.1I^VJ(V-~
Generator of the Byproduct Material: L>E.&-~ HofcuSoA.
Shipper's Manifest or Bill of Lading number: L} \$ - { L\T)
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(YesNor
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? yV_<.
Have all drums with void spaces been filled with tailings sands or soil? rvv^vt ^or«. r rutUtA
Which tailings cell was the material placed in? C-eAK. ~S
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
&i
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STAN HARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #: rtfth~ l4o
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 13 of 13
Manifest or BOL #: Hf>t>- IMP
Are additional settlement monitors required to be placed for this generator?
A/A
If required, where were settlement markers were placed?
AlA
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activitieslL Yesj)r No
Shipment Number HOB-140
BILL OF LADING - BYPRODUCT MATERIAL
24-HOUR EMERGENCY CONTACT NUMBER/PROVIDER & CONTRACT NAME OR No.
[phone] Kevin Dziuk (Radiation Safety Officer)
CONSIGNOR (Shipper/From): Company Name and Site CONSIGNEE (Receiver/To): Company Name and Site:
South Texas Mining Venture LLP - HOBSON TX Energy Fuels - BLANDING UTAH
ADDRESS: 20278 N. FM 81 Hobson, TX 78117 ADDRESS: 6425 S Highway 19 Blanding, UT 84511
SHIPPER TELEPHONE No.: [phone] CONSIGNEE TELEPHONE No.: [phone]
SHIPPER NRC/STATE LICENSE No: R03626
SHIPPER USDOT No.: 148604
CARRIER NAME: Cosby Trucking, LLC
CARRIER USDOT No.: 298957
SHIPPER/TRANSPORTER INFORMATION
CONSIGNEE NRC/STATE LICENSE No.: UT 1900479
SHIPPER PHMSA REGISTRATION No.: 071111 550 027TV
j
CARRIER ADDRESS: 601 S 200 E Blanding, UT 84511
CARRIER PHMSA REGISTRATION No.: 071113 550 019V
NUMBER
OF UNITS HM
DESCRIPTION OF MATERIAL, ARTICLES, SPECIAL MARKS, EXCEPTIONS
UN PSN CLASS
Gross
WEIGHT
KG (LBS)
UN 2912
TRAILER
RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1)
(Solid By-Product Material)
o-OlM
Activity 37 Mba ( &Mt Ci)
Curie x 3.7E4 = 1 Megabecquerel
Volume; 45J cubic feet
Estimated
18,143
(40,000)
••••EXCLUSIVE USE SHIPMENT"**
CATEGORY OF LABEL(S) APPLIED TO PACKAGE - 2912 ! ;
EMERGENCY RESPONSE DOCUMENT ATTACHED - 2012 ERG Section. i62
This is to certify that the above-named articles are properly classified, described, packaged, marked, and labeled, and are in proper condition
for transportation according taine applicable regulations of the Department of Transportation.
SHIPPER'S SIGNATURE
DRIVER'S SIGNATUR
DESTINATION SIGNATURE OF
INDICATION OF LEAKAGE
portation according tfAhe appl
DATEjJMiiC
DATE j^ZS^CS
DATE Lrg£d£
(NO) YES, EXPLAIN
inergy Fuels Resources
ihite Mesa Mill
•4S5 S. Highway 191
ilandinq UT 845.1.1
(USA) Corp.
'ehicle IDs
'railer IDs
iccoimb IDs
irder IDs
iwner IDs
later i a 1 ID.
•est in. IDs
COSBY 815
UEC MNT LU ECOLOGY
Transaction No.
50465
Date Time Scale
Ins 01/29/2015 09s48 1
Outs 81/29/2015 10sl8 1
Gross: 54800 lb <M>
Tares 32640 lb
Wets 22160 lb
11 < e) 2 Mat 11 (e> 2 Materi a 3. Racei pt
BLANDING
:ommentss TRLtt 15
iperators 4 Charge? by Weiyht
:i gnature: J jZ^^.ffl^^^^f^. —
50465 01/29/2015 09:48' 54800 lb <M>
OSBY 815 01/29/2015 10s 18 -32640 lb
EC MNT LU 22160 lb
J. <e> 2 Mat Net Chg: 0 Tot Chgs
Generator of Byproduct material: UEC Hobson
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
TOD of material in trench
5604.16
5597.6
5603.24
4.5
13.38
19.94
4.2
14
Top of cell 3 Liner
Feet below liner
5608.5
5.26
1
8= 0~
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