DRC-2013-003468 - 0901a068803d4c88

ENERGYFUELS
"DRC-2013-003468"
Energy Fuels Resources [USA) Inc,
225 Union Blvd. Suite 600
Lakewood, C0, US, 80228
303 974 21.40
www.energyfuels.com
VIA OVERNIGHT DELIVERY
October 2I,2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
F.O. Box 144850
Salt l-ake City, UT 84116-4850
Re White Mesa Uranium Mill - RML UT1900479
December l5r20ll Request to Amend Radioactive Materials LÍcense to Allow
Processing of Alternate Feed Materials from Sequoyah Fuels Corporation
Response to URS Inc. September 19,2013 Questions and Clarification Request
Dear Mr. Lundberg:
This letter responds to the URS September 19, 2013 Questions and Clarification Request which Energy
Fuels Resources (USA) Inc. ("EFRI") received from the Utah Division of Radiation Control ("DRC")
on September 24, 2OI3 regarding EFRI's August 30, 2Ol3 letter to DRC and December 15,20II
Request to Amend (the "December 2011 Amendment Request") the White Mesa Mill's (the "Mill's")
Radioactive Materials License UTL9O0479 (the "RML" or the "License") to allow processing of
alternate feed material from Sequoyah Fuels Corporation (the "Uranium Material"). For ease of review,
each of DRC's comments is provided verbatim below in italics, followed by EFRI's response.
"Redline" versions of pages changed in response to the Questions and Clarifications are attached as
Appendices to this letter. Upon approval of the changes, a final "clean" version of the full Amendment
Request will be submitted.
Comment I
On page 1l of 47 of the 8/30/13 EFRI Letter to Rusty Lundberg, it ís stated that the W.R. Grace
allernate feed material had much higher concentrations of Th-230 and Th-232 than the Sequoyah Fuels
Resources Uranium Material. Should the text here be revised to instead state that the W.R" Grace
alternate feed material had much higher concentrations of Th-228 and Th-232 than the Sequoyah Fuels
Re source s U raníum M ate rial ?
EFRI response to Comment 1
Table 1 in the August 30, 2013 response to the December 4,2012 comments was missing one line of
data. A corrected version of Table t has been provided in Appendix A to this letter.
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N:\WMM\Alternate Feeds\Sequoyah Fuels\O9.19.13 URS comments and responses\Response to DRC comments SFC
l0.2l.l3.doc
Letter to Rusty Lundberg
October 2l,20l3
Page 2
As indicated in Table 1, the RMPR included with the'W.R. Grace Amendment Application identified
average and maxirnum levels of Th-232 as 8,000 pCi/g and 31,500 pCi/g, respectively. Additional data
in the RMPR attached to the Amendment Application identified average and maximum levels of Th-228
as 2,000 pCi/g and3,222 pCi/g, respectively. This data has been added to the corrected version of Table
L The RMPR identif,red the average and maximum levels of Th-230 as 2,000 pCi/g and 10,400 pCilg,
respectively. The corrected version of Table 1 shows the values of these three thorium isotopes for the
\ff.R. Grace alternate feed material. As indicated in the revised Table l, the'W.R. Grace alternate feed
material had much higher concentrations of Th-228 and Th-232 than the Sequoyah Fuels Resources
tr-lranium Material and lower Th-z30levels.
Flowever, as indicated in Table 1, the Nevada Test Site Material had substantially higher levels of Th-
230 than the Sequoyah Fuels Uranium Material, since its average Th-230 was 28 times higher and its
maximum Th-230 was 31 times higher than the Sequoyah Fuels Uranium Material.
A revised version of Table 1 is provided in Appendix A. The W. R. Grace RMPR and radiological
characterization data from the Amendment Request are also provided in Appendix A to this letter.
Comment 2
On page 2 of 5 of Attachment DI (in Attachment 2 of the Revised August 2013 LAR), 3'd pør., it is stated
that (some) analytical results (for F, ammonia as N, and nitrate-nitrite as N) of rffinate sludge
collected in May 2003 are presented "in Table 5 as Dewatering Filtrate" and the text refers the reader
to laboratory reports in Anachment Dlciii for additional details. No analytical results corresponding to
the re.sult,t reported in Tabl,e. 5 of Anachm,en,f Dl coul.d be. found in Attachme.nt Dl ciii. Should the text in
this par. of Attachment DI be revised to instead state that the analytical results reported in Table 5 are
from a sample of dewatered sludge collected in December 2012 and analyzed in July 2013 and that the
laboratory analysis report for this sample øre provided in Attachment D.l.cvi?
EFRI response to Comment 2
The text of Attachment D.l, paragraphs 3 and 5 on page 2 of 5 have been corrected to accurately reflect
which attachments provide the data reports. A redline of the corrected Attachment D.l is included in
Appendix B to this letter.
Comment 3
On page 5 of 5 of Attachment DI (in Anachment 2 of the Revised August 2013 LAR), the footnote to
Table 5 suggests that the analytical results apply to "Sample ID 5D282, July 2013". Can EFRI please
verify that this sample was actually collected in December 2012 and is the same sample for which the
analytical results presented in Table I of Attachment DI apply to?
EFRI Response to Comment 3
The sample in Table 5 was collected in December 2012 and is the same sample for which the analytical
data are presented in Table 1. The laboratory inadvertently logged the sample with the wrong year. The
Letter to Rusty tr-undberg
October 2I,2013
Fage 3
laboratory revised the data package to correctly reflect the December 2012 collection date. The revised
data report is included in Appendix C to this letter. The date and time of sample collection noted on the
Chain-of-Custody ("COC") documents (l2llÙll2 11:30) was used to verify that the samples shown in
Tables I and 5 are the same.
Comment 4
The laboratory report provided in RMPR Attachment D.Icvi indicates that sample SD-282 was collected
on 12/10/13. Can EFRI please verify that this sample is the same sample that was actually collected in
Ðecember 2012 (e.g., 12/10/12)?
EFRI Response to Comment 4
See the response to Comment 3 above.
Comment 5
In '4ttachrnent 7, Standard Operating Procedwre \SOPI- SFC Alternate Feed Management, of the
RevisedAugust 2013 LAR, Sections 2.0 and 3.0 refer to "Ore Receiving" and "Ore Dumping". For
clarity, suggest that these descriptions be revised to refer instead 1o "Uranium Material Receipt" and
" U ranium Material Dumping " .
EFRI Response to Comment 5
The SOP has been modified as requested to refer to Uranium Material. A redline version of the
revised SOP is provided in Appendix D to this letter.
Comment 6
In Attachment 7, SOF, of the Revised August 2013 LAR, in Section 6.2, Item 2 states "Ensbtre that aII
personnel within 50 feet of the area where the truck is backing up or moving." The sentence appears
incomplete and does not state what those personnel should do"
EFRI Response to Comment 6
The Section 6.2" ltem 2 of the SOP has been revised to state:
"Ensure that no personnel are within 50 feet of the area where the truck is backing up or
moving""
,A.s mentioned in the response to Comment 5, a redline version of the revised SOP is provided in
,A,ppendix D to this letter.
I-etter to Rusty Lundberg
October 2l,20l3
Page 4
Commcnt 7
Reþrence Attachment '/ (SOP): Considering the potential inhalation hazard posed by thorium, it
suggested that EFRI consider including some additional precautions to help further prevent dust
inkalation during ffioading and placement ("dumping") of the Supersaks containing the Uranium
Material onlo the slorage pad ønd during subsequent loading of the Supersaks for lransport to the Mill
for processing. For example, is there a possibilily that the bags could have surface contamination on
the outside lkat could become airborne during ffioading/loading activities? Item 9 of Section 3.0
discwsses moniloring and PPE, bwt other precøutions could also be taken 1o minimize the potential for
inhalation ucposures. It could be argued that some of these precautions are already implied since
Sectíon 6.1, Item 4, discusses respiratory protectionfor "initial receipt and handling" of the SFC feed
nnaterial, which presumably includes ffioading. It would be beneficial, however, to clarify that both of
these specific ffioading and loading (for transport to the Mill) activities are included in the activities
discussed in the cited section (Section 6.1) that addresses respiralory protection measures. It may be
beneficial to also briefly describe what additional precautions would be laken during such
ffioading/loading activities to minimize potential "rporuri, 1o personnel.l
EFRI Response to Comment 7
It is correct that the terms "initial receipt and handling" in Section 6.1 of the SOP were meant to refer to
offloading, handling, and transport from the ore pad to the Mill circuit. The SOP has been clarified by
the addition of language specifying that the respiratory protection measures will apply to offloading,
handling, and transfer to the Mill circuit for processing.
It should be noted that the Uranium Material will average 45 %o moisture at the time of shipment. It is
unlikely that the moisture content will change appreciably during shipment, particularly given that the
material will shipped within polymer bags. Should any spillage occur, either from bags broken during
shipment, or at the time of unloading, the spilled material will be a clumping, wet solid, not a dry
powder, and will have virtually no tendency to generate dust and little or no inhalationhazard" Spilled
material will be handled as discussed below.
Itrowever, EFRI will take the additional measures described below, if required, for Supersaks that may
arrive at the Mill in damaged condition.
1 Such precautions could include, for example: (i) visually inspecting the Supersaks for signs of leakage (e.g., possibly noting
that the dewatered raffinate material typicalty has a rusty brown color or some other color) during these activities (the proposed
SOP refers only to inspections to assess the integrity ofcover material placed over the Supersaks after they have temporarily been
placed on the pad); (ii) if spillage occurs outside of a contained area, indicate measures that would be used to secure the area as
needed; (iii) indicate how tracking of any spilled material would be avoided in such instances; (iv) indicate whether in such
instances personnel would be notified to avoid access to the area until the area is cleaned and secured; (v) indicate whether and
how, ifdamage is noticed or occurs to a Supersak container such as a hole or slit during ofloading or loading and transpolt to the
Mill, it would be corrected/controlled by taping the hole, placing plastic sheeting around the container, etc... or other measures
that would taken; (vi) indicate how, if small amounts of material are spilled, that material would be picked up by hand tools and
placed into an empty drum/container or by using a HEPA vacuum, etc...; (vii) indicate how, if a larger amount of spillage
occurs, that spillage would be picked up and how this would be accomplished so as to minimize potential exposures, how spillage
from a ruptured bag would be containerized, etc... Other additional or altemative precautions/safety and personnel protection
measures might also be considered and implemented.
Letter to Rusty Lundberg
October 2l,2OI3
Page 5
If during transportation from SFC, any Supersaks are damaged and/or leaking, the Shipper and
Transporter will have the responsibility under their Emergency Response Plans to have the material
contained, cleaned up, and the shipping conveyance repaired. Any spillage of material that requires the
notification to the DOT or DOE cleanup crews, will again be the responsibility of the Shipper or
lfransporter"
Once the rnaterial tras arrived at the White Mesa Mill, the local Radiation Staff will perform an
inspection of each load to make sure ttrat there is no damage or leaking material, prior to the loads being
received on site. If any Xoad is found to be damaged or leaking, the loads will be photographed and
docurnented prior to entering the Restricted Area and the Shipper and Transporter will be notified. If
leaking rnaterial has been found, the Radiation Staff will inspect the roadway to see if the spillage has
come in contact with the roadway. If so, the roadway will be decontaminated to background
measurements. The leaking load will be secured in the conveyance and taken into the Restricted Area.
Once in the Restricted Area, the conveyance will be unloaded following the SFC SOP. The conveyance
will then be decontaminated to meet Unrestricted Release requirements. All costs associated with the
cleanup activities will be forwarded to the Shipper.
If leaking materials have been found, all activities will cease until employees are wearing the proper
PPE and respiratory protection. No additional PPE will be required during the initial
inspection/observation on an inbound delivery.
If bags arrive in damaged condition, whether or not the damage results in leakage into or outside the
conveyance, Radiation Staff may, if needed, cover or patch damages Supersaks by taping polymer
sheets or tarp material over the damaged areas, and maintaining the Supersaks and any exposed material
in wet condition during transfer to storage, to minimize dusting and dispersion. As discussed above, the
material will be a wet solid with little or no tendency for dusting and, once placed in storage, the
Supersaks and any exposed material resulting from damaged Supersaks will be maintained in a moist
condition by daily water sprays until they are covered by native soil or other suitable material as
described in the SOP Section 3.0Item 10.
Once the soil or cover material is removed for transfer to the Mill circuit, bags will be maintained in a
moist condition by spraying until the Uranium Material has been loaded into the grizzly or other
appropriate feed equipment. ,{s discussed above, respiratory protection measures will apply to all steps
as specified in Section 6.1 Item 4 of the SOP"
Comment I
On page 16 of 47, par. 7 of the of the 8/30/13 EFRI Letter to Rusty Lundberg, it is stated that "Based
upon experience with receipt of other alternate feeds in SuperSaks and bulk bags, the Mill expects that
the flatbed trailers or lined end-dwmp trwcks would be unloaded by tipping and dumping. A small
number of bags may be ruptured during the tipping and subsequent nxovement by dozer to the storage
location on the ore pad" ... A discussion of additional precautions and ad"ditíonal corrective action
measures that would be implemented in response to such rupture of any bag, as discussed in ltem No.
7" above, should be provided.
Letter to Rusty l-undberg
October 2l,20l3
Fage 6
EFRI Response to Conrment I
As discussed in the August 30,2A13 responses to Comment 3b of DRC's/URS' December 4, 2OI2
comment letter, and in the specific SOP for the Uranium Material, EFRI has assumed that, regardless of
the rnanufacturer's test performance data for the Supersaks, some number of Supersaks would tear or
rupture either in shipping or during unloading. The SOP procedures for Uranium Material storage were
based on the assumption that sorne Supersaks in storage would be in broken condition and for that
reason would be repeatedly wetted until they are covered. Moreover, the SOP specifically states that
placement of a cover of soil or other material to provide shielding from potential gamma emanation
frorn the Llraniurn Material would be implemented, regardless of the condition of the SuperSaks; that is,
even if they remain intact during their shipping, unloading, and storage life on the Mill's ore pad.
Also, as discussed in the response to Comment 3b in the August 30,2Ol3 responses to DRC's/URS'
December 4, 2012 comment letter, the Uranium Material has significant economic value to both EFRI
and SFC; hence the schedule for its processing will be prioritized. It is expected that the Uranium
Material would be processed within a two-year period from receipt of the f,rnal shipments.
A discussion of additional precautions and protective action measures that would be implemented in
response to the rupture of a SuperSak has been provided in the response to CommentT, above.
Comment 9
On pages 16 and 17 of 47 of the 8/30/13 EFRI Letter to Rusty Lundberg, it is stated that "The SuperSaks
are expected to be constructed of any of a number of types of polyolefins fibers. Although previous
experience indicates that prolonged storage of SuperSaks beyond several years may result in UV
degradation of the fiber material, it is not anticipated that degradation of the SuperSaks wíll be
appreciable, due to the expected short ore pad storage anticipated for the Uranium Material". EFRI
should provide additional information on the specific type of geosynthetic material that comprises the
Supersak bags and other pertinent characteristics of the bags (e.g., fabric weight, UV damage
resistance, weight holding capacity, drop and flip test performance resuhs, stacking height and weight
limitsfor stacking of fieldbags as applicable, if these bags are stacked at the Gore Facility and/or are
planned to be stacked on the MiIl storage pad, etc...), and the expected longevity (service lift) of the bag
geosynthetic material, with supporting reþrence information. EFRI should present conclusions
regarding the expected integrity, durabiliry/survivability, and service hfe of the Supersaks relative to
the environmental and handling/storage condítions that these bags have exposed to at the Gore
Facility, will encounter during loading, transport, and unloading and later loading and hauling to the
Mill at the Mill Site, and relative to the total amount of time from the first use of the Supersaks
containing the Uranium Material at the Gore, Oklahoma Facility to the time the Uraníum Material is
processed at the MiU2
EFRI Response to Comment 9
2 Information contained in the following document may be applicable for addressing questions posed in this item (should
verify that the proposed material and Supersak bags described in the document listed below are the same as those that were
actually used):
Letter to R.usty Lundberg
October 21,2013
PageT
SFC has selected B.A.G. Corp.'s Spec. Number G6798-1 35 cubic foot, 1,000 kg Supersak for shipment
of the uranium Material. B.A.G. Corp's Product Specification and bag drawing, along with TEN-E
Packaging Services, Inc.'s test results data are provided in Appendix E to this letter. The enclosure
provided with URS' letter of September 19,2013 also refers to the same Supersak specified by SFC for
this purpose.
All data available from SFC has been provided in these attachments. The Supersak rneets US DOT and
{JN packing Group II and III test standards, by passing the required Top Lift, Stack, Drop, Topple,
R.ighting, and Tear tests as identified in attached Test Report #: O4-47I1. The Supersaks passed a load
stacking test at full load weight (I,0O2.7 kg) with a safety factor greater than 5. That is the Supsaks
retain their integrity up to a top load of 5,443"2 kg, as stated in attached Report # 05-4605 or could be
stacked 5 high with no loss of integrity. The Mill plans to stack the Supersaks 3 to 4 high.
Long-term UV damage resistance is not a concern for the Supersaks because they have been stored
under a UV protective polymer cover at SFC and will be stored beneath soil at the Mill.
Comment l0
Reference Attachment 7 (SOP): In ltem 10b. it is stated that "the completed stockpile [of Uranium
Material temporarily stored on the storage padl will be covered with native soils or another material
to provide a cover of the stockpile to reduce the potential for dusting and provide temporary radiation
cover". EFRI should provide additional information regarding the material(s) proposed for such use,
including minimum design/performance criteria such as water and wind erosion resistance thresholds
and requirements; if a geosynthetic material cover is used, the minimum wind uplift, ultimate wide-
width tensile strength, UV radiation damage resistance characteristics of the geosynthetic material to
be used, proposed ballast method and placement configuration, if applicable, etc...) to support the
suitability of that material for covering the Supersak containers of Uranium Material while stored on
the pad. Additionally, Item 10.c. of the SOP should discuss contingency/repair measwres that wowld
be undertaken if inspections indicate loss of integrity of the cover material.
EFRI Response to Comment 10
EFRI proposes to cover the Uranium Material Supersaks with approximately 6 inches of native soils
or the equivalent. The Mill has placed a similar cover of soils on alternate feed bulk material from
Cabot and bagged alternate feed material from Fansteel Metal Resources, [nc. ("FMRI"). The soil
cover will be monitored for apparent dusting and will be sprayed with water when the cover soil, or
the ore pad conditions in general, indicate the potential for dusting.
As stated above, it should be noted that the Uranium Material has significant economic value to both
EFRI and SFC; hence the schedule for its processing will be prioritized. It is expected that the
Uranium Material would be processed within a two-year period from receipt of the final shipments.
Letter to Rusty Lundberg
October 2I,2Ol3
Page 8
Cotnment 1I
For clarity and consistency, it would be beneficial to verify whether in Table I on page 12 of 47 of the
Revised August 2013 IAR, that the Th-232 radionuclide activity range for the Heritage Alt Feed
Materials is based on "Heritage RMPR., .f uly [5] 200A Amendment Request Application".
EFRI Response to Comrnent 11
The Th-232 radionuclide activity in Table X is based on the RMPR submitted with the July 5, 2000
Heritage ¿\lternate Feed Arnendment Request Application. Table t has been revised to clarify this
document source.
Comment 12
On pages 12 and 17 of 47 of the 8/30/13 EFRI Letter 1o Rusty Lundberg, it is stated that alternate feed
materials received from Heritage Minerals, Inc. were previously stored on the ore pad in bulk and
managed under a high thorium SOP which was previously approved by the NRC, and that a copy of that
SOP is provided in Attachment 7 of the Revised August 2013 LAR. On page 1I of 47 of the 8/30/13
EFRI Letter, it is stated that: (i) a high thorium SOP was originally prepared for the WR Grace
alternate feed material, which had "a much higher concentration of Th-230 and Th-232 than the
[Sequoyah Fuels] Uranium Material", and (ii) that "a modified version of that SOP was ølso
implemented for the Heritage alternate feed material". On pages I I and 22 of 47 of that letter, it also
iøÅinntoa thn¡ FFÞf ¡nìlnraÅ ¡ho ÍllÞ tLnt lo ;--1")-,1 i- ¡¡^^l^-nn¡ -7 ¡n ¡l^- D-,'i"-Å A,,n,,¡¡ )n12 I AÞ ¡^att .Ø.úv. çØ atov uvt ùtLøL Lr ú.avLuLwaØ ara t tLtøvrL,ra9taú t av arLo ar9vþúwq tLwâØoL LvtJ u ttr LU
the specific radiological characteristics of the (Sequoyah Fuels) Uranium Mqterial.
To permit comparison of "the high thorium SOP previously approved by the NRC" to the SOP in
Attachment 7 to the Revised August 2013 I^A,R, considering dffirences in the isotopic compositions of
the [Sequoyah Fuels] Uraniwm Material, the WR Grace material, and the Heritage Minerals material,
EFRI should provide: (i) a copy of the previous SOP that was used during handling of the Heritage
Minerals material; (i) a copy of the previous SOP that was approved by the NRC; (iii) a copy of the
initial SOP that was prepared for the WR Grace material; and (iv) a copy of the WR Grace alternate
fee material License Amendment Request (or a referenceable version of the RMPR, at a minimum) for
the WR Grace material. Apparent or actual inconsistencies in the cited descriptions provided in
dffirent sections of the text in the 8/30/13 EFRÍ Letter should also be corrected.
EFRI Response to Commentl2
Copies of the following documents, as requested in Comment 12, have been provided in Appendices to
this letter:
o High Thorium Content Ore Management SOP approved by NRC for W.R. Grace alternate feed
material PBL-XX (,Appendix F),o Radioactive Material Profile record for W.R. Grace alternate feed material (Appendix F),o Heritage Alternate Feed Management SOP PBL-6 adapted from the W.R. Grace SOP by the
Mill's SERP and approved by NRC (via the annual SERP report) (Appendix F), ando The revised SFC Uranium Material specific SOP (Appendix D).
Letter to Rusty Lundberg
October 21,2013
Fage 9
For ease of reference, Table 2 below, summarizes the levels of key radionuclides in the IV.R. Grace
Alternate Feed, lleritage Alternate Feed, and SFC Uranium Material.
Table 2
' From Decem
' From July 5,3 From npiit t
o Th-230 is not included here because it is considered in the development of
DACs for each ore or alternate feed material.
EFRI wishes to clarify that both the W.R. Grace High Thorium SOP (or "High Thorium SOP") and
Heritage alternate feed SOP were approved "NRC approved SOPs". The W.R. Grace SOP was
approved by direct submittal to NRC on December 18, 2000 in response to discussions between IUSA
and NRC regarding W.R. Grace alternate feed material. As mentioned in the attached letter in Appendix
F, the procedure was approved by Mr. Bill von Till of NRC staff. The Heritage SOP was developed by
the Mill's Safety and Environmental Review Panel ("SERP") process by adaptation of the W.R. Grace
High Thorium SOP, and submitted to NRC as part of the Annual SERP summary reporting process for
2æ3"
The SFC SOP was adapted from the \Y.R. Grace High Thorium SOP approved by NRC. The
following discussion summarizes and compares the SFC specific SOP to the W.R. Grace SOP.
The specific differences between the \il/.R. Grace High Thorium SOP and the SFC SOP can be
summarized as follows:
High Thorium SOP addresses decontamination and release of lntermodal Containers ("IMCs").
Since IMCs are not planned for use in transport of SFC material, such language has been
modified in the SFC SOP to refer to trucks and/or trailers.
The High Thorium SOP limits the size of bulk stockpiles of material to 200 tons or ten 20-ton
container loads. SFC material will not be stored in bulk piles, but in Supersaks. Hence the
limit for loose bulk solids is not applicable.
a
a
lV.R. Grace Alternate
Feed3
Heritage Minerals
Alternate Feed2
SFC Uranium
Materiall
Ra-226 (pCi/g)2,000 average, 10,400
max
186 average 135 to 367
Weighted averase236
Th-228 (pC¡/g)2,000 average, 10,400
max
170 to 186 based on
equilibrium with U238
449 to l,ll0
Weighted average 699
Th-230(pCi/g)2,000 average, 10,400
max
170 to 186 based on
equilibrium with U238
43,900to74,400
Weighted average
55.685
Th-232 (pCi/e)8,000 average, 31,500
max
1,190 average 1,060 to 4,990
Weishted averase2.385
Unat (me/kg)7,4N averuse 500 average 7,080 to 10,100
I-etter to Rusty l-undberg
October 2l,2Ol3
Fage l0
The F{igh Thoriurn SOP commits to the addition of stabilizing agents to the water spray on the
loose bulk solids in bulk piles. Because the SFC material will be stored in Supersaks covered
by native soils, the addition of stabilizing agents to the water sprays was not required.
The F{igh Thoriurn SOF commits to covering the bulk stockpiles with reinforced plastic.
Because the SFC material will be stored in Supersaks of polymer (plastic) material, the SFC
SOF comrnits to covering the Supersaks with native soils in lieu of plastic sheeting.
Othen requirernents in the W.R.. Grace SOF related to radon monitoring, area airborne monitoring,
breathing zone safnpling, equipment release surveys, personnel protective equipment, urinalysis and
other dose monitoring, have rernained the same in the SFC SOP.
Yours truly,
Funr.s Rnsouncns (USA) Ir,rc.
Jo Ann Tischler
Manager, Compliance and Licensing
cc Frank Filas, EFRI
David C. Frydenlund, EFRI
Dan Hillsten, EFRI
John Hultquist, Utah DRC
Ryan Johnson, Utah DRC
Harold R. Roberts, EFRI
David E. Turk, EFRI
Kathy Weinel, EFRI
Attachments
a
o
AppendËx A
Table 1
Comparison of Radionuclide ActÍvity Concentrations in
Proposed Uranium Material and Previous Alternate Feeds
t Attachment 2 of the December 2Ol I Amendment Request (Radioactive Material Profile Record, and associated
tables)2 pCi/gunless otherwise noted3 Selected concentrations for constituents found in characterization data for other alternate feed materials licensed
. for processing at the Mill, for comparison purposes only.* Mined ores range from}.l%o to higher than lVo. Some Arizona strip ores have ranged as high as 2Vo lJ3Os (1.77o
U-nat). Abundance of uranium daughters can be estimated from the assumption that ores are in secular
_ equilibrium.
' Th-230 is not a contributor to gamma emissions but has been included here because it is considered in the
_ generatio
o'Based on7' Monthly ally been as high as80.7To U3O3 (68.67o U).8' Heritage bulk and managed under a high thorium SOP.
Radionuclide
Range of Uranium
Matenial Radionuclide
Activity Concentnatioml
(pCi/g dry)2
Previously Licensed
Alternaüe Feed
Radionuclide Activity
Concentrations3r4
(oCi/e drv)2
Source for Alternate Feed
Information
Ra-226 135 to 367
Weishted averase 236
2,000 avg; 10,400 max rùy'. R.Grace Application April
2000
Th-228 449 to I,llO
V/eighted average 699
2,000 avg.; 3,222 max rJy'.R. Grace Application April
2000
75.5 mg/kg (1,555,000
pCilg) avg.,l43 mglkg
(2,330,000 pCi/e) max.6
Nevada Test Site Cotter
Concentrate Application March
1997
Th-230"43,900 to 74,400
rMeighted average 55,685
2,OOO avs.., 10,400 max W.R. Grace Application 2000
8,000 avg.; 31,500 max W.R.Grace Application April
2000Th-232 1,060 to 4,990
rWeighted av erage 2,385
1.190 avs.Heritase RMPR, undatedð
Unat 7,080 mg/kg to 10,100 mg/kg 686,000 mg/kg max'Mill lab monthly assays Cameco
UFo
Appendix B
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
a. The process bl¡ which the material was generated.
Sequoyah Fuels Corporation chemically converted uranium ore concentrates to uranium
hexafluoride. This process included two primary purification steps: digestion followed by
solvent extraction. Digestion occurred by dissolving the uranium in nitric acid. The resulting
slurry was subjected to solvent extraction using tributyl phosphate diluled with n-hexane.
Process conditions were conlrolled to extract uranium into the organic phase. The milling
impurities remain in the aqueous phase, a dilute nitric acid mixture termed raffinate.
The aqueous raffinate stream is primarily a solution of nitric acid, melallic salts, and trace
quantities of uranium and radioactive transformation products of natural uranium, primarily
Th-230 and Ra-226. The aqueous raffinate stream was combined with spent sodium
hydroxide from nitrous oxide scrubber systems and waste sodium carbonate solutions. The
untreated raffinate stream from solvent extraction was pumped to an impoundment and
allowed to cool. Anhydrous ammonia was added to the raffinate solution to convert the dilute
nitric acid to ammonium nitrate. The addition of the anhydrous ammonia also increased the
pH of the raffinate solution causing the metallic salts and trace quantities of uranium, thorium,
and radium to precipitate and settle out in the impoundments as raffinate sludge. The treated
raffinate solution was decanled to another impoundment for further treatment with barium
chloride to remove trace levels of radium through co-precipitation. This precipitate was
periodically combined with the raffinate sludge in the other impoundments.
The raff inate sludge was transferred by slurry to other storage ponds as necessary. The final
treated raffinate solution was stored in surface impoundments prior to use as an ammonium
nitrate fertilizer.
b. Available process knowledge of the material.
The raffinate sludge was accumulated and stored in several impoundments on site, including
Clarifier A basins and Pond 4. No other materials were combined with the stored sludge.
The raffinate sludge was eventually consolidated to Clarifier A basins to suppod
decommissioning Pond 4 and dewatering of the raffinate sludge.
The raffinate sludge was slurried from Clarifier A basins and processed through a225 psi
filter press to remove entrained water. The dewatered sludge was placed in one cubic yard
polypropylene bags. The bags are stored on site.
Page I of5
sfc d1 rev 9.30.13- redlin .doc February 2010
Hadioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
I. DESCRIPTION AND HISTORY OF MATERIAL
c. The basis of hazardous material or waste determinations.
Physical and chemical properties of the raffinate sludge have been determined at different
tlmês to support site characterization activities and treatabilily studies. The results of those
determinations are described in the RCRA Facility lnvestigation Report (HFl) and the Site
Characterization Report (SCR): information from these reports is summarized below.
Assessment of the data provided in the RFI or the SCR is included in the respective reporl.
lnformation regarding physical and chemical properties of lhe raffinate sludge developed in
support of evaluating dewatering the sludge is also summarized here.
The ratfinate sludge in Pond 4 was transferred to Clarifier A basins between 1993 and 1995.
A single sample of raff inate sludge was collected f rom basin 1 of Clarilier A in January 1995
to determine the concentration of volatile and semivolatile organic compounds;the basis for
the selection of constituents is provided as Attachment D1ci. The analytical results of this
sample that are greater than respective method detection limit are presented in Table 2. The
results presenled in Table 2 are lor sludge that had not been subjected to dewatering. The
laboratory report of results for each constituenl for this sample is provided as Attachment
D1cii.
Raff inate sludge was collected in May 2003 f rom basin 1 of Clarifier A for the purpose of
testing feasibility of dewatering the raffinate sludge using a pressurized plate filter press.
After dewatering by the filter press, three samples were developed and analyzed for metals
and radionuclides. The three samples included the dewatered sludge, the water expelled
from the sludge as a result of dewatering (filtrate), and a leachate derived from the dewatered
sludge. The analytical results of these Dewatered Sludqe samplee are presented in Table 1
as Dewatered Sludge May 2003 Total Meta
+esp€€+ively. The laboratory repods for these-lhis_samples a+e-þprovided as Attachment
LJ tuilt.
Physical characteristics of the raffinate sludge are provided in tables 3 and 4. These results
represent the raffinate sludge before and after dewatering by pressurized plate filter press,
respectively. The dewatered sludge passes the paint filter test for f ree liquids (EPA Method
e0e5A).
Dewatered raffinate sludge samples were collected in December 2012 and analyzed for total
metals and Toxicity Characteristic Leachate Procedure ("TCLP') metals. The December
2013. The analyticalsuite of metals are based on 40 CFR 261.24 Table 1 [Vlaximum
Concenetration of Contaminanats for the Toxicity Characteristic. The analytical results are
summarized in Table 1 as the Dewatered Sludge December 2012 -Total Metals"and
Dewatered Sludge TCLP Leachate December 2012 . and inTable 5 as Anion Data for
. The laboratory reports for the analyses of the
December 2012 included as Attachement D.1cv
Page 2 of 5
.doc February 2010
Radioactive Material Profile Record: Sequoyah Fuels Corporation; dewatered raffinate sludge
D. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTION AND HISTORY OF MATERIAL
A list of the chemicals and materials used in or commingled with the material; a list of any and all
applicable EPA Hazardous Waste Numbers, current or former; and a list of any and all applicable land-
disposal prohibition or
or delistings.
Chemicals or materials used in or comingled with the raffinate sludge.o nitric acid. tributyl phosphate. n-hexane. anhydrous ammonia. barium chloride. spent sodium hydroxide. waste carbonate solutions. recovered weak acids
Any and all applicable EPA Hazardous Waste Numbers. none
Any and all applicable land-disposal prohibition or hazardous-waste exclusions, extensions,
exemptions, effective dates, variances or delistings. none
d. Attach the most recent or applicable analytical results of the material's hazardous-waste characteristics
or constltuents.
See attachments Dl cii through Dl cv for applicable laboratory reports.
None
f. Attach any oroduct infbrmation or Material Safet)¡ Data Sheets associated with the material.
None
e
Page 3 of 5
I sfc d1 rev 9.30.13- redlin .doc February 2010
Appendix C
O¡treach
Laboratory
3l t l'{orlh Aspen
Ðrd¿sn A.r¡ow, Oltlæ12
i9!8) 25¡-25'5
rAX (9t8) 251-O0O8
LABOßATOßY
ACCßEDITATION
BUßEA\,',,'_ i': I i.','.ri.nel ô
&ffiËrumE[I
@
- srlill¿atrr + l- 22tÌ'1 Testlno
'IJ
ON{JÐ,I
Case Narrative
tab No: 20130697
This report contains the analytical resi¡lts for the I sample(s) received under chain of cuslody by Outreach Labof"llor\ !\rr
06 28 l3 I I :59:05, These samples are associated with your SFl3-128 project.
The analytical results included in this ieport meet allapplicable quality control procedure requiretnen"s excepl ¡ì\ llotcd bcit x
The ¡est resulls in this report nreet all NELAC requirements unless noted beiow:
This leport shall not be reproduced, except in full, without the written approval of Outreach Laboralorl
All radiochernical sample results for solids are repofied on a dry weight basis with the exception of trillun, carbotl- l4 ,rntr
radon, unless wet weight was requested by the client.
C)bserYations / Nonconformânees
The fbllorving QC paramsters are outside method control limits
The MS MSD oo Recovery for Ammonia diluted out.
Thc MS o b Recovery for Nitrate diluted out,
Observations / Nonconformances
l'lris re pon has been amended from lts original version submitted on 07' | 9 2t)13, The date sarnpled tbr sa¡irple 20 I 3009: 0 ,
was reported as l2 l0 2013.'lhat date is ineorreet. The eorrect date sampled is l2 l0 2012. An amended leport \\tlh tl'i!
correetion has been issued. No other changes have been made to this repon.
1 t- l Af a',ñrlic¡î Þ;rrnntc,p¡IFll-ll -- Þelntr flFt..ti^ñ I ilnrr
Clienr
Ciient Project:
Lab Number:
Date Reponed:
Date Received;
Page Number;
Sec¡rror.rlr I uels Lolp.
\l- ll- 128
l0 t.ì0697
09 26 li
6lE t3
2 ol2
Anrl¡ sis Anulysl
Datr
Outrcacfi
faUoræory
3l I North Aspen
Erctr:o Arrcnv, AKT4ÉIZ
|9tat ?5t-l'tsfÆ( ig¡a} 251-OOOE &ffiËFåeË,Ð
Melhod
Analytical Report
Result DL LOD LOQ Unils Qual. Prep
Dale
Lab lD:
C lienl lD:
l)ate Sompled:
Ìlatrir:
\rnmonia as N
I luoride
ritrate-Nitrire ar (N)
20't30697-A1
sD-282
lZllù,tlZ I l:30:00
scM
SM 45OO-NH3 B.D
SFC Ken-McGee
257-F-3,SM 4500-F -
C
SM 4500-,"'l03-D
lnorganics Analyses
5210 84
4410Ð 3070
45ß0 ?5
07 l7 t-1
07 17 r]
r)7 l" ll
(,7 lt)'l
mg'kg
mgikg
mg I'g
I{.7
tìT
0717ll {ì1 -'1 l(T
QC Report
l'nr¡¡metcr Blnnk LCS
%REC
LCSD
%REC RPD
RER, NAD MS
or DER o¿'oREC
IVISD
ü/oREC RPD
DL'P
RPD
D¡lc
\nlnlollia as N
I ILtoridc'
', itratc -Nrtrite ¿¡s (N)
0t
365
I,E
t,0
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DO
DO
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u7 l9lj
07 i7 tì
3."7
l0.E Þ(r
Lab Approval:
ifrll--l ¡\C Cerulied P¡romçter BDL - Þelo¡v Detcc¡ion Lrm¡t
SD- 28LClient Sample lD
'(
tlto/t¿
Date
Sqmpled //;n
-lïlfle
Sampled sMatríx
Prolect:
Requested Turnaround Time':
Sample/cooler Return eddress*?
I
c.'6-
caO¡+
P
Contaanêr
Size
Plastic or
Glass
L
Prsservat¡vè É
f. icÉ. <4"C
z. HNor pH<2
3. HÇí pH<z
4. f-(...sQ¡ pH<z
5. NsoF{ pH>f 1.
6. NofÌr,,
F
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Hardcopy Lvl 2 or Lv[ 4' EDD'
C¡ty
pany
Fax:
Statê
Phone
Data Email only
EmaÍl address
Þ
t\Ir
BY OATE. -. - TIME' RECE!\G:ÞBY:,
My slgnatute on thfs chaín of cuslsdy forrn, Indicstes th,al | ám authorized by lhe above company to re.lease samples Ícr aûstysie. The com,pany agrees þ pay
the entire balsnce upon receipt of sample datE and il is understood and egreed that any bElance earríed over thirty (30) days is suÞjecÍ to. a 1.5"k per mgnth-
(1.8% Per annum) fate cnarge. !n the eveî.f. of defbult. the company b@comes legafty (iaÞle for any reasonable atforney and/or coflec,tion fêes and alt relsted
cosr.s necessgry lo romit the enlire Þalance to OutreachTechnologies, !nc. (Outr.each Laborat-qry)-
þr non-sta.ndard turn-limes ancf F.DD fbrm.sts. for hardcopies. Level 4 dâta pkgs. and fadíoecfive sample dtsposol of retumed
8-ELINOUISHED BY r,.u.e/-O-&*EcErvEo ch)1]ME:/ pme
.AddÍtionBl charges
Êìç
în'o,tDn-çrzE
Remarks (1"e.
Filtered. Unfìltered,
Grâh- Co]ltôositel
City
PO#
State zfp
Send by mail or emal.l
Address
Company
Name
Phone
address
R<achint br¡.ond ilra tl?l¿ørd.
Outreech L^aboraúory
o¡H4.IN OT GUSTODY
I f North Aspen
Broken Arrow, OK 74012
Phone: [phone]
Fax: (918) 251-oOoB
www.outreachlab.com
StrE
P6o"^,r fl
7rr
zÊ7 ,FR-sE€- st/2 -
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BILL TO
ANALYSIS REQUESTED
RESULTS TO
Appendix D
Page I of8
No.: PtsL-8
Rev. No.:R-0
Date:A*gtrst
27Sçp!e!sþer25,
2013
ENERGY FUELS RESOURCES (USA) INC
STAND,ARD OPERATING PROCEDURES
Title: SFC Alternate Feed Management
1.0 Pqrpqee
The following procedure applies to acceptance of alternate feed material(s) which Energy
Fuels Resources ({.lS,A) Inc. deterrnines to potentially contain levels of thorium that
require worker safety and/or environmental protection measures over and above those
required for conventional ores or other alternate feed materials. This procedure may be
amended, subject to approval by EFR's Safety and Environmental Review Panel (SER.P)
from time to time, as appropriate to incorporate information and results obtained from the
evaluation of health physics surveys, monitoring and controls implemented to keep
radiological exposures to employees, the public and the environment As Low As
Reasonably Achievable (ALARA).
The methods set forth in this Standard Operating Procedure (SOP) are based on the
assumption that the SFC material(s) will be delivered to the White Mesa Mill in
Supersaks in poly-lined shipping boxes in an enclosed trailer or flatbed. Should the
delivery method be modified, EFR will revise this SOP to address the selected mode of
delivery.
2.4
For material receiving procedures, see Section 2.0 of V/hite Mesa Mill SOP PBL-9, End
Dump Trailer Accepîance, Handling and Release.
I s.o
The trailer containing the SFC material will enter the Restricted Area at the
Scalehouse gate and proceed to the scales and weighed.
After weighing the load, the truck and trailer will proceed to the designated
unloading site.
At the unloading site, the trailer will either be opened or the tarp removed from
the flatbed. The Radiation Safety Officer, or their designee, will perform an
entrance bet4/gamma survey on the material and will document thoqe findings on
an Aiternate Feed Receipt Inspection form. These forms will be maintained
within the Radiation Department.
After the inspection process by the Radiation Staff, the load will be off loaded.
After all material has been removed from the trailer, the now empty transport will
return to the Scalehouse for an empty weight.
1
2
3
4
5
No.: PBL-8
Rev. No.: R-0
Date:
27sg¡!g!qber25,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PR.OCEDURES
Title: SFC Alternate Feed lVfanagement
Page 2 of 8
6. The conveyance will then enter the decontamination process.
7
8.
9
Once an ore lot pile is complete, label the pile with the appropriate ore lot number
and cover.
Use a front-end loader or similar equipment to push the bags of material into the
designated ore lot pile.
Gross alpha, beryllium, arsenic and lead air sampling will be performed
continuously, as indicated in Section 7.I of this SOP, during initial phases of
material receipt in order to determine the exact frequency of monitoring and the
required PPE to be used. A Radiation Work Permit ß\ryP) will be issued during
the initial receipt of the SFC feed material(s). The R\ryP will list the health
physics controls, required PPE, monitoring and survey requirements necessary to
assess the radiological and health exposure potential to employees operating
under the RWP. The air sampling data collected, as described in Section 7.I of
this SOP, will also be among the data used to ensure that the stabilization methods
listed below are adequate.
10. Dust suppression measures will include the following:
The stockpile will be wet down at least once per day until such
time that it is covered.
The completed stockpile will be covered with native soils or
another suitable material to provide a cover of the stockpile to
reduce the potential of dusting and provide a temporary radiation
cover,
All stockpiles will be inspected at least once per day to ensure the
integrity of the covering.
In the event of wind speeds in excess of 20 MPH, all dumping
activities will cease immediately.
4.0
!; !i
Due to the potential fol higher concentrations of thoron and other potential radiological
hazards during SFC processing, the following monitoring methodologies will be followed
while processing SFC mill feed. Based upon results of monitoring and dose calculations
and recognizing that there may be a potential for higher than normal radioiogical
exposures, the Mill Radiation Safety Officer (RSO) may recommend that personnel be
rotated from area to area periodically in order to reduce potential exposure.
a.
b.
c.
d.
Page 3 of 8
No.: PBL-8
Rev. No.: R-0
Date: A,ugt+st
2013
ENERGY FUELS RESOURCES (USA) INC.
ST^ANDARD OPERATING PROCEDURES
Title: SFC Alternate Feed Management
As soon as the.results of the monitoring activity, conducted in accordance with the
conditions indicated by the R'WP, have been evaluated, the added radiological surveys
applicable to the particular SFC material will be established, communicated to the
Radiation Safety Technicians (RSTs), conducted, and documented. Irrespective of the
added surveys selected, the following radiological surveys will be performed routinely
for the duration of the receipt of SFC rnaterial.
4.1 A.rea /\irborne Sampling
\Meekly area airborne sampling will be conducted in the areas of the Mill listed
below. Also, an eight hour air sample will be collected at a flow rate of 40 liters
per minute, or greater. ,{fter sufficient data has been collected and reviewed by
the RSO and ALARA Committee, area airborne sampling frequency may be
reduced to once every two weeks during the receiving of SFC mill feed.
Ore Storage area.
Leaching area.
Central Control Room.
SX Building.
Precipitation area.
Yellowcake drying area.
Yellowcake packaging area.
The above samples will be analyzed for gross alpha, beryllium, arsenic and lead.
4.2 DAC Determination
A composite feed sample will be analyzed for radioscopic composition for U-Nat
and Th-Nat. A composite of two air samples from each of the above locations
will also be analyzed for U-Nat and Th-Nat. The composite air sample results
will be compared to the feed material results. These data comparisons will be
used by the RSO to establish the appropriate derived air concentrations (DAC) for
each location listed above, and the U-Nat to Th-Nat ratio for analysis using gross
alpha counting. If gross alpha counting of air samples using the U-Nat to Th-Nat
rations indicate an ajrborne radioactive dust concentrations of 257o of the {çrived
D,AC or the geometric rnean of the mixture, in any of the areas listed above, then
the air sample frequency will be increased to weekly in those areas only.
4.3 Breathing Zone Sampling
Breathing zone air samples will be collected once per month on
select individuals who perform routine work tasks associated with
processing operations.
1
2
J
4
5
6
7
a.
No.: PBL-8
Rev. No.:R-0
Date:Augnst
23Sçp!e!qþer25,
2013
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: SFC Alternate Feed Management
Page 4 of 8
Breathing zone air samples will be collected from individuals who
perform work tasks under an RWF.
In addition to he above sampling under (a) and (b), further
breathing zone samples may be collected from individuals at the
discretion of the RSO.
Samples will be analyzed for gross alpha, berylliurn, arsenic and
lead.
4"4 EnvironmentalSampling
a. Continuous air samples will be collected on a weekly basis in the following
areas during processing of SFC feed material.
i. Ore Storage area.
ii. Tailings area.
4.5 Tailings Management
Tailings resulting from the processing of SFC alternate feed material will be
deposited in an area of the tailings system that will ensure that the material is fully
submerged beneath pond liquid and/or tailings slurry from non-SFC alternate feed
materials until such time as the first layer of interim cover or random fill is placed
on the tailings system. This will minimize the potential for thoron gas to escape
to the atmosphere. Mill Management and the RSO will coordinate efforts to
ensure that operations personnel are provided direction regarding placement of
SFC tailings. In addition, the weekly tailings inspections reports will document
the placement of SFC tailings during the preceding week.
4.6 Surveys For External Radiation
All employees working with SFC material will wear a personal radiation
monitoring device. The devices will be collected quarterly and the results
entered on individual exposure forms.
Beta/gamma dose rate measurements will be performed weekly in all areas
of the Mill opq¡ations. These data will be used to perform monthly dose
rate calculations.
Monthly personal radiation monitoring devices will be worn by
individuals who perform work tasks that are anticipated to exhibit the
highest potential dose rate exposures, such as those assigned to RV/P tasks
and workers performing initial receipt and handling of the SFC material,
prior to establishment of material-specific DAC values.
b.
c.
¡(.l.
a.
b.
c
4.7 Surveys for Radon-222" Radon-220 and Their Dauehters
No.: PBL-8
Rev. No.: R-0
Date: August
2#Sçp!s!qþq25,
2013
ENERGY FUEI-S RESOURCES (US,A,) INC
STANDARD OPERATING PROCEDURES
Title: SFC Alternate Feed Management
Page 5 of 8
Monthly measurements of radon daughter concentrations for both Ra-222 and Ra-
220 will be conducted in those areas of the N{ill listed above in Section 4.1 of this
SOP. If radon daughter concentrations from either the uranium or thorium parent
are greater than25Vo of the limit (0.08 working level for Ra-222 or 0.25 working
level for Ra-220) the sarnpling frequency will be increased to weekly in areas
where these levels are routinely encountered. All ventilation systems in the Mill
will be checked daily by the radiation safety staff.
5"0 Decontamination a
For conveyance release procedures, see V/hite Mesa Mill Standard Operating Procedure
PBL-9, End Dwmp Trailer Acceptance, Handling and Release"
6.0
In addition to the usual safety procedures required for work at the Mill, the following
safety procedures are to be followed for projects involving SFC materials.
6.1 Required Personnel Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required as a minimum. These must be worn in all areas of
the Mill with the exception of the Administration Building.
The following are required while handling SFC material.
1. Coveralls. Coveralls must be laundered on a daily basis.
2. Rubber gloves.
3. Rubber Boots.
Respiratory protection as directed by the RSO or specificd in an ¡;
RWP. Respiratory protection will be used during initial receipt
(offloading) -and handling of SFC feed material(s). and transfer to
the Mill cilcuit for processing and-until material-specific DAC
values are set. In addition, all individuals who work in areas where
there is a likelihood that the airborne concentration DAC limits for
either uranium, radon, thoron or thorium will exceed 25%o of the
DAC will be required to wear respiratory protection, as directed by
the RSO (See section7.I.2), below.
4.
No.: FBL-8
Rev. No.: R-0
Date: Aa*gnst
27Sçp!enþer25,
2013
ENERGY FUEI-S RESOURCES (USA) INC.
STANDARD OPER.AT'ING PROCEDURES
Title: SFC Alternate Feed Management
Page 6 of 8
Industrial F{azards and Safet}'
1 Use caution when operating on the Ore Fad.
2. Ensure that all-no_personnel are_within 50 feet of the area where the
truck is backing up or moving.
3. During unloading operations, make sure that the conveyance is
blocked to prevent movement and the ignition is turned off.
4. Be aware of the movement and operation of the use of forklifts or
loaders in the area. Before placing the equipment in reverse, signal by
using two audible alarms with the horn. Then backup with caution.
5. Be aware of high-pressure wash water.
6. Be aware of slippery conditions on the ore pad during periods of
inclement weather.
7. Be aware of the potential for ice build-up on and around the
decontamination pad during periods of cold weather.
8. Use caution when entering or exiting equipment. Be sure to use the
ladders and hand rails. Do not jump off of the equipment.
7.4 Radioloeical and EnvÍronmental Concerns
Environmental radiation monitoring is routinely performed at the White Mesa Mill at
sufficient frequency (quarterly and semiannually) that any potential impact to the public
and or the environment would be identified. In addition to the environmental air
monitoring samples collected continuously at the Mill and analyzed for radioisotopes U-
Nat, Ra-226, th-23} and Pb-210, the air samples collected during receipt, handling,
processing and disposal of SFC materials will also be analyzed for Th-230, Ra-228 and
Th-228. The RSO will evaluate thp resulting data and compare the results to their
respective effluent concentration limits contained in 10 CFR Pat 20, ,A,ppendix B and
will retain records of these evaluations at the Mill for State of Utah DRC inspection.
7.l Airborne Radiation Protection
Until otherwise indicated by air sampling results and agreed upon by the
Mill RSO and the ALAR,A Committee, the areas of the ore storage pad
6.2
1
Page 7 of 8
No.: PBL-8
Rev. No.: R-0
Date: 'A.ugust?3Sep!s!sþer.25,
2013
ENERGY FUELS RESOURCES (US,A) INC.
STANDARD OPERATING PROCEDUR.ES
Title: SFC Alternate Feed Management
2.
used for SFC material will be posted as either a "RadÍation Area" and/or
"Airborne Radioactivity Area" in accordance with 10 CFR 20.1902.
,{ll personnel involved with material handling will be required to wear a
full face respirator, until such time that review of the air samples by the
RSO and AL,ARA comrnittee indicate that this level of protection is not
needed. Employees will be notified of any changes to the respiratory
protection requirements by memorandurn.
Subsequent to approvals by the RSO and ,\tr-AR,{ Committee for reduced
posting, if, based on air sampling, an area exhibits 257o of the D.AC limits
for either uranium or thorium, it will be posted "RespÍratory Protection
Required".
All individuals who work in areas where there is a likelihood that the
airborne concentration DAC limits for either uranium, radon, thoron or
thorium will exceed 257o of the DAC, or where there is a potential for
elevated beryllium, arsenic or lead, will be required to wear respiratory
protection. As directed by written memorandum from the RSO, one of the
following respirators will be selected:
Full Face Respirator
Powered Air Purifying Respirator (PAPR)
Self Contained Breathing Apparatus (SCBA)
Respirator usage will remain in effect for all areas where elevated readings
for any of the above parameters have been found until laboratory analysis
indicates that the operations no longer pose a health risk.
Personal air monitoring will be conducted as per Section 1 of the V/hite
Mesa Mill Radiation Protection Manual and Sections 4.2 above.
Continuous air sampling will be conducted around the perimeter of the ore
pad. At the onset of the SFC project, sample filters from the continuous
air samplers will be collec{pd and analyzed for gross alpha, Ra-222 and
Ra-220 on a weekly basis. This frequency may be relaxed upon approval
of the site RSO and the ALARA Committee.
Real time thoron monitors will be placed around the periphery of the ore
pad for the duration of the SFC project. These monitors will be changed
out according to the frequency recommended by the manufacturer and
analyzed for Ra-220.
3
4
5
6.
7
I
No.: PBL-8
R.ev. No.: R-0
Date: At*grst
?7Sçptsloþer2s,
2013
ENERGY FUELS RESOURCES (US.A,) n{C.
STANDARD OPERATING PROCEDURES
Title: SFC Alternate Feed Management
Page 8 of 8
7.2 Urinalysis
All personnel involved with the dumping and stockpiling or processing of SFC
content rnaterial and RST's involved in monitoring described in this SOP will
submit a urine sarnple every two weeks at a minimum, or at a greater frequency if
so directed by the provisions of an RWP. These samples will be analyzed for
uranium and thoriurn content. Evaluation and corrective actions will be
conducted pursuant to guideline provisions contained in Regulatory Guide 8.22
Bioassay at Uranium l\4ills. In vivo lung counting may be implemented if
circurnstances suggest an overexposure or uptake of either uranium or thorium
has occurred. trn vivo counting will be conducted at the discretion of the RSO and
AI-ARA Committee.
7.3 Personal Hygiene
1 All personnel involved with the dumping, stockpiling or processing of
SFC material will be required to wear designated coveralls. These
coveralls will be changed and laundered on a daily basis.
All personnel involved with the dumping, stockpiling or processing of
SFC material will be required to shower before leaving the restricted area
ta the end of their shift.
All personnel will survey their hands, boots and clothing for surface
contamination prior to eating or leaving the restricted area.
2
J
Appendix E
Product Specification
Customer
Customer #
Customer Spec. Number
BAG Spec. Number
Prepared by
Date
BaE Style
Bag Diameter
Bag Cubic Foot
Working Load
Ticket Print
Specification D.O.T, / U.N
Lift Style
Loop Size
Diameter
Material
Fill Spouts
Discharge Spouts
Liner Type
Print
Sift Resistant
Document Pouch
Extra Options
SEQUOYAH FUELS
6798
G6798-1
SHIRLEY SANDERS
7t1t2004
DT/PB/CO/NL/S-R ES/RAT I22OO#I UN-CE RT/4.PANE L
45" DIA
35 CU,FT.
2200#
uN13H2^t UN CONSTRUCTION CLASS II
Strap bag with standard 2" PP webbing
10" |ift loop
35"x35"x42"
6.5 oz coated
3 oz open duffle top x 29" long with web tie closure
Plain bottom - no spout
None
None
Filler cord - all seams
None
Reinforcement webbing sewn in top setting seam
COMMENTS
Originator's Approva Date Phone
uustomer Approvat ¡irgnaturÉ uate Pnone
Copyright O 2003 by B A.G Corp
All rights reserved Cannot be reproduced without the express written consent of B A G Corp except for intra-company use
Bag Drawing/Dinnen¡sions
CUSTOMER SPEC B.A,G. SPEC. #G6798-1
4-PANEL BAG with: FullOpen Fill Spout, Flat Eottom Discharge & Standard Straps
45"
TUF VIEt¡/29"
10"
13" I 15"
42"
BETTEM VTEV
lnches Centimeters lnches Centimeters
FILL SPOUT DIAMETER
FILL SPOUT LENGTH
LOOP LENGTH
.; STRAP OVERLAP
STRAP OVERLAP
CUBIC FOOT BAG
BAG HEIGHT
BAG NARROWSIDE
BAG WDE SIDE
45.00 114.30
29.00 73.66
10.00 25.40
13.0r 33.02
15.00 38.1 0
35.00 1.00
42.00 107.00
35.00 88.90
88.90
DISCHARGE SPOUT DIAMETER
DISCHARGE SPOUT LENGTH
0.00
0.00
CUBIC IMETERS BAG DIAMETE
[\¡OTE!!!! All dirnensions shown are between searn dimensions
Copyright @ 2004 by B.A G. Corp.
All rights reserved. Cannot be reproduced without the express written consent of B.A G. Corp. except for intra-company use
VIDE SII]E
35"
45.00 114.30
TJN PERF'ORMANCE CERTTFICATION
TIONDESIGN
4.:-TEN-E PACKAGING SI,RVICES, INC. certifies that the FIBC refèrenced above has passed the required performance tests set fòr'th below. It is the responsibility of
the end user to detetmine authorization for use under these requirements and those specifìed within the country that the above referenced packaging is manufactured. The
use ofother packaging methods or components other than those documented in this report may render this certification invalid.
ALL OTHER WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING ANY WARRANTY THAT THE PACKAGING TESTED IS MERCHANTABLE OR FIT FOR A
PARTICULAR PURPOSE, ARE DISCLAIMED. ln no event shall TEN-E Packaging Services, Inc. liability exceed the total amount paid by B.A.G. Conponatiom for sewices rendered. ln
necessary to verifi that the above tested remains in compliance with those standards.
Ê
(Da
ôÞ¡g
oq -t
,Hg+rd
5ìr 5IO l.Jò-iO-l
-ÞsÊ
Durffle T'op
Flat Bottorn
No Liner
Top Desigm:
Bottorn I)esign:
Liner:
Mfe ID / Spec. #: G6798-l
Country of Mfg.: lndia
Handlinq Method: 4 Corner Lift Loops
Flexible Intermediate Bulk Container
Style:Four-Panel
Net Capacitv: 1,000.0 Ke Q,2A4.6Lbs.)
I)imensions:35" x35" x42"
DESCRIPTION:
TEST
RESULTS
PA.SS
PASS
T'ASS
PASS
PASS
PASS
August 18,2004
Aueust 18.2004
August 19,2004
TEST
DATE
Aueust 18.2004
August 19, 2004
Aueust 17.2004
TEST
CONTENTS
Clay Based
Pellets
and tr-ead Shot
TEST
LEVEL
ó,000.0Kg-5Minutes
1,895.0 Ke - 24 Hours
1.2 Meters
1.2 Meters
0.1 meters / Second
4" Score / 2,100.0 Kg Top Load - 5 Minutes
IMDG
6" 6.5.4.5
6;6.5.4.6
6..6.5.4.9
6:6.5.4.11
6:6.5.4.12
6;6.5.4.10
Mexico
8.2.4
8.2.6
8.2.7
8.2.8
8.2.9
8.2.5
USA
178.812
l 78.815
178.810
178.816
178.817
178.81 8
REFERENCE
UN
6: 6.5.4.5
6:6.5.4.6
6;6.5.4.9
6:6.5.4.11
6;6-5.4.12
6:6.5.4.10
TEST
Too Lift
Stack
Drop
Topple
Rishtins
Tear
SUNIJIIARY OF PERFORNIANCE TESTS
E.A.G. Conporation
1 15 10 Data Drive
Dallas, TX 752\8
l¡t¡¡ ll¡zr¿r¡rrlii
| .rltr[.rt¡rr r I tr l¡¡ti. i.r¡,
I I'. t t',.r1',,sirr1 i,rrr..r lrrt
!,r('lr ( ,r'trì¡r lì'r.r(l ) I
\rrr¡rrrri \l\ Sitlii
-,,.,, : .,
I rrlìr t,. \rrdrt;¡r0
l'rtÍ,it g¡tria l.-fi 1ì rrtrl
I l'l\-li I'rtçLrryirl¡ \rt \rtr5. {n(.
Itrt'lr ( rrrutr l{rr:ttl I I
\($l){'ù'1. .\!N 5sflìi
u
n
The following is an example of the UN ma¡k that may be applied to this package. The markins letters. numerals and
l3H2 I Y I * I )x+ I +** / lgg5 / 1000
UN MARKING:
PACKAGING IDENTIF'ICATION CODE:l3H2 (Woven Plastic, Coated)
PERFORMANCE S'TANDARD:Y (Packaging meets Facking Group ll and lll tests)
MONTH & YEAR OF MANUFACTURE:Insert Month & Year (last two digits) of MaÍufacture
STATE AIJTTXORIZING TT{E MARK:Insert the Symbol of State Authorizing Allocation of
the Mark (Distineuishing Sisn for Motor Vehicles)
r¡ tr
NAME OR SYMBOL OF MANUFACTURER: +++ Insert The Name or Symbol of the Ma¡rufacturer
STACK TEST LOAD:I 0 177.7 Lbs
TEN-E Packaging Services, Inc. (USA)
Midwest Facility Ii_fi#f
I 0MAXIMUM PERMISSABLE LOAD:
PACKAGING CERTIFICATION AGENCY:
UNIQUE DOCUMENTATION
REFERENCE NUMBERS:
Current Certilication
Previous Certification:
a4-4711
NA - Design Qualifìcation
DESIGN RE.QUALIFICATION DATE:August 19, 2005 (Optioral)
TESTING CONDI.IC-I-ED
TESTINC CON ED BI':
IFIED
LIN JVIÁ.RK¡NG
5II]I11[ illi STfl III] RtII]
Four-Panel Flexible Intermediate Bulk Container
Net Capacity (S\ilL):
I)irnensions:
Mfg. ID / Spec. #:
Country of Mfg":
Handling Method:
Top Design:
Bottorn Design:
Liner:
1,000.0 Kg (2,204.6 Lbs.)
35"' x35" x42"
G679&1(8.ÀG. Corp)
India
4 Corner n ift Loops
Duffle Top
Flat Bottom
No Liner
Sequoyah Fuels Corporation
Highway l0 & I-40
PO Box 610
Gore, OK 74435
Attn.: John Ellis
Testing Reque¡ted By: John EllÍs
TEN-E Packaging Services, Inc.
1666 County Road 74
Newport, MN 55055
Phone: [phone]
Fax: [phone]
5:I STACK TEST
TEST REPORT #: 05-4605
T ESTING PERFORT}IED FOR:
TESTING PERFORÞÍED BY:
April 13,2005
li I liriii lili :lfilillf]Rll
Report #: 05-4605
April I 3, 2005
Page 2 of 3
TABLE OF CONTENTS
Stack Test Results 3
-Results of the Stack testing perf,ormed by T'EN-E Fackaging Services, [nc
SAMPLES RECEIVEÐ ON: March 7,2005
TEST COMPLETED ON: March 15"2005
SAMPLES:
o The sample arrived in good condition at TEN-E Packaging Services, Inc.¡ The following results are based solely on the product sample provided by the manufacturer.
THIS REPORT SHALL NOT BE REPRODUCED EXCEPT IN FULL }VITHOUT THE WRITTEN
PERMISSION OF TEN-E PACKAGING SERVTCES,INC.
@ .,RTORFRÉFIBÇ Rr.cyciirrg, lrrc
3ló ¡¡o ¡r¡¡ on rraÈnÈcrc!,N.,,r-.rtr
13H2Nt1104
ilr¡[)/Ftulsg5/1000
- r.¿.-t..1.4rsrtr,
És
++l
r-¡-W DO nglttoiá rllttrÈrßHT
Í ðT¿Pfl'lCâtr"l '
rr.tl. !rr. il,rtl lFt
&tt -Íf l0 d.'vt
Jã
t:XA tâ,
, t rrt'At ç67''-t
W*É:ß xì6"X42tÞ?(i¡l ¡{ot.l:
N
0
a a I ,¡t\at.
ItrlPc)Rf fl.I :^L'44Y5 UrT'/FrlIIC4LTY \J3?NÊ FOUF $$ffirfe'h-rilüt
Ð
DÃt^ fiA¡v€oÀLt^5 -rr uÊ¡J
o ãù
rJ0o - Jll - j)-()t) . ¿14- ]4O- /060.g,AçLOlaPaQljl
REPORT & SAùIPLE INFORÙIATION
LABBL(S) ATTACHED TO THE TESTED FIBC
Noîe: FIBC specifications are onfile with the manufacturer
iir iltliI Iiìa 5 i iìilllrlti
Report #: 05-4605
April 13, 2005
Page 3 of 3
TEST PROCEDURES AND RESULTS - 5:l STACKTEST (Sample#l)
SAMPLE PREPARATION / CONDITIOI{ING:
1 Sample Filled to 1,000.0 Kg (2,204.6l-bs.) ar
95o/oMax. Capacity / Ambient
FILLING SUBSTANCE:
Clay Based Fellets
STACKTEST DURATIOI\:
24 Hours
STACK TEST EQUIPMENT:
L.A.B. 6630 Compression System
TEST STANDARD:
ST,¡\CK TEST SET-UP
The FIBC must withstand a top load equal to five FIBCs stacked on top. The load must be evenly distributed and
maintained for a minimum of 24 hours.
1,002.7 Kg (2,210.6 Lbs.)x 5 5,013.5 Kg (11,053.0 Lbs.)
Maximum Permissible
Gross Mass (S\ilL)
Safety Factor Requested by
Sequoyah Fuels Corp.
(5 FIBCs Stacked on Top)
Minimum Required Top
Load
Actual Top Load Applied: 5,443.2 Kg (12,000.0 Lbs.)
DETERÙIINATION OF REQUIRED LOÄD FOR ST¡\CKING TEST
United Nations Recommendations on the Transport of Dangerous Goods used as a guideline
ALL OTHER WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING ANY WARRANTY THAT THE PACKAGING TESTED IS
MERCHANTABLE OR FIT FOR A PARTICULAR PURPOSE, ARE DISCLAIMED. In no event shall TEN-E Packaging Services, tnc liabiliry
exceed the total amount paid by Sequoyah Fuels Corporation for services rendered. In the event of future changes to the above retèrenced test
standard, it is the responsibility ofSequoyah Fuels Corporaûion to determine whether additional testing or updating ofpast testing is necessary to
veriSr that the packaging we have tested remains in compliance with those standards.
Í , 'r ir r;- -{t,,l.rì,,,r
f'aL Lrgir¡1 I r,¿ilttt
I l'\ l' l'rrlrr';ir1 ïcrrírrr f¡rr
llr(,¡ LÍrIt1 ll¡r;Íl I I
\¡ r¡ p¡¡il, \ll ¡íltí5
Sample
ID
Maximum Recorded Top-To-Bottom
Deflection After 24 Hours Result Comments
Upon completion of the 24-hour stack test, there
was no leakage ofthe contents and no
DerÏnanent deformation to the FIBC.
2 1.16"PASS
ST¿\CK TEST RESULTS
There may be no permanent deformation which renders the FIBC unsafe for transportation
and no loss ofcontents.
CRITERIA FOR PASSING THE TEST
Sequoyah Fuels Corporation
Highway l0 & I-40
PO Box 610
Gore,OK 74435
TESTING PERFORÙÍ ED FOR:
¿I SEOUøYAH FUELS
A GSA/EFAI. ATOMICS COMPANY
RE:0427-N
May 19,2004
Federal Express
U.S. lrluclear Regul atory Conirnission
ATTN; Mn" Myron Fliegel, Sr" Froject Þfanager
Fuel Cycle Faeilities Erar¡cL¡
Division of Fue! Cycle Safety and Safeguancls
i 1545 Rockville Fike
Trvo Sfhite Flint Norttr
Rockville, lVtraryland
Subject:License SUB-1010; Docket No. 40-8027
Amendment Request for Rafiinate Sludge Dervatering Project
Response to R.equest for Additional Infonnation
Reference Letter from Myron Fliegel to Johr¡ Ellis, Request for Additional
Information - Raffinate Sludge Dervatering Project (TAC LU0029), dated
4/23104
DearMr. Fliegel:
Sequoyah Fuels Corporation (SFC) submits this response to your referenced letter.
Responses to each of the individual questions are provided in Enclosure l.
If you have any questíons, please call me at (918) 489-551l, ext. 13, or Craig Harlin at
ext. 14.
John H. Ellis
President
xc:Kelly Bureh, Esq. OK AG
Afsaneh.trabbar, OKDEQ
Mict¡ael Broderick, OKDEQ
Rita K. rffare, EPA
Jeanine Hale, Cherokee Nalïon
Pat Ballard, NRMNC
Alvin Guttemran, Esq,, Morgan Lewis & Bockit¡s
Ricardo Munoz, LiSt{R.C Region IV
ÈilGHWAY t0 & r-40 PO BOX 610, GORE, OKLAHOfrIA 74435 (9¡8t 489-55il F,AX: l9t8| 489-2291
Enclosure I
Rosponse to NRC Request for Adctrrtional nnf,ormati,on Daitec] April 23, 2004
ENCLOSURE I
Sequoyah Fuels Corporation
Response lo Request for Additional Information
Arnendrnemt Request fon Raffinate Sludgc Dervatering
Wt¡at is tt¡e thiclcr¡ess of the concrete pad that the dewatered raffinate sludge
wiln be termporarily stored on?
RESPONSE:
The Yellowcake Stonage Pad {s six (6) ír¡et¡ thiek comerete, reinforced with number 4 (1/2
inch) rebar"
Provide delails and descriptions, including thÍckness, of the material to be
used as liners and covers for the temporary cells.
RESPONSE:
The material to be used as lir¡ers and covers for the temporary cells is PERMALONo fty
X-210@. Thís rnaterial is a 20 mil, hígh density, cross-laminated polyethylene, and is UV
stabilized to rvithstand prolonged €xposure to sunlight. The rnaterial is not prone to
environmental stress-cracking.
SFC purchased this malerial in 1999, and has an adequate amount for this project. The
material is nerv, and is still stored in the original shipping eontainers, which protect the
material from sunlight and precipitation. The manufacturer was contacted and has
informed SFC that ttre linermaterial stored in the original shipping containers will last
indefinitely rvithout degradation.
Copies of the specifìcation sheets for lhe Ply X-21 0@ are included as .Attachment 1 .
Ir¡ Section 1"3.1.4, of yourJanuaryT,zÛ}4,submitlal, it is stated thatthe
eoncrete pad includes a "clay''base" Provide the analysis which led to the
determination that the soil beneath the pad can be classified as clay.
RESPONSE:
Section 1.3"1.4 of our January 7,2A04 subnrittal refers to the processing pad which is
being construeted for this project, and states that the pad includes a clay base with a
sealed asphalt surface. No conerete is proposed for this area"
No specific analysis was performed to classify the soil as clay" The statement that the
pad Íncludes a clay base rvas based on physieal observation of the rnaterial during
preparation of the area, as well as infornnation related to the t1çes of soil on site. (See
S ite Characterization Report, Section 3.3.2.)
î
2
3.
Fage I of4
Provide details on the bags that rvill be used to femporarily store the
dervatered raffinate" The concern is to provide assurance that the hags will nnt
tear during placement or while temporarily stored. Is there a specificatior¡ of
the maximurn weight of material that can be put into a bag, and if so, how rvas
that deter¡nined? ls there a specification or¡ horv rr¡uch weight can be placed
on top of a fllled bag (i"e., horv rnanybags can be stacked vertieally) and if so,
how rvas that detern¡ined?
RESPONSE:
The bag is a woven polypropyle¡le lïexible ir¡termediate butk cor¡tair¡en (FIBC) fon
shipping, handling, and storing.
Detai ts_ídesqiglion o f bael
The bag intended for use for storage and shipmer¡t of dervatered raffinate sludge has the
follorving speci fications :
o Bag type: Four panel pollpropylene rvith glued hems on all side
se¡uns.
Weight capacity: 2200 pounds
Volume: 35 fl3
Diameter (filled): 45"
Height (filled): 38'"
'l')?e ot strap: Standard (4 straps ot 2" width and I0" length)
T¡pe ofmaterial: Vy'oven lr0}%uncoated polypropylene treated for
ultraviolet resistance.
Fabríc weight: 6.5 ounce
Color: \4¡hite
Fill: Full open duffel top
Fill closure: V/eb tieDischarge: None
Diseharge closure: Not applicable
Bottom: Flat
Liner: None
Special construction:
o Certifications: UN Packing Group II
UN13H1 / Y / {month & year manufactured) / (test counlry} / {lD of
test facility) / 5400 /1000/o Sift resistant: Filler eord in slde seams, top arad bottorn settings.
o Reinforcernent around top: Y/ehbing sewn around the top perimeter of the
bag for added strength.
The bag chosen for use by SFC has a specilied weight load of 2200 pounds" The bag is
constructed to an engineered design dependent on the desired perfornnance requirements"
4.
a
a
a
a
a
a
a
a
a
Page 2 of4
The fabric t1pe, fabric rveight; and special constructior¡ are each cor¡sidered in the design
and construction of the bag.
The bag lhat SFC inter¡ds to use is designed ar¡d iested to satisfy the requirenrents of a
UN Packing Gnoup ü packaging (a9 CFR tr78, Subparl N - trBC Perforrnanee Oniented
Slandards, and 49 CFR t7E.710 Standards for flexible trBCs). The bag has been tested
against a top lifl test. The top trift test was perfornaed at six tin¡es the maxirmur¡r net rnass.
The top lifl test was compneted i¡l accordance with 49 CFR i78 Subpart 0 - Testing of
trBCs, and 49 CFR 178"8i2 Top lifi test. The ariteria for passing the test include there be
no perrnanent deforn¡at¡or¡ rvhioh renders ühe bag unsafe f,or transportatior¡ and no loss of
cor¡tents.
The bag that SFC i¡rtends to use t¡as also been sub.lected to a drop test" The drop test was
perfomred f,rom a rniriirnurn of for¡r feet" The drop test rvas cornpleted ir¡ accorciance witt¡
49 CFR 178 Subpart O - Testing of IBCs, and 49 CFR. 178.810 Drop test. The criteria
for passing the test include lhere may be r¡o loss of cor¡tents.
The bag that SFC intends to use has been tested against a superimposed (stacked) load of
11880 pounds; this is equivalent to stacking more tlran five fllled bags on top of one filled
bag. The stacking test rvas completed in accordanee with 49 CFR 178 Subpart O -
Testing of IBCs, and 49 CFR 178.815 Stacking test. The criteria for passing the test are
that there may be no deterioration rvhich renders the bag unsafe for transportation and no
loss of contents.
Provide a discussion of the potential for a tornado to damage atemporary
storage cell and disperse the material. Discuss the probability of a tornado
hitting this location during the period of temporary storage and the potential
consequences.
RESPONSE:
The probability of any particular point in the county being hit by a tornado is 1.66x10 3
(the equivalent ofonce every 600 years.r
Records of tomadoes prior to about 1950 are aonsidered unreliable, recording only 8
betrveen 1875 and 1955 iri Sequoyah County, Oklahoma. Since I 955 there have been 33
tomadoes recorded in Sequoyah County, with approxirnately 70% oeeuning in the
months of Apri! and May" Of these 33, one was not classified as to severit¡ l9 were
classified as rveak (F0 or Fl on the Fajita Scatre),''ten rvere classified as strong (F2 or F3),
and three were classifìed as violenl (F4). ltlone of the lornadoes rvere elassified as F5.
I M.fREG-t t 57, Section 3.2.2, Environmental Assessmer¡l for ¡enerval of Speeial Ì{c¡elear Material Lieense
No. SLJB-I010, August 1985"
)
Fage 3 of4
Tomadoes have the potential to cause damage to a temporary storage cetrl and cause
dispersion of haggert material. The most likely consequences rvould be darnage due to
flytng debris. A tornado could easily damage or rennove the cover frorn the ternporary
storage cel|s, and ftytng debris could cause punctures of the Super Sacks" trf this occurs,
the dewatered sludge rvill rnost likely be containecl on the Yellowcalee Storage Fad, or
rvil! be washed dorvn to the Nor|h or South Yellolvcake Sunnp.
6"Frovide the inforrnation previously requested regarcXing the effects of severe
precipitation events. Note that tt¡e ir¡formation provided by youn subrnittatr
dated March 8, 2004, was not ørtirely responsíve to oun request" As discussed
rvith your staff on March tr6, 2004, you need to provide quantítative analysis
to shorv horv severe precipítation ever¡ts rvill be aceornn¡odated by the
drainage system" The analysis shor,¡ld specify ttre desïgn event chosen,
assumptions regarding blockage of drains, and values of parameters (such as
roughness coefïicients) used. If the design event is less severe tl¡an the
probable maxirnum precipitatior¡, you should justify its use and discr¡ss
potential impacts if it rvere to be exceeded.
RESPONSE:
Calculations were performed to determine the capacity of the processing pad and
Yellorvcake Storage Pad to accommodale a severe rainfall event (see Atlachment 2). The
rainfall event selected for the calculations rvas a storm of 1OO-year frequency,
corresponding to 9.5 inches in a 24-hour period, The calculations assume a runoff
coeflicient o199%.
Processine Pad
Due to the small síze of the processing pad, ín conjunction with the slope built into the
pad, the rainfall event will drain to Clarifier lA Basin with no appreciable buildup on the
pad. The n¡noff from a rainfall event of 9.5 inches rvill raise the level in the basin by less
than an additional 6 inches, for a lotal of l5^5 inches" This is above the freeboard of 12
inches currently maintained in the Clanfrer Basins" The excess rvater fron¡ Clarif¡er
Basin lA rvill overflorv into Clarifìer Basins 2A,3A. and 44, and rvill not overflow out of
the Clarifier Basin berm.
The stornr event used in the calculation can be aecoînmodated by the drainage syslem of,
the Yellorvcake Storage Pad. The South Yello,,vcake Storage Pad Drain has been
nnodified 1o reduee the possíbílity that debris will clog the drain" Additionally, the
dewatered Raffrnate Sludge is proposed to be stored on the north and east areas sf the
Yellorvcake Storage Pad, and these areas are above the level at lvhich water could b¡tild
up on the pad.
Page 4 of4
Appendix F
IurnnruetloNan
Un¿,muna (use)
ConponATIoN
Independence Plaza, Suite 950 . 1050 Seventeenth Street ¡ Denver, CO 80265 . 303 628 7798 (main) ' 303 389 4125 (fæÒ
Deeember n 8, 2000
VIA FACSIIvIÍLE AND OVERNIGF{T N4AIL
Mr. Fhilip Ting, Branch Chief
Fuel Cycle and Safety ancl Saf,eguards Branch
Division of Fuel Cycle tr icensing
Office of Nuclear Material Safety and Safeguards
{.J.S. Nuclear Regulatory Cornmission
2 White Flint North
11545 Rockville Pike, Mail Stop T-7J9
Rockville, MD 20852
Supplemental Information Regarding April 12,2000 Amendment Request to Frocess an
Alternate Feed Material from W.R.. Grace at the'White Mesa [Jraniurur Mill
Source Material Lieense SU.A-1358
Dear Mr. Ting:
International Uranium (USA) Corporation ("IUSA") hereby submits the enclosed final
procedure, following IUSA discussions with NRC staff regarding the subject license arnendment
request. As indicated in our transmittal of the draft procedure on December 15, 2000, this
procedure is submitted in response to the NRC's request that IUSA provide specific practices
that would be applied to managernent of the material fromr the W"R. Grace facility; however, this
procedure is intended to be applied to acceptance of any alternate feed material(s) which IUSA
determines to potentially contain levels of thorium that require that special procedures, over and
above those required for eonventional ores or other alternate feed r¡rate¡ials, be appXied.
Based on our diseussion today witli Mr. von Till of NRC Staff, IUSA understands that the
proposed draft proeedure was acceptable to NRC; therefore, tr{JSA is transrnittirag the final
version of the SOP at this time. IUSA looks forward to your staff s completion of reviewing the
W.R. Grace amendrnent request. .As always, tr can be reached at 3t3.389,4131. i
Sincerely,
22.**
Michelle R. Rehman¡r
Environmental Àzlanager
Re'
lvir. Fhilip Ting
Deoernber i8, 200û
Fage2 of 2
Attaah¡:¡iemt
Ronalcl Ð. tserg
William l.J. Deal
Davicl C, Frydenlu'rncl
R.on F. F{oohstein
V/itrliam Sinclair/UDE,Q
Williarn von TillÆrlR.C
cc
wıIpgl,-Xx
Rev. No.: R.-0
Date: Decernber 18,
2000
il-ñ1È-nrqnrTÕr.¡AruneÑt-rnif [IsÁ)-c-oR-PoRAx]rûN
SIIANÐAR.D OPERATING PR,OCED{JR.ES
Title: F{ig!'r Thorium Contemt Ore Nlanagement
Fage tr ofB
1.0 Purpose
T'he f,ollowing p,rocech..lre applies to acceptance of aXternate feed material(s) wfrich
lnternational Uraniuno (lJS,¿\) Corporalioti (I{-ISA) de'tenuines to potentially c'oiltain
levels of thorium tliat require that special proceclures he f,ollowecl, whieh are over ancl
above those required for converntional ores or other alternate feecl materials. Fotential
aÌteLrnate feed rilaterials undergo pre-acoeptance evaltlation by tihe nUS.¿\ AI,A.RA
Cornmittee. Material(s) whicla the An AR¡\ Cornrnittee determines require such speeial
procedures wini be elesignated as "F{igh Ttronium-Content" (on, "FÏTC") materials" This
þrocedwe may be uu"nt"rdud, sub.lect to approval by IUS,rVs Safety and Environrnental
Îìeview Fanel (SERP) from time to time, as appropriate ito ineolporate infornaation a¡'rd
results obtained from the evaluation of healütr physics surveys, raronitoring and controls
implernented pi;rsuant to keeping radiological exposures to ernployees, the public and the
environrnent As {-ow As Reasonably Aclaievable (AX.AF.A).
The rnethods set forthr in this Standard Operating Frocedure (SOF) are based on the
assurnption that the HTC material(s) will be delivered to the Vlhite Mesa Mill in 20-ton
intermãdal containers (IMCs). Should the delivery rnethocl be rnodified, nUS,{ will
revise this SOP to address the selected mode of delivery'
2.A Ore Receivins
For material receiving procedures, see Section 2.0 of lilhite Mesa Mill SOP FBL'tr, rev
No. R.-1, Intermodøl Cantainer Acceptance, Ilandling and Release'
3.0 Ore Dumping
I. After the IMC has been dropped off in the Restricted Area, connect the Bartlett
tipper to the ohassis with a loaded IMC and transport across the truck scales.
After weighing the trMC, rnove the tipper and ahassis onto the ore storage pad.
2- Enter the loaded weíght of the IMC on the IkfC SWT.
3 Rernovc the tarp on the baek of the [N4C and open ttre tailgate.
4 Dump the n'raterial inithe trMC onto the ole storage pad. ii
5 After all materiatr tras bcen rennoved from thc IMC, transport the empty trMC back
across the scales for an empty weight.
6. Record the ernpty weight on the appropniate Ih4C SV/T'
7. A,t tlie end of,eaeli day, turn in outbound SWT' to Mill R.ecords lVfanager.
i
S.\MRR\nr il lsopsVrtcrv0 I 2 I E00finalbymrr.doc
No.: Pgl--XX
Rev, No.: R-0
Date: Decernber I E,
2000
TNON
S'I'ANDARD OPER.ATXNG PR.C}CEDUR,ES
Tìtle: High Tlrorium Content One lvlanagernent
o'fIFage
9
I The lyfill Recorcls Manager wiil fill out a Dainy Materials R.eceipts for¡n to obtain
the net weight of the n-raterial in eactr IMC"
After weighing the llvtrC, the Eartlett tipper will deposit the nMC in a designated
area, within tire Restricted Area, f,or decontamination.
10 {.Jse a f,rorit-encn loacler or similar equipnient to push rnaterial into the cXesignated
ore lot pile.
I 1" StockpiXe size will not exceed 200 tons or X 0 containers
T2 Once an ore lot pile is complete, label the pile with tlie appropriate ore lot
number, and cover wittr reinforced plastia"
13 Gross alpha air sampling will be performed continuously, as indicated in Seation
7.1(6) of this SOP, during initial phases of material receipt in order to deterrnine
the exact frequency of monitoring and the required PFE to be ursed. A R.adiation
Work Permit (RWP) will be issued during the initial receipt of FtrTC feed
material(s). The R.WF will list the heatrth physics controls, required personal
protective equipment, monitoring, and survey requirements necessary to assess
the radiological exposure potential to employees operatrng under the RWP. l he
air sampling data collected, as described in Section 7.1 of this SOF, will also be
among the data used to ensure that the stabilization methods listed below are
adequate.
14. Dust suppression measures will include the following
Application of stabilizing agent(s) to the piles (for example
magnesium chloride or similar material), either prior to or in
addition to being covered.
All piles will be wet down at least once per day until such time that
they are covered.
All completed stockpiles will be covered with reinforced plastic.
A.ll stockpiles will be inspected at least once per day to ensule tlee
integrity of the covering.
in the evènt of wind speeds in excess of 20 ¡vÍPH, altr duneping;'
activities will cease immediately.
4"0 Ra_diatiqn_Mqnitoring during Ore Prqc€sgirig
Due to the likelihood of higher concentrations of thoron and other radiological clangers
during HTC ore processing, the following monitoring rnethodologies will be fällowed
a.
b.
c.
d.
e.
S:\MRR\m illsopsVrtcrv0 I 2 I 80Ofi n al bymrr.doc
No.: Ptsn--XX
Rev. No": R-0
INT'ERN ÃTlı¡¡ar.-l-lnÃNTu¡¡l(t-rse)conpomarloirl
Date: Decennber 18,
2000
STANDAR,D OPER,ATNNG PR.OCE,DURE S
Title: tr{igh Thoriurrn Content One Mamagernant
whitre processing FXT'C nnill feed. Basecl upoil results of n'rorritoring and dose calcutrations,
recognizing that there may be a potential for higher than non"nal raclionogicaÏ exposures,
the Mill R.actriation Safety O.ffîcer (R.SO) rnay recoûlrnend that persomrael be rotated frorn
area to area perioclically in orcler to recluae potential exposure.
As soon as the results of the naonitoring activity, aonductecl in aacorclance with the
conditions inciicalecl by the RWF, have been evaluatcd, the addecn racliological surveys
applicable [o the particular FITC mill feecl will he establislaed, comnmunieated to the
R.adiation Safety Teohnicians (R.STs), conducted" ancl documented. lmespeetive of thre
added surveys selected for the particular FIT'C feed, the followit"lg na'diological surveys
wili be perf,ormecl routireely for the duration of the processing of F'ITC rmaterials.
4.\
During initial reaeipt of FITC materials, weekly area ai¡borne sarnpling will be
conducted in the areas of the Mill listed below. A twenty-four hour air sarnple
wili be collected at a flow rate of 40 liters per minute, or greater. ,After sufficient
data has been collected and reviewed by the R.SO and ALARA Cornrnittee, area
airborne sampling frequency may be reduced to once every two weeks during the
processing of HTC rnill feed.
Ore feed area.
Leaching area,
Central Control Room.
Solvent Extraction Building.
Precipitation area.
Yellowcake drying area.
Yellowcake packaging area.
The above sarnples will be analyzed for gross alpha.
4.1.4 DAC Determination
A composite feed sarnple will be analyzed for radioscopic con'rpositíon for U-Nat
and Th-Nat. A cornposite of two air samples fron: each of the above loaations
will also be analyzed for trJ-Nat and T'h-Nat. The composite air sarnple results
will be cornpared to the feçd material results. These data cornparisons will be ¡;
used by the RSO to establish the appropriate clerived air ooneentration (DAC) for
each location listed above, and the IJ-Nat to Th-Nat ratio for analysis using gross
alpha counting" If gross alpha counting of air sarnples using the U-Nat t',0 Th-Nat
ratios lndicate an airbome radioactive dust concentration af 25o/o of the thoril.lrn
DAC or Uraniurn D,qC" or the geornetric rnean of the mixture, in any of the areas
listed above, there the air sample ftequency will be increased to weekly in those
areas only.
Fage 3 ofE
i
2
J
4
5
6
7
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-No.:-pBr---Xx--|ñîFÌ-RñATIOñÃIunnNIuM({JSA)coRPoRATnoNiI
Rev. No.: R-0 STANDARD OPERATING PÊ.OCEDÏJR'ES i
, Date: December 18,
200û
Title: Higlr Thorium Content Ore Managernent
4.2 tsreathine Zone Sampling
Fage 4 of I
Breathing zone air sarnptres will be solleotecl on€@ per
month on select indivicli"rals who perfonar routine work
tasks associated with processing operations.
Breathing zone air sarnples wiill be collected ft'orn
individuals who perf,onm work tasks under an RWF.
trn addition to the above sarnpling unden (a) and (b), further
breathing zone samples wiXl be collectectr fror¡r individ¡.¡als
at the discretion of,the R.SO.
4.3 Environmental Samp.line
Continuous air samples will be collected on a weekly basis
in the following areas during processing of F{TC feed
material.
Ore pad area.
Tailings area.
4.4 _l ilrlrnr¿s i\li!U;r!crlìgu!
Tailings resulting from processing HTC altemate feed rnaterial will be
deposited in an area of the tailings system that will ensure that the material
is fully submerged beneath pond liquid and/or tailings slurry from non-
HTC alternate feed materials until such time as the first layer of interim
cover or random fill is placed on the tailings system. This will rninirnize
the potential for thoron gas to escape to the atrnosphere. Mill
Management and the RSO will coordinate efforts to ensure that operations
personnel are provided direction regarding placernent of HTC tailings. In
addition, the weekly tailings inspections reports will document the
placernent of HTC tailings during the preceding week.
4.5 Surveys For External Radiation
a.Alt employeesi;working with HTC material will ìruear a personal
TLD badge. The badges will be collected qurarterly and the rest¡lts
entered on individual exposure forms.
Beta/gamma dose rate measurements will be perfonnecl weekly in
all areas of the mill operations. These data will be used to perfonn
monthly dose rate calculations.
Monthly TLD badges will be worn by individuals who perforrn
work tasks that are anticipated to exhibit ttie highest potential dose
a.
b
c
a
I
l
b
c
S :\MRR\m il lsops\htcrv0 I 2 I 800fi nalbymn, doc
i-Ño : PEL XX INTERNATXONAÌ- URANIUM GJSA) CORPOR,ATION
Rev. No.: R.-0
Date: Deaember tr 8,
2000
STANDAR.D OFER.ATXNG PR.OCEDUR,ES
Title: FÏigfr Tborium Conter¡t Ore lVlanagement
Fage 5 Rof,
rate exposr"tres, such as those assigned to R.WF tasks and workers
perforrning initial receipt and handling of the FtrTC rnaterial, prior
to establishment of material-specific DÉ\C vall¡es.
4.6
Monthly rneasutrerrÌents of raclon clanigtaten concentrations for hoth R.a-222
and Fta-22t will be aoncXucted in tliose areas of the lvfiltl listecl above in
Section 4.1 of ttrris SOF. Xf radon daugtrter aoncentrations frorn either the
uraniurn or thorium parent is greater tban 25%o of the limit (0,08 workialg
trevel for Ra-222 or 0.25 working level for R.a-220) the sarnpling frequaency
witl be incrEased to weekly in areas where these levels are routinely
encountered. All ventilation systems in the lvlill will be ahecked claily by
the radiation safety staff.
5.0 Dcesut¿¡,uli¡alio-n and Relea.Se of IMCs-
For intermodal release procedures, see White Mesa Mill Standard Operating Frocedure
PBL-1, rev. No. P*-T,Intermodal Container Acceptance, Handling and Release'
6.0 Hazard ldentification and Safetv
I¡ addition to the usual safety procedures required for work at the lvfill, the following
safety procedures are to be followed for projects involving HTC r¡raterials.
6.1
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required as a minimum. These must be worn in all areas of
the Mill with the exception of the Administration tsuilding"
The following are required while handling FITC material,
1. Coveralls. Coveralls must be laundered on a daily basis!
Leather or rubber gloves"2
J
4
R.ubber Boots of Rooties.
R.espiratory protection as directed by the R.SO or specified ln an
RV/P. Respiratory protection will be used during iaiitial receipt
and handling ,of F{TC feed material (s) and until material-specific
DAC values are set. In addition, all individuals who work in areas
where there is a likelihood that the ailbomE ooncentration DAC
S :\MRR\mil lsops\htcrv0 I 2 I 800fi naNbymrr,doc
I
i
No.: FBtr--XX
Rev. No.: R-0
Date: December 18,
6of8
limits for either uranium, radon, thoron or thoriurn will exceed
25o/o af tï¡e DAC will be required to wear respiratory protection, as
directed by the R.SO (See section 7.1.2), below"
6.2 nndt¡strial Hazards and Safety
1. {-Jse caution when chassis are backlng onto the Ore Facl.
2. Ensure that all personnel wíthin 50 feet of tftre anea wþrere the nNfC rs
hooked up to the Bartlett tipper are aware that clumping is about to
comrnence.
3. Bartlett tipper operators must use caution during the durnping process.
Move at least 25 feet away from the rear of the IMC during the initial
dumping operation.
4. Do not place any part of your body inside the IMC when the chassis is
being tipped and the tailgate is open. The IMC could be lowered or
accidentally fall at any time, which would cause the tailgate to close
rapidly and result in injury. Only work under the tailgate after it has
been properly blocked open.
5. Be aware of high-pressure wash water
6. \ilhen the crane is in operation, make sure all personnel, except the
persons in charge of the tag lines, are 50 feet away from the IMC
being moved. The persons in charge of the tag lines should never be
underneath the IMC that is being moved,
7, Be aware of slippery conditions on the ore pad during periods of
inclement weather,
8. Be aware of the potential for ice build-up on and around the
decontamination pad during periods of cold weather.
9. Use caution when entering or exiting equipment. Be sure to use the
ladders and hand rails. Do not jump off of the equipment"
1 "0 Raü¡_logical and E4vl¡_olr.4¡çUlel{_qne9tût!
Environmental radiation monitoring is routinely performed at the White Mesa Mill at
sufficient frequency (quarterly and semiannually) that any potential impact to tF¡e public
and or the environrnent would be identified. In addition to the envíronmental air
monitoring samples collected continuously at the Mill and analyzed for radioisotopes U-
S:\MR.R\m i I lsops\htcrv0 I 2 I 800fi nalbymrr.doc
ñã.: PtsI,Jfi
R.ev. No.: R.-0
Date: Decemher 18,
2000
ñrpm,laTr dñÃr-u fr*ÃNl uM (l-lSÃ) cıFFÕR ArnoN,
STANDAR.D OPER,ATÍNG PR.OCEDTJR,ES'Iitle: FXigh Th¡orium Content One Mamagement
Fage 7 o.f E
lriat, R.a-226, Th-230 ancl Pb-210, the air sarnples collected during reoeipt, hanclling,
prooessing, and disposal of FIT'C materials will also be ana\yzed for Th-232, Ra-228 amal
Tb-228" The R.SO will evaluate the resulting clata ancl conapare the resullts to their
respective ef,ftrr.¡ent concentration limits containecn in X0 CFR. Par.t2A,,Appenclix B, ancl
wilfi retain reoorcls of these evaluations at the Mill for NRC imspection.
7, 1 Airþ. gæe=l!+lt,r1 ¡r'_¡¡ Prplçc1lsg
1. {Jntil otherwise indicatecl by air sarnpiing resunts, and agreocl upon by tÞre iVfilX
R.SO and the ALARA Commi'ttee, the areas of tlie ore storag,e pacl used for
F{T'C material wili be posted as either a "Radiation Area" and/or "Airhorme
Radioactivity Area". These areas will be postecl with oautiora signs in
accordance with 20. 1 902.
2. Subsequent to approvals by the R.SO ancl AL,ARA Cornmittee for reduced
posting, if, based on air sampling, an area exhibits 25Ð/o of the DAC limits for
either uranium or thorium, it will be posted "Respiratory Frotection
Required".
All personnel involved with material handling during a project involving F{TC
material will be required to \¡/ear a full face respirator, until such tirne that
review of the air samples by the RSO and AL,ARA cornrnittee indicate that
this level of protection is not needed. Ernployees will be notifiecl of any
changes to the respiratory protection requirements during an FITC project by
memorandum.
a. All individuals who work in areas where there is a likelihood that the
airborne concentration DAC limits for either uraniuna, radon, tleoron or
thorium will exceed 25Yo of the DAC will be required to wear respiratory
protection. As directed by written memorandurn fro¡n the RSO, one of the
following respirators will be selected:
Full Face R.espirator
Powered Air Purifying Respirator
Self Contained tsreathing Apparatus (SCEA)
Personal air monitoring;will be conducted as per Seation i of the
rWhite Mesa Mili Radiation Protection Ma¡r¡al and Seotion 4.2
above,
Continuous air sarnpling irill be conducted around the perinieter of
the ore pad. At the onset of am F{TC projeat, sample filtens frorn
the continuous air sarnplers will be collected and analyzect f,or
gross alpha,Ra-222 and Ra-220 on a ureekly basis. T'his frequemcy
I
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S :\MRR\m i I lsops\htcrv0 I 2 I 800ftn albymn.doc
rNo.: FßI--XX INTERNA URANIUM (USA)
STANDARD OPER,ATING PROCEDURES
Title: High Thorium Content Ore Management
Fage I of8
may be relaxed upon approval of the site RSO and the A[-AR'A
Cornrnittee"
Real tirne thoron rnonitors will be placed around the penphery of
the ore pad for the duration of the FITC project. These rnor¡itors
witrl be changecn out accorcling to tlae f,requenay rocomrnendecl by
the rnanufacturer and allalyzed for R.a-220.
7.2 Uninalysis
i, All personnel irivotrved with the clurnping, stockpilirag or
processing of F{TC content material and R-ST's involvec{ in
monitoring described in this SOF will submit a urine sarnple every
two weeks at a minirnum, or at a greater frequency if so direated
by the provisions of an RWP. These samples will be analyzed for
uranium and thorium content. Evaluation and coffective actions
will be conducted pursuant to guideline provisions contained in
Regulatory Guide 8.22 Bioassay at (Jranium Mills' In vivo lung
counting may be irnplemented if circurnstances suggest an
overexposì,[e or uptake of either isotope has occurred. In vivo
counting will be conducted at the discretion of the RSO ætd
ALARA Cornmittee.
7.3 Personal Flvqiene
All personnel involved with the dumping, stockpiling or
processing of HTC material will be required to wear designated
coveralls, These coveralls will be changed and laundered on a
daily basis.
All personnel involved with the dumping stockpiling or
processing of HTC material will be required to shower before
leaving the restricted area at the end of their shift"
All personnel wiil survey their hands, boots and clothing fol
surf,ace contamination prior to eating or leaving the restricted
area. ¡i
TIONAL
Rev. No.: R-0
Date: Decernber 18,
2000
5
1
2.
aJ
S:\IMRR\millsops\htcrvO I 2 1 800fi nalbymn.doc
No.: PBL-6
Rev. No.: R-2
Date:December 18,
2012
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
Page I of9
1.0 Purpose
The following procedure applies to acceptance of alternate feed material(s) from Fleritage
Minerals Inc. (FIMI) which Energy Fuels Resources (USA) Inc. (EFR) determines to
potentially contain levels of thorium that require that special procedures be followed,
which are over and above those required for conventional ores or other alternate feçd ,
materials. This procedure may be amended, subjêct to approval'by EFR's Safety aird
Environmental Review Fanel (SERP) from time to time, as appropriate'to ihcorporate
information and results obtained from the evaluation of health' physics sur.veys,
monitoring and controls implemented pursuant to keeping radiological exposures to
employees, the public and the environment As Low As Reasonably Achievable
(ALARA).
The methods set forth in this Standard Operating Procedure (SOP) are based on the
assumption that the HMI material(s) will be delivered to the V/hite Mesa Mill in 20-ton
intermodal containers (IMCs). Should the delivery method be modified, EFR will revise
this SOP to address the selected mode of delivery.
2.0 Ore Receivins
For material receiving procedures, see Section 2.0 of White Mesa Mill SOP PBL-Z,
Intermodal Container Acceptance, Handling and Release.
3.0 Ore Dumpins
I After the IMC has been dropped off in the Restricted Area, connect the Bartlett
tipper to the chassis with a loaded IMC and transport across the truck scales.
After weighing the IMC, move the tipper and chassis onto the ore storage pad.
2. Enter the loaded weight of the IMC on the IMC SWT
Remove the tarp on the back of the IMC and open the tailgate.
Dump the material in the IMC onto the ore storage pad.
:¡
After all material has been removed from the IMC, transport the empty IMC back
across the scales for an empty weight.
Record the empty weight on the appropriate IMC SWT.
At the end of each day, turn in outbound SWT to Mill Records Manager
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5.
6
7
No,: FBL-6
Rev. No,: R-2
Date: Decernber 18,
2012
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
Page2 of 9
8
9
The Mill Records Manager will fill out a Daily Materials Receipts form to obtain
the net weight of the material in each IMC.
,A.fter weighing the IMC, the Bartlett tipper will deposit the IMC in a designated
area, within the Restricted Area, for decontamination.
10"Use a front-end loader or similar equipment to push material into the designated
ore lot pile.
ll The F{MI material will be stored in one stockpile to enhance dust control and
minimize exposure risks" The stockpile size, not including the cover material will
not exceed a height of 10 feet.
12. Dust suppression measures will include the following
The stockpile will be wet down at least once per day until such
time that it is covered.
The completed stockpile will be covered with Ashland material or
another suitable material to provide a cover of the stockpile to
reduce the potential of dusting and provide a temporary radiation
cover.
All stockpiles will be inspected at least once per day to ensure the
integrity of the covering.
In the event of wind speeds in excess of 2O MPH, all dumping
activities will cease immediately.
4.0 Radiation MonÍtorins durins Ore Receipt
Due to the potential for higher concentrations of thoron and other potential radiological
hazards during HMI material receipt and handling, a Radiation Work Permit (RV/P) will
be issued during the initial receipt of HMI material. The RWP will list the health physics
controls, required personal protective equipment, dust control, monitoring, and survey
requirements necessary to assess the radiological exposure potential to employees
operating under the RWF.
As soon as the results of the monitoring actiyity, conducted in accordance with the
conditions indicated by the RIVP, have been evaluated, the added radiological surveys
applicable to the particular HMI material will be established, communicated to the
Radiation Safety Technicians (RSTs), conducted, and documented. Irrespective of the
added surveys selected, the following radiological surveys will be performed routinely
for the duration of the receipt of HMI material. Based upon results of monitoring and
dose calculations, recognizing that there may be a potential for higher than normal
radiological exposures, the Mill Radiation Safety Officer (RSO) may recommend that
personnel be rotated from area to area periodically in order to reduce potential exposure.
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a.
b.
c.
d.
No.: FBL-6
Rev. No.: R-2
Date:December 18,
20t2
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
Page 3 of 9
4.1 Area Airborne Sampling
Weekly area airborne sampling will be conducted in the areas of the Mill listed
below. A twenty-four hour air sample will be collected at a flow rate of 40 liters
per minute, or greater. After sufficient data has been collected and reviewed by
the RSO and ALARA Comrnittee, area airborne sampling frequency may be
reduced to once every two weeks during the receiving of HMI mill feed.
HMI Stockpile area.
Scalehouse area.
The above samples will be analyzed for gross alpha.
4.2 DAC Determination
A composite feed sample of HMI material was analyzed for radioisotropic
composition. The data were used by the RSO to establish a derived air
concentration (DAC).
The DAC for the HMI material that was established based upon data gathered
under RV/P#370, and which will be applied during processing of the HMI
material, is 1.248-12 ¡tCi/cc, based on thorium.
If air sample results indicate an airborne radioactive dust concentration of 25Vo of
the thorium DAC in any of the areas sampled during processing, then the air
sample frequency will be increased to daily in those areas until mitigative
measures have reduced concentrations below 257o of the thorium DAC for two
consecutive days.
4.3 Breathing Zone Sampling
Breathing zone air samples will be collected once per week on select
individuals who perform routine work tasks associated with receiving
operations. After sufficient data has been collected and reviewed by the
RSO and ALARA Committee, breathing zone sampling frequency may be
reduced to once every two weeks or greater during the receiving of HMI
materials.
Breathing zone air samples will be collected from individuals who
perform work tasks under an RWP.
In addition to the above sampling under a. and b., further breathing zone
samples may be collected from individuals at the discretion of the RSO.
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2.
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b
c
No.: PBL-6
Rev. No.: R-2
Date: December 18,
2012
ENERGY FIIELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: tleritage Alternate Feed Management
Page 4 of 9
4.4 Surveys For External Radiation
a.All employees working with IIMI material will wear a personal radiation
monitoring device. The devices will be collected quarterly and the results
entered on individual exposure forms.
tseta/gamma dose rate measurements will be performed weekly in all areas
of the Mill operations. These data will be used to perform monthly dose
rate calculations.
Xndividuals who perform work tasks that are anticipated to exhibit the
highest potential dose rate exposures may be directed by the RSO, at his
discretion, to wear monthly personal radiation monitoring devices.
4.5 Surveys for Radon-222. Radon-220 and Their Daughters
Weekly measurements of radon daughter concentrations for both Ra-222 and Ra-
220 will be conducted in those areas of the Mill listed above in Section 4.1 of this
SOP. If radon daughter concentrations from either the uranium or thorium parent
are less than 25Vo of the limit (0.08 working level for Ra-222 or 0.25 working
level for Ra-220) the sampling frequency will be decreased to monthly.
5.0 Radiation Monitorins durins Ore Processins
A Radiation Work Permit (RV/P) will be issued during the initial processing of HMI
material. The RV/P will list the health physics controls, required personal protective
equipment, dust control, monitoring, and survey requirements necessary to assess the
radiological exposure potential to employees operating under the RWP.
As soon as the results of the monitoring activity, conducted in accordance with the
conditions indicated by the R'WP, have been evaluated, any added radiological surveys
applicable to the HMI material will be established, communicated to the Radiation Safety
Technicians (RSTs), conducted, and documented, Irrespective of the added surveys
selected, the following radiological surveys will be performed routinely for the duration
of the processing of HMI material (that is, from the time the material is fed to process to
tailings disposition). Based upon results of monitoring and dose calculations, the RSO
may recommend that personnel be rotated from area to area periodically in order to
;¡ reduce potential exposure. Èi
5.1 Area ,{irborne Sampling
Initial area airborne sampling will be conducted during HMI material feeding at
locations where it is known that the potential for dust normally exists during
material feed operations, specifically alongside the portable and the stationery
grizzly and at the belt drop chute into the trommel. Samples will also be taken
during initial ore feeding operations in any other areas which show evidence of
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b
c
No.: FBI--6
Rev. No.: R-2
Date:December tr8,
2012
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
Page 5 of9
dusting. At a minimum, initial area air samples will be collected for at least two
hours at a collection flow rate of 40 liters per minute, or greater. These samples
will be analyzed for gross alpha using standard laboratory methods described in
Mill Radiation Protection SOPs, but applying the modified DAC limits for FIMI
material that were established with RWF #370, detailed in Section 4.2 above.
As processing progresses, additional area air samples will be collected and
analyzed using the same air sampling procedures described above, in areas such
as the tr-each area or any other process areas in which the RSO determines it
would be useful to quantify the potential for air emissions.
5.2 DAC Determination
As noted above in Section 4.2, a composite feed sample of HMI material was
analyzed for radioisotropic composition. The data were used by the RSO to
establish a derived air concentration (DAC) L24E-12 ¡tCi/cc,based on thorium.
If air sample results indicate an airborne radioactive dust concentration of 25Vo of
the thorium DAC in any of the areas sampled during processing, then the air
sample frequency will be increased to daily in those areas until mitigative
measures have reduced concentrations below 257o of the thorium DAC for two
consecutive days.
5.3 Breathing Zone Sampling
Breathing zone air samples will be collected for at least four hours at a
collection flow rate of four liters per minute during initial HMI material
processing for select individuals performing material feed operations,
namely the loader and trommel operators.
Breathing zone air samples will be collected from individuals who
perform work tasks under an RV/P.
In addition to the above sampling under a. and b., further breathing zone
samples may be collected from individuals at the discretion of the RSO.
5.4 Tailings Management
ii
Tailings resulting from processing HMI material rvill be deposited in an area of
the tailings system that will ensure that the material is fully submerged beneath
pond liquid and/or tailings slurry from non-HMI alternate feed materials until
such time as the first layer of interim cover or random fill is placed on the tailings
system. This will minimize the potential for thoron gas to escape to the
atmosphere. Mill Management and the RSO will coordinate efforts to ensure that
operations personnel are provided direction regarding placement of HMI tailings.
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a,
b.
c.
No.: PBL-6
Rev. No.: R-2
Date: December 18,
20t2
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
Page 6 of 9
In sddition, the wcclcly tailings inspcctions rcports will documcnt thc placcmcnt
of HMI tailings during the preceding week.
6,0 l)econtamination and Release of IMCs
For intermodal release procedures, see White Mesa Mill Standard Operating Procedure
PtsJ-z, Inte rmodal C ontaine r Acc e ptanc e, Handlin g and Releas e.
7.4 Hazard ldentification and Safetv
In addition to the usual safety procedures required for work at the Mill, the following
safety procedures are to be followed for projects involving HMI materials.
7.'1, Required Personnel Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required as a minimum. These must be worn in all areas of
the Mill with the exception of the Administration Building.
The following are required while handling HMI material
1. Coveralls.
2. Leather or rubber gloves.
3. Rubber Boots or Booties.
4.Respiratory protection as directed by the RSO or specified in an
R\ryP. Respiratory protection will be used during initial receipt
and handling of HMI feed material(s) and until material-specific
DAC values are set. In addition, all individuals who work in areas
where there is a likelihood that the airborne concentration DAC
limits for either uranium, radon, thoron or thorium will exceed
25Vo of the DAC will be required to wear respiratory protection, as
directed by the RSO (See section 8.1.2), below.
;i
7.2 Industrial Hazards and Safety
1. Use caution when chassis are backing onto the Ore Pad.
2. Ensure that all personnel within 50 feet of the area where the IMC is
hooked up to the Bartiett tipper are aware that dumping is about to
commence.
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PageT of 9
No.: PBn--6
R.ev. No.: R-2
Date: Decernber 18,
2012
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
3. Bartlett tipper operators must use caution during the dumping process.
Move at least 25 feet away from the rear of the IMC during the initial
dumping operation.
4. Do not place any part of your body inside the IMC when the chassis is
being tipped and the tailgate is open" The IMC could be lowered or
accidentally fall at any time, which would cause the tailgate to close
rapidly and result in injury. Only work under the tailgate after it has
been properly blocked open.
5. Be aware of high-pressure wash water
6. When the crane is in operation, make sure all personnel, except the
persons in charge of the tag lines, are 50 feet away from the IMC
being moved. The persons in charge of the tag lines should never be
underneath the IMC that is being moved.
7. Be aware of slippery conditions on the ore pad during periods of
inclement weather.
8. Be aware of the potential for ice build-up on and around the
decontamination pad during periods of cold weather.
9. Use caution when entering or exiting equipment. Be sure to use the
ladders and hand rails. Do not jump off of the equipment.
8.0 Radioloeical and Environmental Concerns
Environmental radiation monitoring is routinely performed at the White Mesa Mill at
sufficient frequency (quarterly and semiannually) that any potential impact to the public
and or the environment would be identified.
8.1 Airborne Radiation Protection
I The areas of the ore storage pad used for HMI material will only be posted
as either a "Radiation Area" and/or "Airborge Radioactivity Area" in
accordance with 10 CFR 20.1902.
,A.ll personnel involved with material handling will be required to wear a
full face respirator, until such time that revierv of the air samples by the
RSO and ALARA committee indicate that this level of protection is not
needed. Employees will be notified of any changes to the respiratory
protection requirements by memorandum.
2
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No.: PBL-6
Rev. No.: R.-2
Date: December 18,
2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Heritage Alternate Feed Management
Page 8 of 9
Subsequent to approvals by the RSO and ALARA Committee for reduced
posting, if, based on air sampling, an area exhibits 25Vo of the DAC limits
for either uranium or thorium, it will be posted "Respiratory Protection
Required".
All individuals who work in areas where there is a likelihood that the
airborne concentration DAC limits for either uranium, radon, thoron or
thorium will exceed 257o of the DAC will be required to wear respiratory
protection. As directed by written memorandum from the RSO, one of the
following respirators will be selected:
Full Face Respirator
Powered Air Purifying Respirator
Self Contained Breathing Apparatus (SCBA)
Personal air monitoring will be conducted as per Section 1 of the V/hite
Mesa Mill Radiation Protection Manual and Sections 4.2 and 5.2 above.
8.2 Urinalysis
All personnel involved with the dumping and stockpiling of HMI material and
RST's involved in monitoring described in this SOP will submit a urine sample
every two weeks at a minimum, or at a greater frequency if so directed by the
provisions of an RV/P. Personnel involved in processing of HMI material will
submit urine samples at the usual frequency prescribed in Mill Radiation
Protection SOPs. These samples will be analyzed for uranium content.
Evaluation and corrective actions will be conducted pursuant to guideline
provisions contained in Regulatory Guide 8.22 Bioassay at Uranium Mills. In
vivo lung counting may be implemented if circumstances suggest an
overexposure or uptake of either uranium or thorium has occurred. In vivo
counting will be conducted at the discretion of the RSO and ALARA Committee.
8.3 Personal H)¡giene
1 All personnel involved with the dumping, stockpiling or processing of
HMI material will be required to wear coveralls. ¡¡
2 ,All personnel will survey their hands, boots and clothing for surface
contamination prior to eating or leaving the restricted area.
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J
3
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ill
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I:;ttRl,.rttro\.\L
L n.rxiU\l (LrSÀ)
'Conpon.\Tro\
TndependencePlaza,SuitegS0.l0ı0seventeenthStreet'Denver,CO80265'3036287798(main) '303389.1125rtà\)
Apri!24,200t
Mr. Tkromas lT. Essig, Branah Ctuef
Uraniu¡n Reeovery anel f-ow Levei Waste tsrar¡efri
Division of, Waste lVtranagement
Office of Ì,Iuciear Material Safety and Safeguarcls
U. S. b{r"rclear Regulatory Commission
2 White Fiint Nonth
11545 Roclarille Fike
Rockviile, hdD 20E52
¿\rnendment Request to Frocess an A.lternate Feed Material frorn W.R.. Grace at
the White Nfesa {Jranium Mill
Sourae Material I-icense S{JA- I 358
Dear Mr. Essig:
Ïnternational {.Jranium ({.JSA) Corporation ("[USA") hereby submits supplemental
information in response to comments received from b{RC during the week of April 10,
2t00, regarding the above:named requcst for amendment to Source Nlateriai License
suA-r3s8
Speeifrcally, NRC requestecl that IUS¿\ revise page two of the ruSA Râdioaetive
lvÍaterial Frofile Record ("RlrffR"¡ f,orrn, to elarefy itern D.l, whieh deseribes the liistoryof ttre u¡ranlunn material. ruSA has reviscctr ttre RMP& aeeoreling to l.lF*C's
reeomrflenclation, so that iteni D.l now reaels:
"was tliis material mixecl, treated, neutralizcd, solidified, eonimingled,
drieel, or otherwise proeessed at any tinie after generation?"
tse
A revised copy of,the RlvfP& eompleted and signeel by W.R. Graee, has bcen attaehed to
this letter
VIr. Thon:as fI. Essig
A.pril24, 2000
Fage 2 of 2
IUSA appreciates the responsiveness NRC has demonstrated in its prompt review of the
above-rnentioned ame¡rdment request. If you have any fi.¡rther comments or questions on
the r,equest or ttris submittal, tr can be reached at [phone], after May 1, 2000. I
witrl be out of,tiie country from April 15 to April 30. If you have any further comments or
qtlestions cluring that trme, piease contact Ron FXoehstein at [phone]
Sineerely,
ç-Miehelle R. Rehmann
Envirorimental Manager
MRR.:srnc
Attachment
cclatt. Williarn von Till/Ì.{RC
Ron F. Flochstein
David C. Frydenlund
lVilliam N. Deal
Ronald E. Berg
William Sinclair/UDEQ
Don Verbica/UDEQ
ATTACFIIVTENT
frhibit.{
RA-DÍOACTIVE t\ÁATEzuAL PF OFILE RECORD
Gcr¡gúçNg::9/-.LGfæ._.,*.--G,øa¡lg^va¡rsSrçg:sc@l-;Vobrr:ollffd,rtd.lgid.¿500'@o¡Â_
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chccksppoqcbcbor¡r:Ljc(rr¡d Y )e( ìf _ NORM/ÀlAllll-; iJåW )O(; MI{-; MWTæetcd-; MltrNecdiagTrd :
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OriÊ¡d$uöqirú¡s Y )CI- N-:; Rsvbim, -û-;Eg¡gf Lgvbi*4,1¡Ãxl
ì{¿ma aod Tllo of Proæ eo'rlP}nag l€ír!: -ttÍ¡r¡in w. 8.rrçúa- Pbæ: -ó?}'69?"12 ¡6
A SUSTOôáER INFORIvÍAFÍü{:
GENERJIt; Plæ€ rd erefrlly ürd cærplæ thi¡ fr¡s for crrc a/& rùcæ T?ús iaf*at¡dor¡ tilg be ryÊd to &ltrûb
bn'r þ fsec¡ly r¡r¡Ê tbc æ¡ler!¡L gùßoH tbG bc oy qEái¡r¡¡ uåüg ûdc[û¡ lbb ftrE eæld TU€ er
303,3t9.¡ll3¡. MATR,IAI.S CA¡ÛNOT EE ÄeCEPrEp AT fUe W¡{ITE IICSA MII¡, rr-NlÆS}S TtGl FOR¡ùí F
COMPIEIED. If a cdcgry dæ ncr a¡aty" Cø- indic¡a This fctr¡ ûnS bÊ ¡rpddld a¡Euaty.
I. GENERA'TCIRINFORÀ{ATTO}I
EFA IDrt TND03157530E-: pPA lls¡rdors lil¡¡c Nuabo(s) (if .p9¡í€¡t lc)
Müisg Arlk€rli -40æ N. ll¡rrùs¡c SüÊcq Cb[üæß¡ TN 37¡106-
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Phmc; 4234974216 Flç': -4234?A-2291
B. N{ATERIAI PIÍYE¡CAL PROPERTIES (Shû¡¡d yoo tr¡rr æy qoÊdøs rÀile cooghi4 tùi s*rioo, oo¡¡lrct IUC
Eovi¡uumøl ìrlangesrÉrü * (3O3) 3t9413¡.
t, PHYS¡CAL DATA (l¡dicefc 960€d¡ge of nlsi¡t tb$ rilt ¡oo tùroqù tb foü,orilg GRADATiON OF
II4AÎERIAL:
gnd a''^q c,å 12" 1009á,4' 9{it6' l' 74?\ll4'509ô l/40' Sllr\lnffi' .5%')
Z. DESeRIPTICII{:eoh X.Êstt/lárä- fic:O&l-V
Uqurd- Solidx, SH¡q Psr*øPu¡:
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4. GENERALCITARASIERBTTS(9ÚOFEACIÐ
Sloil 90tó ildnú P!ùb ¡0tó ffiþ: Pige Scrb: TdLÐ: Pro€s IYrrG- eææ:
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(U* Std hæm lùltrùod åSfM D69t) Opd¡rualfo¿¡n¡c Cæs 3G40 tt
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ó oF MATERJAI (Plcsec Btlach s dcscrigtion of the malsial wlth regecr to rts phyncal ccmpuotcocs' This <icscriFim can be anached sÊp€sËc¡y or includ *!rh f¡Ê "ttú;Êtt tc ltcm O. lj
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ND-Aûslyæ no¡ del€dÉd to-
Is the radioctivlty c¡o¡aiæd i¡ &c wåfê p¡rerial Lqç'Levcl Radknctirc lryr$e ð dfu in th Low-¡.crlJ Rad¡oætivc VY¡ge Polþ .ÂrnrndrncnÈ.Art of l9t5 q i¡ DOE Ordã 5tZ0.2A CbåÉÊr III? (PhåseCirclc) If yc4 chæk 'aLA.UrUæts¡ lhc3 ofP38e ILTCENSEDrrEtería¡ ligcd or indudÊd ou art act¡vs Nrrkr RcgulatoryCcæsissiooCircle)
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l. DESCRIPTIONAIIDHISTTORYOFMATERIAL S€eÂsæh4
Pleasc at¡ch a dr:ciptim of the r¡¡si¡! to rhis ¡rcÉilc. lncludc rhc folowirg as ryplicotdø The proccss þ *ùich fu
roatqi9'l wac 8ffidlcd. Awil¡bb FoE sc k¡rorvlcdgÊ of tbc ¡ua¡si¡l- Thc hsb of à¡za¡¿ot¡s ¡n¡c¡i¡¡ or 11"æl€
døsr¡inaiøs A lict of ttc clH¡iceb" re¿crù¡ls ø n/ìúe r¡s€d in or ecrnnirgled eiù tbc rnflsb& a [r* åf arry aoc au
applicable ËPA træsùr¡¡ rvasl€ N¡¡f¡þÈå q¡îã18 €F forrnc, æd a lH of a¡¡y æd d¡ ¿Ðtictb|t ¡std,ö46s¡ pmhibirioa
ar h¿zardou*r+oslc clrolrsior4 g¡sr¡¿q¡gr eran¡*ions, e{foetive dara¡ vriånccs ur dclislogr. .AtÎgch üÊ fiogl fcú€4t of
aplicaHc 8lttyticel nilt8 of tbe r¡a¡crid"s h¡za¡dor¡s-nßc eharætsislier ø cø*it¡øs. A¡lreù ery applrcablc
êr¡dyticål ræ¡¡lÞ ifl¡o¡"iag ¡bÊ eoruPw¡tim of tbe ¡na¡siat. Aqach -ay proûrt i¡fersntion crltl¿súl s.fqy Dat¡ Stìæ6
assoc¡st€d wi¡h ¡h øøint If a øccgory ur tl¡þ ild¡Ei.¡ Èo6lc aÆú€Íd doÊs lst â¡p}y. dÉlcr¡bc wtry it doer noc
fi{ ecgtraingl€4 &ie4 s cnbcrwue procwed a auy tine
s r@rcd frsr th læatios 6 siæ !#ke it *æ crigindty
Fi¡l a rs¡ó- of) fu üæ*" dg¡e€! aøillor dispoeetr of
eny appiicaHe ù@sml sdr@
2 LIST .{LL ¡G{O\ÀIN A}{D POSStslS C|IEMIÇAL COVÍPONENTS OR i{A7-+\RDQUS wA.sT!
CifARACTER,IST]CS
(Y) (À'l (Ð GÐ (Ð G.{)a. Lisled Hw _ _X_ b. 'Ðeriræd-Frefß- i{IY _ _X_ c. Toxis _ _X_d. Cyrudã _ _X: e. Suifd:s _:X: f 9ioÉ!r _ _X_S, Pcstis¡&s _ _X_ b. Hsùicidcs _ J_ À. PCB6 _ _X_j. Erçlæiver _ _X: !r. P¡ræpùcnes _ _X: 1. Solv'srr _- _X_m. Orga¡iæ : _X: ¡1. Pbaplbs
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_X_ Ð. Infcst¡rnr: _X_p- Ignit¡þlc : _X_ q. Ccrocivc _-=:- _X: r" Ræti"ve : _X_s, Antinrøy _ _X_ I Ecryllirm _ _X_ r¡ Coçpø _X_ _y. Nicksl _ _X_ w, Tùaillirs : :X: ;L Yæadim
-=
_X_y. Alcoùolt : _X: z. A¡":Ec _X_: es 8s¡æ _X: :bb. Cadah¡no :X* : cc Cùroirru _X_ _ dd" ¡.€d _X_ _ee. lVscury *X: : ff. gclahm : _X_ ¡* Silvc¡ : _i(_irl¡. Bc¡¡ze¡æ : _X_ ii. ìäîrãt : _X_ i¡, Niùitcrk. Flü6idÊ ::X_ l¡. Oi¡ : _X_ s!ú.F¡cins Chciain¡ Aßa¡s X
Æaser,'- =;c- -ãsTcr-rr
pp. Othcr t$àsu/u 6 PosiUe fúaþi¡Lg
Geuc¡¡& ø Ccr¡bactcr lnitids:
3. Aì{ALYTICAI RESULTS FOR. TOXICITY CHARACTERETICS" (PLæ eæibc ææhr 6 tbc trknk çøpøvidcd- Aüact addiüGd úÉstr if E Eó!4 indic{€ reúgÊ or rrrs{üc rcs¡¡Ð}
Mctats(circlcæ): Tûl(rqg/tg) or TeLP(Fgt) Or€rric€(cirttcæÌ Td¡t(n€ftÐ * @
xtÞ
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Lcâd
Etrh¡rr
3.62 lrfcrcr¡n 0.00æ6
4.ó9 Tine 0.7 ¡¡Ð
¡fD - An¡¡)4êl¡ot &c¡icd
4. AI{ALYTICAL RESULTS FOR REQLIIRED P^RåMEÍERS: (Plcrsc Brssibc rc¡¡}ts m te Hof +æ
Drovtd€d. Au&l däcd tH ifælÌ
Sûil pH !Å=ljtl Fdú F¡tE l'{e Frce tiquit PASS_ a)Ëúdc æ l{orMÃtiqiôT€r(h/Fril) Rc¡c¿scd 44s. tGNrrAffUTV (¿f{l cF'R 2ól¿lf¡lEHr})
FHPdst >¡,Í0 t t Lûeæ¡nen¡ stüt¡/?
$¡¡6dc lË Not
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E.
ó, CfíefiCA¡. COÞfPЀITION (List ail knovm cÀÊorca¡ coßpor¡€r¡ts asd c¡rc¡€ ttr apgltcsÞlc c.cscentæion
dir¡¡ecLsicrf¡s" Usc aracl¡rna¿s to cornplla if ucscry )
ChffiiçåI Corupooørl C,cncæbdiq¡ ChÉs¡ir.i¡ Cæropæs¡t Ccacæ!'ûios
Sec ad¡ctcrl data shces _ e/orøgllg
F¡a¡otErcdûgüde GfOe) 38 @g/}g
eoryædo ($r¡ €f ibË ¡b of HOerþ bctieræd to
be gÞtier¡ cr¡rcris¡crfcrenÊe siæamc xere
dinfuplecao
RS(NJßEE CIïEM¡CAL L-ABOR.A'I0RY A¡itALYSlS. Gto¡aor m¡t stri! ttdg af 6lys c'f æglcr of tbe
rc¡trr¡a¡. Rcs¡¡& rc rcquired Ëoo e qù¡.ËÍicd lrboratory for th folhb¡ sr¡}tt¡e.¡ Fdlrt unlcs norpptkabiliÇ of(h ü¡i),s.s fq ¡lp otcri¡l eq¡ bc sdcd eÉ jur¡f¡cd io #rh.d rt¡tæt* AtlrÉù dl údydcd rcrrb d A¡â¡açdñ¡E sàtitru (CAUTIGI: PRIOR TO ARRA¡.¡G¡¡íG FOR L-ASORcTORY A¡¡AI-16tr¡" CHECK wIffi AtC AND
LAËOn ATORY REOARDTNG UTAII I-AHORAIORY CERTIFICATIONS. )
FOR AIl- IvIATERLAL TìIPES: CHEMreAL AÌ¡IAIWIS: Soit p¡{ (90{5} hiat Filrr Uqrür T€r (S951 Radivify
(cland. and s¡¡ßd.).
r. MTNTMUM ADDITIOìúqL AN,rLyTIeAt REQUIRED FOe
a. NqI-RCRA lVasc (l,Io il{ird TVadc ag,, IJ.RW, NORM} TCIP iæloÄry th 32 ae¡nic¡, E Esüb! ed
crppcf (Cu) üd zinc(ZBI
2. REQUIRED RADIOLOGICAL ANAIYSES, Pl€rsr obain qúck¡r l@C.! to sdqr¡dc¡y c4,rãmiæ r ragc ard
çci¡ätat ¡rqagc af ætivrty in tlæ macrirt t{¡vc ¡ s6cia nuobcrof rnflcr nÅyzÁ !y ¡s¡n¡ 3e.ft1 æalysis
fø all n¡u¡nl isobpes s¡ch thn ttçy srypor¡ lbr raogp ad *cightcd ¡r€ngs infrautiß fcr tbc q¡ts¡l that vi[ bc
recordcd in itcs D l. lf Urani¡¡r¡, ïTrcrir¡¡!, or stþ ¡r@-Éarrn¡ cßi¡u¡U ¡rrlida sE Ftsaas in tbÊ Ed6¡!¡, l¡arc a¡
l€ast (l) srnplc e?al¡¡ald ry r¿diaàcrsis¡ry !o ddønil: tlp cæatr¡i¡n cf ùrrG addi¡iøal cslsi¡a¡ß in úE
matcrial,
Gcrcratc cr Cø¡üasts ûritiats
-l=\- - "-:¿UU Lt' ':
3 PRE-SIæìi€)iT S"C-UPLES OF ytATER.iAL TO tIiC
O¡ce Fsm¡ssioc hås bÉea obÞrr¡d frq¡ IUC, asd uolcss eß@ab¡Ity srnples bave gænously bcm rcnt to ILC,
plcasc md 5 rcçrcsortative nuplcr of thc r!¿dcrial þ ruC, A cosplcted chain of custody fgm eol¡s¡ lr urludcd *rth
ec srpha oostaiûrl- Tlrcsc sarghc wtlt bÊ rpcd to cr¡blirh thc ¡u¡rri¡l's inßrlni¡rg Siyaot s€¡sptec€
ptr@ßlcr tolgæcs aod nay be ıtå¡fæd fø addiuco¡i par¿@¡clÆ. Sod abom Þo poucds (æ3 bls) fs each
sauplG in an an{igin ciean giass ccntrim yic UaiËd Fúccl Pd (LÍPS) s Fedcnl Expesr to:
iatrr¡¡¿¡is!¡¡ Uraaiun (u*SA) Ccçoøer¡ ¡qßx Sorpk Cdo¡, cli25 3. Higlwry l9l , P.O. Bq,r 809, Biqditag" Lff
t45l ¡Pæ {435) óæ.2Z2t
4. ¡IEOR"âTORY CERTIFICATION nfFORMAnçÈf. .91æ ieùcals brlsw ulhjcb of tlæ follouæg caugaries
agpti{Eto þur bbsälny d¡ûa
a" êål rarfiolotic fu¡ us:d to s¡pporl lb drâ ¡ß iun e, !, mr¡c br Éqs a ealifd laùo*ary,
" Tb hbs¡ry blÀ s sr¡ûcd clmied ø mdbþicaÀUuhnpuætofF¡.âljû¡üsfs git¡ts
_GENERATOR'S STATE CERTIFICATI(7}í. Tb hbøatay hlå a curtrcs EüÊEúkm far thc açplicable
cbÉaicd ps@€{sl ôm thc gædtr"s S¡ltc i¡æfr ¡¡ ¡¡cå o6ci¿l ceniGc¡iæ æ girre, c
_GC¡{ERA'TOR'S STATE I^ABORATORY REQlnREME}ffS Th tåralry Elr ¡b rquir@ of tttc
gæúor'rStatr tr cot¡¡ize¡ ¡¡py fqfuic¡l labr¡sicr,æ
If uig r m.Ul¡h csti6cd hô6nry, bic8y d:sib: tb gffn¡ù sfß's rcguir@ fq cffi rn¡lttrcal
laôø¡rþr to dcd fu daqr¡bliø thc lb hhay rd¡¡dc ærcçrwaa ryirity in ss¡ of
u,hÊtk fu ltqrúffi sc 9m@ts TcEiñc !¡.Ôod ææi6a, q inrob: CLP or ù QA dar pta6r*
Notß: ltùÉr Fæcss c fojæ Uy¡¡¿gc of thL ßrc b diÉ{ rötlqnl a¡tyt¡c¡¡ rcu¡k n¡y not ÞGclry !o cmphc sdioû B, D¿ D.5. s D.6. of ttir fm.
b. For ulytical e,!rk dmc by UhÞcstif¡cd l¡Uatoricf glÊæÊ providc E cog of tbe lùaq'r cr¡lrern
certific*ion !:tts b c! przæcr E lyzld ¡¡d æch ned rrat fc ui¡s nçiircúþ thb frr.
c. Fø a¡¡lytic¡l urút ddc Þy l¡bs*oric¡ nôi€À ar nd Utrb.Csti6cd¡ Éørc Fovidc th followiog infçæa¡iø:
Stt 6gthsAtt3cyCm¡aPqs GsddsSaæ Tckphæñnb
IlD(-lfr[Æ¡R$m L¡bmtory'¡ S¡æ ldcfù*Ìftsbs
F. CERTIFICATIOIìÍ
GENER/I'TOÎ'S CERTIFICAflOI{: ¡ €üry ü¿ rqlc. rcg¡cdiæ dtþ nncll dcsiDd io lË. Fl6þ nzr or
S¡ll bc sùtdd ¡iç :ÈÞ. d lP¿l'.qferrd qlin¡ tr* I d¡ cclify tf sEG qcËry thc æpc-¡¡æ
s.ngkl tr¡rÊ c d ù. f¡stídd ¡r llrc d o çrliûd lrùqtsb f¡r thc atyt¡ot rcrltr rlDfid bcir. I aflo
cãti$ ltf ù¡ffin¡sriËcóøtû fuB i¡ enflcg ra adaørad bmrødy ¡ryDdd d dæqøncd
þ aoy lrk*y É3 r æçiÉ bt nrc. I cqtfy û.¡ tb rrrllr of ay rlll Hry hæ b€ ¡ffi to lÍJC. I
ecrüry ûr tb r¡id hibd b ùi¡ Fo6h !É tcËn fuüy chrraird o¿ tùf hødø. €dfi[ú tiild b l0
CFt 40 epdtA Gü¡is¡ ¡3 rtÈ¡ ¡r +É¡¡llc to tli¡ døil hræ b iffi s¡ ûb ftrn" t ñsb €.ni$d rffi þ nrc úa lb rrirl rqaød o thi¡ fm ir d ¡ ¡zrfu. *¡3 s ¿.frd by {0 CFR 2út mdb û¡r
û¡¡ Es¡.¡ it 4 tm RßRA rr¡uhU ú ¡10 CFR 2ó I .a(ela)
Ibe kc'r rryitilitir rith æ?rg te tu u¡úrid kiùcd ¡n ¡bir fún ¡r fa púNiry" fmÚrenÈen lldbgd *ffiliA ¿æ¡¡im¡¡ r¡ rdl a¡ gaanl eci¡h Th Cmæs': rcrymlilitb rit æ¡a r üb ssirl rc fqtb dry-Þdry sFrüút (b md¡oe aiô aær¡ di¡estkn ¡rr¡ by tb Cæaor.s Ft db tffid sts:l3bt
rclDmdhllyl bßftq hr d linild o tùr ñlbrrng ræt¡üic¡; ürt tuã.rid¡oå Dttir d H¡nA
srûgb¡; gnitdrg, fcfit Þtrç, reúd$ d cctil3cy pln¡ûaf, ¡t¡ccC¡gly, tb Cmæ brr fu ¡¡q¡¡iric
UsçtcCf: d .rrùaüy te r¡l Ëú¡ ertitlc¡h¡ o Ëlf of Íd( d l arn tu tu Cffitr" æ båaú of ?bctu. ry d¡¡ú¡t ü €stiffeai4 tûc C¡ræur b ri¡lb¡ c il¡ o*¡r bårlf d m trtf dtt¡e Cæs.
Generalor s or prrraeror' s siglarureÐaæj/t¿/o--
(Sig¡ for úæ above ceruñca¡ioss).
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