DRC-2018-009457 - 0901a068808d489c

September 1 I , 2018
SENT VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www .energyfuels.com
Div of Waste Management
and Radiation Control
SEP i 7 2ma
D RC-20 l 5 -004)457
Re: Honeywell Drum Shreds Licensee-to-Licensee Transfer Processing Totals, White Mesa
Uranium Mill
Dear Mr. Anderson:
This Jetter is a follow-up to a telephone discussion between the Division of Waste Management and
Radiation Control ("DWMRC") and Energy Fuels Resources (USA) Inc. ("EFRI") on May 15, 2018,
regarding EFRI' s processing totals from concentration and purification at the White Mesa Mill (the "Mill")
of yellowcake adhered to drum shreds (the "Honeywell Yellowcake") from Honeywell Inc.'s
("Honeywell's") Metropolis, Illinois works.
On July 26, 2013, EFRI submitted a letter to DWMRC requesting approval to accept the Honeywell
Yellowcake for the purpose of concentration and purification and to return the yellowcake to a useable
form. EFRI proposed using a specific licensee-to-licensee transfer of licensed material, which would not
require an amendment to EFRI's Radioactive Materials License ("RML"). The Utah Radiation Control
Rules allow for transfer of licensed materials between licensees as stated in R3 l 3-l 9-41 (2)( d). DWMRC
evaluated the information provided by EFRI regarding this request and agreed that the Honeywell
Yellowcake could be transferred to EFRI under the provisions of R313-l 9-41 (2)( d), and that no
amendment was necessary to EFRI's license with respect to the Honeywell Yellowcake. The DWMRC
concurrence was received by letter dated September 11, 2013.
In its July 26, 2013 letter, EFRI estimated that the Honeywell Yellowcake was contained in approximately
4,800 drums, and that the drums contained approximately 200,000 pounds of Honeywell Yellowcake.
DWMRC' s September 11, 2013 letter listed several conditions relating to the receipt of the Honeywell
Yellowcake. One of the conditions was that 4,850 drums of material could be received. During the receipt
and processing campaign, EFRI noted that the amount of material in each drum was highly variable and
that many of the drums were not full. As a result, EFRI began using pounds of Honeywell Yellowcake
recovered as the measurement point for the project, because pounds recovered provided a more meaningful
measurement.
As of May 15, 2018, EFRI had accepted 5,130 drums and recovered 180,000 pounds of Honeywell
Yellowcake. While the number of drums exceeded the limit in the DWMRC letter, EFRI was within the
200,000 total pounds contemplated by its July 2013 letter. As stated above, the cause for the variance on
Yours very, t ly,
Letter to Scott Anderson
September 11, 2018
Page 2 of 2
the number of drums has been due to the variable amounts of Honeywell Yellowcake and shreds in each
drum. Overall, at the time of our call, EFRI had concentrated and purified less than the 200,000 pounds
anticipated or requested. Since May 15, 2018, the Mill has not received any additional Honeywell
Yellowcake. In no circumstance would the amount of Honeywell Yellowcake received cause exceedances
of production limits in RML Condition 10.1.A.
Honeywell still has some additional Honeywell Yellowcake from this project, which is currently estimated
to be approximately 50,000 additional pounds (above the original 200,000 pounds requested). EFRI hereby
requests DWMRC' s concurrence for the Mill to take this additional amount of Honeywell Yellowcake.
EFRI is also requesting that pounds recovered become the measurement point at this time, rather than
drums, as this provides a more accurate representation of the quantity of the Honeywell Yellowcake
received and processed.
If you should have any questions regarding this letter please contact me.
E UEL RESOURCES (USA) INC.
David C. Frydenlund
Chief Financial Officer, General Counsel, Corporate Secretary
cc: Scott Bakken
Mark Chalmers
Paul Goranson
Logan Shumway
Kathy Weinel
A f
2