DRC-2018-009371 - 0901a068808cfbce

DRC-2018-009371 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
September 25, 2018
David C. Frydenlund
Chief Financial Officer, General Counsel, Corporate Secretary Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228

RE: Licensee-to-Licensee Transfer of the Honeywell Yellowcake Drum Shreds White Mesa Uranium Mill Radioactive Material License Number UT 1900479
Dear Mr. Frydenlund:
On September 11, 2018, Energy Fuel Resources (USA) Inc. (EFRI) requested approval to process additional yellowcake drum shreds (yellowcake material) from Honeywell Inc.’s Metropolis, Illinois works (Honeywell).

History of the Request In July 2013, EFRI requested approval to take drums of hardened yellowcake that was affixed to metal drum shards in order to recover, concentrate and purify the yellowcake putting the yellowcake back into
usable form for Honeywell. On September 11, 2013, the former Division of Radiation Control (DRC)
concurred that EFRI could accept and concentrate and purify the yellowcake material with a license to license transfer of radioactive material in accordance with R313-19-41(2)(d) of the Utah Administrative Code. This approval was based on the following provisions:
• The concurrence for the transfer of materials was exclusively for the Honeywell yellowcake material described in the July 26,2013 submittal and did not apply to other future projects;
• The concurrence was limited to the 4,850 drums, which contained approximately 200,000 pounds of yellowcake material identified in the August 6, 2013, letter. Any additional drums
would require Director approval; and
(Over)

• The yellowcake produced from this project would count toward the yellowcake production limits in EFRI’s RML License, Condition 10.1.A. EFRI explained in its September 11, 2018 letter that it had recovered 180,000 pounds of yellowcake of
the original 200,000 pounds approved in 2013. Current Request EFRI is requesting approval to recover, concentrate and purify an additional 50,000 pounds of the
yellowcake material. As before, this will put the yellowcake back into a usable form for Honeywell. According to this new request, this yellowcake material is the same material that was approved in 2013. Based on the information provided from both the 2013 and 2018 requests and observations made by Division staff of this material being processed, the request for an additional 50,000 pounds of yellowcake material above the original 200,000 pounds that was approved in 2013 is approved with the
following conditions:
• The basis for this approval is the same as the basis for approval of the Honeywell yellowcake material described in the July 26, 2013 and August 6, 2013 letters;
• EFRI will be required to keep records of the drums received for Division review. Any additional yellowcake material will require Director approval; and
• The yellowcake produced from this project counts towards the yellowcake production limits in EFRI’s RML License, Condition 10.1.A.
If you have any questions, please call Phil Goble or Ryan Johnson at [phone]. Sincerely,

Scott T. Anderson, Director Division of Waste Management and Radiation Control

STA/RMJ/ka c: Logan Shumway, Manger, White Mesa Uranium Mill Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer