DRC-2018-009458 - 0901a068808d4b1c

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
September 11, 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
Div of Waste Management
and Radiation Control
SEP 1 7 2018
1) RC- 201/3 -009458
Re: Honeywell (formerly Allied Signal) KOH Alternate Feed receipts, White Mesa Uranium
Mill
Dear Mr. Anderson:
This letter is a follow-up to a telephone discussion between Energy Fuels Resources (USA) Inc. ("EFRI")
and the Division of Waste Management and Radiation Control ("DWMRC") on May 15, 2018, regarding
receipts of KOH Alternate Feed Materials ("KOH AF") from Honeywell (formerly Allied Signal)
authorized by an amendment to the White Mesa Mill's (the "Mill's") Nuclear Regulatory Commission
("NRC") Source Material License (the "Source Material License"), which is now included in Condition
10.7 of the Mill's DWMRC Radioactive Materials License ("RML") Amendment 8, dated February 16,
2018.
EFRI received an amendment to the Mill' s Source Material License and associated Technical Evaluation
Report ("TER") from the NRC on November 26, 1996. A copy of the TER is attached to this letter. The
NRC TER considered the amendment request acceptable and approved the receipt of "approximately 2,475
tons of material...". Despite the TER referring to an approximate quantity of KOH AF, EFRI does not
believe that either the amended Source Material License or Condition 10.7 of the RML sets a limit on the
amount of KOH AF that may be received by the Mill, for the reasons discussed below.
First, EFRI (Energy Fuels Nuclear Inc. rEFN"] at the time of the amendment request) did not specify a
total tonnage for the material in the amendment request. Specifically, the amendment request states "This
Material is currently contained in approximately 11,000 drums. Approximately 110 loads, or 4,000 to 5,000
of 55-gallon drums (900 tons), of dry material will be shipped in drums, and approximately 98 loads will
be shipped in slurry form (in tanker trucks) to the Mill." A copy of the initial amendment request is attached
to this letter. The approximate total tonnage was calculated by NRC and stated in the TER, but the
amendment to the Source Material License did not limit the tonnage or amount of KOH material that could
be received by the Mill. Because the calculations were an estimation, the amount in the TER was listed as
an "approximate" value.
Further, the KOH AF is from an ongoing continuous stream, because it is a by-product of Honeywell's
routine conversion process, and is not part of a finite project. EFN submitted the amendment request for
the initial KOH AF receipts, but anticipated that it could receive supplemental additional materials in the
Letter to Scott Anderson
September 11, 2018
Page 2 of 2
future. Although EFRI believes it is likely NRC understood that the KOH AF was from an ongoing process
stream at the Honeywell facility, the fact that the KOH AF receipts at the Mill could also be ongoing was
not specifically stated in the amendment request.
As of December 31, 2017, EFRI had received 1,955 dry tons of KOH AF. To date in 2018, the Mill had
received 248 wet tons of KOH AF as of May 15, 2018, and an additional 141.3 wet tons since May 15,
2018 (dry tonnage will be calculated at the time of processing). Although EFRI has not exceeded the
approximate amount noted by NRC in the 1996 TER, it may do so in the near future. Out of an abundance
of caution, EFRI is providing this notice and request to DWRMC at this time.
EFRI hereby requests DWMRC' s concurrence/confirmation that the quantity of KOH AF that may be
received by the Mill is not limited by the RML. In the alternative, if DWMRC believes the quantity of
KOH AF is limited by the RML, EFRI hereby requests a variance to the limit set by the RML, which would
allow the Mill to receive and process an additional 2,525 dry tons of KOH AF over and above the
approximate 2,475 tons of KOH AF referred to in the TER, for a total of approximately 5,000 dry tons.
The receipt and processing of this additional KOH AF will not cause the Mill to exceed its production limits
in RML Condition 10.1.A.
If you should have any questions regarding this letter please contact me.
Yours very tyuly,
ENERGY FUELS RESOURCES (USA) INC.
David C. Frydenlund
Chief Financial Officer, General Counsel, Corporate Secretary
cc: Scott Bakken
Mark Chalmers
Paul Goranson
Logan Shumway
Kathy Weinel
Request to Amend
Source Material License SUA-1358
White Mesa Mill
Docket No. 40-8681
September 20, 1996
Prepared by:
Energy Fuels Nuclear, Inc.
1515 Arapahoe Street, Suite 900
Denver, CO 80202
Contact: Michelle R. Rehmann, Environmental Manager
Phone: [phone]
Submitted to:
United States Nuclear Regulatory Commission
2 White Flint North, Mail Stop T-7J9
11545 Rockville Pike
Rockville, MD 20852
DMC0000399
Amendment Request
License SUA-1358
September 20, 1996
Page 1
INTRODUCTION
Energy Fuels Nuclear, Inc. ("EFN") operates an NRC-licensed uranium mill located
approximately six miles south of Blanding, Utah. The mill processes natural (native, raw)
uranium ores and feed materials other than natural ores. These alternate feed materials are
generally processing products from other extraction procedures, which EFN will process primarily
for the source material content. All waste associated with this processing is, therefore, 11e.(2)
byproduct material; or, as stated in the alternate feed analysis noticed in Federal Register Volume
57, No. 93:
"The fact that the term 'any ore' rather than 'unrefmed and unprocessed ore' is
used in the definition of 1 1 e.(2) byproduct material implies that a broader range
of feed materials could be processed in a mill, with the wastes still being
considered as 11 e.(2) byproduct material".
This application to amend NRC Source Material License SUA-1358 requests an amendment to
allow EFN to process a specific alternate feed primarily for its source material content, and to
dispose of the associated 11 e.(2) byproduct material.
1.0 MATERIAL COM:POSITION AND VOLUME
Allied Signal, Inc. of Metropolis, Illinois, ("Allied") will repackage (as necessary), prepare, and
load for shipping material described as uranium-bearing potassium diurinate (K2U207) in a
solution of potassium hydroxide/potassium fluoride ("KOH/KF") in water ("Material"). This
Material is currently contained in approximately 11,000 drums. Approximately 110 loads, or
4,000 to 5,000 of 55-gallon drums (900 tons), of dry material will be shipped in drums, and
approximately 98 loads will be shipped in slurry form (in tanker trucks) to the White Mesa Mill
("the Mill"). Specific gravity of the slurry is approximately 1.5 to 1.6. Approximately 5,000 cu.
ft. of compacted drums, resulting from the repackaging of the Material, having been washed,
pelletized, and wrapped, will also be sent to the Mill. It has been standard practice to dispose
of drums in which alternate feed material is contained as 11 e.(2) byproduct material as they are
emptied for processing of the Material; however, in this case, environmental and waste
minimization considerations demand that some of the Material be emptied from drums and
shipped in tankers as slurry. The drums, however, remain an element of this recycling process.
Further, as discussed below in subsection 1.3, these drums are considered to have become 11 e.(2)
byproduct when U308 (yellowcake) was placed in the drums for shipment to Allied.
DMC0000400
Amendment Request
License SUA-1358
September 20, 1996
Page 2
1.1 Radiochemical Analysis
Attachment 1 is an analytical report for uranium isotopes. Analysis by the on-site laboratory at
EFN White Mesa Mill indicates a uranium content of seven to ten percent. This high uranium
content justifies recycling this material to extract uranium.
1.2 Analysis for Hazardous Constituents
NRC guidance suggests that if a proposed feed material consists of hazardous waste, listed under
subpart D §§261.30-33 of 40 CFR (or comparable RCRA authorized State regulations), it would
be subject to EPA (or State) regulation under RCRA. To avoid the complexities of NRC/EPA
dual regulation, such feed material may not be approved for processing at a licensed mill. If the
licensee can show that the proposed feed material does not consist of a listed hamdous waste,
this issue is resolved. NRC guidance further states that feed material exhibiting only a
characteristic of hazardous waste (ignitable, corrosive, reactive, toxic) would not be regulated as
hazardous waste and could therefore be approved for recycling and extraction of source material.
Attachment 2 lists analytical results based on EPA method 8260 analysis for organics. No
parameters from the method 8260 list were detected.
1.3 Regulatory Considerations
Waste Disnosal
The Atomic Energy Act of 1954, 42 U.S.C. 2014(e)(2), defines "byproduct material" as (1) any
radioactive material (except special nuclear material) yielded in or made radioactive by exposure
to the process of producing or utilizing special nuclear material; and (2) the tailings or wastes
produced by the extraction or concentration of uranium or thorium from any ore processed
primarily for its source material content. For purposes of uranium processing, byproduct material
means the tailings or wastes produced by the extraction or concentration of uranium or thorium
from any ore processed primarily for its source material content (10 CFR 20).
Under License Condition 55, License SUA-1358 authorizes EFN to accept for disposal up to
5,000 cubic yards of byproduct material from any single source, for disposal in Cell No. 3.
Additionally, as alternate feed from Allied is currently processed by EFN under License
Condition 56, drums in which the feed material is shipped are disposed of in tailings Cell No.
2. The drums containing the material are disposed of as byproduct material.
DMC0000401
Amendment Request
License SUA-1358
September 20, 1996
Page 3
According to NRC guidance, for the tailings and wastes from the proposed processing to qualify
as 11 e.(2) byproduct material, the feed material must qualify as "ore." NRC has stated alternate
feed material is determined to be ore, by following defmition:
"Ore is a natural or native matter that may be mined and treated for the extraction of any of its
constituents or any other matter from which source material is extracted in a licensed uranium
or thorium mill". Processing of this ore then, results in byproduct material.
The drums sent to Allied, which contained yellowcake, result from the production of source
material, and as such, are byproduct material. The drums are also used in the recycling process
for containing and/or shipping alternate feed materials, which are processed for extraction of
source material. As part of the process, the drums would also be disposed of as 1 le.(2)
byproduct material.
With regard to this request to amend, due to aging of some drums and moisture content of the
material, a certain percentage of the drums are not considered sufficiently competent to contain
the Material for shipment. Rather than produce additional waste by overpacking these drums
prior to shipment, Allied will empty the contents of these drums into tanker trucks for shipment.
As the drums are still byproduct material, they will be washed, compacted, and shipped along
with the Material, as part of the recycling process, for disposition at the Mill. Attachment 3 is
a statement from Allied confirming that the proposed approach is reasonable in terms of being
a cost-effective, waste-minimizing, and environmentally-protective option.
In Section 4.0, below, EFN certifies that the feed material is to be processed primarily for the
recovery of uranium and for no other primary purpose. EFN justifies the certifications on the
basis of the high uranium content of the feed material.
Classification as Alternate Feed
The Material, as alternate feed to a licensed uranium mill, is not subject to regulation as a
hazardous waste as defmed in the Resource Conservation and Recovery Act, as amended, 42
U.S.C. §6901-6991 and its implementing regulations, or comparable Utah and Illinois laws or
regulations governing the regulation of hazardous wastes. The Material has not been transported
from any site or facility which (1) is or has been the subject of response costs or demands for
payment of response costs as defined in the Comprehensive Environmental responses,
Compensation, and Liability Act, as amended, 42 U.S.C. §9601-9657 ("CERCLA"), or (2) is
listed, or is proposed to be listed, on the National Priority List as defmed in CERCLA.
DMC0000402
Amendment Request
License SUA-1358
September 20, 1996
Page 4
2.0 PROCESS
The slurry material will be off-loaded into No. 2 Pulp Storage Tank. The drummed material will
either be dumped into a small batch tank and pumped into No. 2 Pulp Storage Tank (as the
calcium fluoride was processed) or will be processed through the ore hopper and SAG mill before
being pumped to No. 2 Pulp Storage.
pH adjustment will begin in Pulp Storage Tank No. 2 with the addition of sulfuric acid. After
the initial pH adjustment, the slurry will be pumped to the leach circuit, where it will be mixed
with tailings solution, for the final pH adjustment. The solution will then be transferred to the
CCD circuit for washing.
Depending on the grade of the solution, it will either be pumped into a holding tank (if the grade
is high enough), and then fed to the precipitation and drying circuit. If, after the CCD circuit the
solution grade is low, the remainder of the recovery process will be unchanged from the current
mill process.
DMC0000403
Amendment Request
License SUA-1358
September 20, 1996
Page 5
3.0 SAFETY MEASURES
This section describes how the Material will be introduced into the mill circuit, and the safety
measures to be employed.
The Material received in bulk transport will be a slurry which is pumped from the tanker truck
directly into a receiver mix transfer tank. The density of the pulp will be adjusted, then the
slurry will be introduced into the leach circuit as is typical with uranium ore. Material
transported in drums will be either dumped into the mix transfer tank, or processed through the
grizzly into the SAG mill, then pumped to the leach circuit. In either case, there are no process
changes to the mill circuit and the extraction process sequence is identical to processing
conventional uranium ore.
Employee exposure potential during initial material handling operations is expected to be no more
significant than what is normally encountered during conventional milling operations. Employees
will be provided with personal protective equipment including full-face respiratory protective
devices. Airborne particulate samples will be collected and analyzed for gross alpha
concentrations, as well as potassium hydroxide, potassium fluoride ("KOH/KF") dust
concentrations. If Threshold Limiting Values (TLV's) for KOH/KF dust concentrations of 2
mg/m3 are exceeded, or if uranium airborne concentrations exceed 25 percent of DAC, fiill-face
respiratory protection will be implemented during the entire sequence of material dumping
operations. Spills and splashed material that may be encountered during this initial material
processing shall be wetted and collected during routine work activity.
Sample material of the KOH/KF solids indicates it is a neutral solid, with a measured pH of 6.9;
nevertheless, coveralls and rubber gloves will be worn at all times when handling this material.
3.1 Contml of Airborne Contamination
EFN does not anticipate unusual or extraordinary airbome contamination dispersion when
processing this Material. The contamination potential is expected to be less than what is normally
encountered when processing conventional uranium ore. The Material will be contained in 55-
gallon drums or received in bulk via tanker truck.
If the Material is received in bulk by tanker truck, it will be slurried and pumped directly into
a transfer tank and immediately introduced into the leach circuit. The successive extraction
process circuitry from CCD through solvent extraction and into precipitation are all liquid
processes, and the potential for airborne contamination dispersion is minimal.
DMC0000404
Amendment Request
License SUA-1358
September 20, 1996
Page 6
If the Material is received in 55-gallon drums, each drum will be dumped onto the ore loading
belt and processed through the SAG mill and introduced into the leach circuit.
Uranium extraction proceeds through the mill circuit as if the process Material were uranium ore.
As the Material is dumped onto the ore transfer belt, water is sprayed into the grizzly enclosure,
which minimizes dust dispersion. As the Material is transferred through the ore transfer tunnel
into the SAG mill, a water spray system along the length of the transfer belt is activated. If it
becomes more practicable to dump individual 55-gallon drums into the mix transfer tank as in
bulk processing, a water spray system on top of the mix tank will be activated. The Material is
a moist cake as received (moisture content > 5 percent). Nevertheless, water spray provisions
are provided when handling individual drums or bulk material processing.
The efficiency of airborne contamination control measures during the Material handling
operations will be assessed in the immediate vicinity of the mix tank and next to the grizzly
enclosure. Airborne particulate samples and breathing zone samples will be collected in those
areas during initial material processing activities and analyzed for gross alpha, as well as for
KOH/KF dust concentrations. The results will establish health and safety guidelines which will
be implemented throughout the material processing operations.
Personal protective equipment, including respiratory protection, will be provided to those
individuals engaged in material processing. Additional environmental air sample adequate
contamination control measures are effective.
Based upon previous experience, it is anticipated that adequate engineering control measures and
established personal protective equipment use, which have been and will be implemented during
material handling and processing operations, will maximize the protection of individual workers
and protect the environment.
DMC0000405
Amendment Request
License SUA-1358
September 20, 1996
Page 7
4.0 CERTIFICATION
Laboratory analysis indicates the Material contains approximately seven to ten percent uranium.
Processing costs to recover the uranium content from the Material are minimal, and the
processing of this material will be profitable to EFN. Following is the Certification that the
material is being processed primarily for recovery of uranium.
DMC0000406
Certification of Energy Fuels Nuclear, Inc.
(the "Licensee")
I, Harold R. Roberts the undersigned, for and on behalf of the Licensee,
do hereby certify as follows:
1. The Licensee is a Party Contract with Allied Signal ("Allied")/Converdyn, under which
the Licensee will acquire certain material, in the form of potassium diurinate in a solution of
potassium hydroxide/potassium fluoride ("KOH/KF"), to process at the White Mesa Uranium Mill
for the recovery of uranium concentrates. The Licensee hereby certifies and affirms that the
KOH/KF Material is being processed primarily for the recovery of uranium and for no other
primary purpose.
2. The Licensee further certifies and affirms that the KOH/KF Material is not "waste"
as defined under the provisions of the Resource Conservation and Recovery Act because the
KOH/KF Material has not been discarded or abandoned, but rather is a commercial product for
which the Licensee is paying the supplier (Allied). The Licensee is obtaining the KOH/KF
Material as feedstock for the uranium recovery process being conducted at the White Mesa Mill.
20 199.4
Signature Date
Harold R. Roberts
President
Energy Fuels Nuclear, Inc.
DM C0000407
SENT BY:Xerox Te ecopier 7021 ; 9-20-96 ; 2:38PM ; _32.4 - 303 595 0930# 2
ATTACHMENT 1
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Ijiranium 238 Prec1iJon J.
.. • Date Radlometrk • Method Limit 1/nits Results
1
Analyzed 14-4t •••• • •• • -• ........ • •••••Vrt:44 . ....... ..... ..... . ' • •• . •••“- I Uranium 234 ,1,01)11a Spe J, 0.02 pc.V.8.. 4 .S,200 09-26-96 1.1mnium 234 Preelilonk _ 363
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Report Approved Liy!
huh 0643004v
COMPLETE ENVIRONMENTAL ANALYTICAL SERVICES
DMC0000408
•SENT BY:Xerox Telecopier 7021 ; 9-19-96 ; 2:31PM ; 303 595 0930# 4
ATTACHMENT 2
ENERGY LABORATORIES, INC.
P.O. BOX 8458 • CASPER, WY 81801 • PHONE [phone]
. 8398 SAL,T CREEK HIGHWAY • CASPER, WY 111001 • FAX [phone]
PA METHOD 8240 gr3 RESULTS -MATRIX SPIKg
ClIent: Energy Fuels Nuclear, Inc.
Sample Set COS-83804
Laboratory 10: 09645995 8
Mstrbc oil
20,000
Dots Somprot 09/12/9e
Dee Rewind 09/1 7/96
De% Extrude* 09/17/91
Dets Analyzed 09/17/9e
Dote Repodsd: 09/18/918
Pentellucrobonzene
Fluorobenzeno 1,4 • Difluorobenzone
Chlorobonzene d5
1,4 - Olchiorobenzene-d4
ICAL I CCAL
12823013
1829083 1617821
1190125
090090
SPIKED SAMPLE
1254275
1803800
1801888
1214800 711040
SPIKE DUPUCATE
ARRA
ACCEPTANCE
Nglai 00.4% 1200263 102% SO - 200 % (41,7% 14810011 102% 50 - 200 % 00.0% 1886857 102% 80 200 % 102% 1230139 104% 60 - 200 % 105% 080713 08.0% 50 .200 %
InnehletigletageecgaiKkM01411aL:111.141gREE.W.1%t1.21143.a.t:14:4REAIIMIlfWV SPIKED RAMPLR PERCENT &IKE DUPLICATE PERcENT ACCEPTANCE
ÇONCENTRATION RECOVERY, fargenal:EIN aggiain Nan DIbrornoiluOrOmithene 9.73 ' 9715 0.71 07,15 88-118% TolUene - de 10.2 102% 10.2 1025 88 • 110 % 4 • Brornofficrobenzerte 10.5 1055 9.81 94.15 88 - 115 % 1,2.. DichlOrobeneene-d4 i 9.95 NS% 10.1 1015 80 - 120 %
gpmfriwpoRitsubmirtIRMerg..4'fAftisoiEltiVItirrPi.Pgilgitigrint,.writry.t:„Li
Vinyl chloride 1,1 - OloKoroethene 2 • Butenime (MEN Chloroform 1,2 - Dichloraelhane Carbeh tebyohlorKe Sernene
RI6N8160161184 Tetriohloroelhens
Chforobtrons 1,4 - Dlohlorebenteris
5PIJID$AMPLI 0110; COPA. SPINS' maid P AccairrAkoa CONCINTIA110K ¡croft) t
10.2 NO 10.0 8.68 NO 10.0 0,81 ND 10.0 0.01 ND 10.0 0.011 NO 10,0 8,88 ND 10.0 0.07 ND 10.0
8,90 NO 10,0 a 77 NO 10.0
ND
IRCINT
SIBBISM 91.8% 102% 81.7% KIK 85,1% 90.1% OWN 89.1% 98.7% 89,0% 87.75
3Mi0 00 - 120 % 80- 120 % 00 - 120% 80 • 120 % 00 - 120 % 80 - 120 %
03- 120 % 10.120%
0)020% 80 -120 % _ EINMELLGAilltilthiaingiaa441_1_%0-41ilitiggiiit4-16-1WaileVakiv Mir-- - SPIKE OUP ORM Gum. SPIKE
Vinyl chloride 22MVALM "%l" 111111e1 illier 1.4% BM 1241111 10% 1,1- Oblittioeteni 10.1 ND 10.0 1015 1.85 10 % 2 • 6utenone (MIK) e.31 ND 10.0 83.15 3.05 10 % Chloroform 8.72 ND 10.0 87.25 1.0% 10 % 1,2 - Olohleroothanis LW ND 10.0 86.8% 0.4% 10 % Carbon terriohloride 9.10 NO 10.0 51.45 1.7% 10 % Benzene 9.19 ND 10,0 91.9% 1,45 10 % T 0.02 ND 10.0 90.25 0.4% 10 % TM.JLtIiÒiIP ROO NO 10.0 KM 2.0% 10% 0.00 ND 10,0 00.05 1,15 10 % 1,4*. 0.110 NO 10.0 111,05 1.55 105 ,.!.;: ilitititgaliantiiregiepecttraten•ittaiiitiliaMtWAA51004.1.441.40:4i-itai'lkni.
0 of 11 NW& Spike Oupkite rude Ira outside of wabiehad 40 UMW
Anu
DM C0000409 R"1""± '6° Page 5 (215
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SENT BY:Xerox Telecopier 7021 ; 9-19-96 ; 2:30PM ; ,--24 303 595 0930;# 3
ATTACHMENT 2
ENERGY LABORATORIES, INC.
P.O. SOX 3251 6 CASPER, WY MOS # PHONE [phone] am SALT CHM( HIGHWAY • 0A$PEN, Wv 884101 • FAX [phone]
Client:
Sample ID: Laboratory Itx Matte
Dilution Fecto
CAA. 0
gm METHOD 8260
Energy Fuels Nuclear, Inc. Date Sampled: 09/12/96
KOH - • Date Received: 09/17/90 c96-83604 Date Extracted: 00/17/06
Son • Date Analyzed: OW17/616
. 200 Data Reported: 09/10/06
CONCENTRATION LIMIT OF
TARGET COMPOUNDS DETECTION finaV . 73-714 Dlchlorodifluorometh *no ND 0.20
7447-3 Chloromethane ND 020
73-01-4 Vinyl chlorlde • ND 0,20
74434 arom0M811110141 ND 0.20
73404 chloroethina _ _ NO 0.20
maim Trichlorofluommethene -ND 0.20
75-35.4 1,1 . Dichloroethene NO 0.20
75014 Methyl•he chloride NO 0,20
isseo-5 trans • 1, 2 - Dlohtoroetherte NO 0.20
70444 1,1 - OlohlOrellthans ND 0.20
11111404 018- 1,2 - Olohloroethen. N6 0.20
74-974 Bromochloromethane , ND 0.20
8740-3 Chloroform ND 0.20
384404 2,2- Olchloropropane ND 0.20
7#454 1,1,1 • Trlohloroettline ND 0.20
. 107484 1,2 - Dlohloroethane NO 0.20
609.41114 1,1 • Diehlotopropene ND 0.20
58.234 Carbon tetrachloride ND 0.20
71434 Benzene ND 0.20
14464 DIbromomethane No 0.20
Mem 1.275raroropropane --NO 0.20
70404 Trichloroethene ND 0.20
7S-21-4 Oromodlchloromethane NO 0.20
iocal-o#4 We - 1,3 - Olahlorepropene NO 0.20
icosi.02-0 trans • 1,3- DIchloroprooene NO 0.20
moce 1,1,2 - Valimathane NO 0.20
100-00-3 Toluene ND 0.20
100634 1,2 - Dlbrontoethane • NE) 0.20
142-24-0 1,3 • Dlehloropropane ND 0.20
124.44.1 Dlbromochlarom ethane ---.. • • ND 0.20
127-184 Tetrachlorosthene ND olo
030,404 1,1,1,2 - Tetrachlorcethene ND 0.20
10040-7 Chloroeenzone . NO 0.20
100414 ithylbenzene ND 0.20
108434 m,p - Xylenes ND 0.40
7545.2 Bromotorm ND 0.20
100.44 Styrene NO 0.20
se.47.4 o - Xylans NO 0.20
73344 1,1,2,2- Tetrachloroathane ND 0.20
ge-to-4 1 ,2,3 - Triohloroertne ND 0.20
NO - Anolyto not clofootod at *Wed 11nOt of *NOW DMC00004
Page 1 05
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3N3
SENT BY:Xerox Tel ecopier 7021 , ; 9-19-95 ; 2:30PN ; 303 595 0930;# 2 ,
ATTAC1L1ENT 2
PAIWINCM38280
Date Sampled: 0W12/06
Date Analyzed: 09/17/96
Date Reported: 09/18/98
CONCENMATION LINT OP
OnS*10 DETECTION (MOW
Ollent:
Sample ID:
Laboratory ID:
C.A.S. 0
Enemy Fuels Nuclear, inc.
KOH
C96-53604
TARGET COMPOUNDS
94424 Isopropylbemene ND 016
10440-1 Brom-benzene ND 0.20 10346-1 n - Propylbenzene ND 0.20 118444 2 • Chlorotoluene ND 0.20
146-434 4 • Chlorotoluens ND 0.20 144474 1,3,5 - Trimethylbenzanis ND 0.20 00484 tort - Butylbenzene ND 0.20 94444 1,2.4 - Trimethylbenzene ND 0.20
135464 sec - Butylbenzens ND 0.20 641-78.1 1,3 - Dlohlorobenzane • NO 0.20
10844.7 1,4 - Olchlombanzine NO 020
99•8741 4-lsopropyltoluene . NO 0.20
9440-1 1,2 - Dlohlorobanzene ND 0.20
104414 n - Sutylbenzene ' NO 0.20
90.124 t,2 • Dlbromo - 3 • chloroproolne ND 1.00
120424 1,2,4 - Trichlorobenzene ND 0.20
91404 Naphthalene ND 0.20
87464 Hexechlorobutadlene NO 0.20
87414 1,2 3 - TrIchlorobenzene ND 0.20
ND . And)its not detected et steed &aft of detection
PALS Pentefluo •• none 1302258
Pluorobenzen 1887114
1,4 • Dtfluono 02948 • 1673075
Chlorobenze e • d5 1235710
1,4 • DWI° ns • (14 889788
ICAL / CCAL PERCENT ACCEPTANCE AREA RECOVERY BANGE 1262308 103% 50 - 200 %
1820083 103% 50 • 200 % 18175121 103% 50 • 200 %
1190126 104% SO - 200 %
090090 100% 50 - 200 %
PERCENT ACCEPTANCE
CPNCENTRATION RECOVERy BANE Dibmmofluo , methane
Toluene • de
4 - Bromotlu • . . nzene
1,2 - Diablo • . ozone • d4
9.53 95,31b ae - 118 %
10.1 101% 8$ - 110 %
• 10.2 102% ss - 115 %
9.94 99,4% SO • 120 %
Method 5250: volatIte Organics by Gas chromatography/Mass Spectrometry team Capillary Technique
Test Methods tar Evaluating sold Weste, SW-134e, Third Edition, LisEPA, November 1990
Arglyst
Mewl Pne0. 11411Viriiiid:

DMC0000411
Page 2 ot 5
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NOV 2 3 1996
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
November 20th, 1996
•
Energy Fuels Nuclear, Inc.
ATTN: Ms. Michelle Rehmann,
Environmental Manager
1515 Arapahoe Street, Suite 900
Denver, Colorado 80202
SUBJECT: AMENDMENT 43 TO SOURCE MATERIAL LICENSE SUA-1358, ENERGY FUELS
NUCLEAR, INC.'S WHITE MESA URANIUM MILL, BLANDING, UTAH
Dear Ms. Rehmann:
The U.S. Nuclear Regulatory Commission staff has completed its review of
Energy Fuels Nuclear, Inc.'s (EFN's) request to amend NRC Source Material
License SUA-1358 for the White Mesa mill, submitted by letter dated
September 20, 1996, and amended by letters dated October 30, and November 11,
1996. EFN requested that SUA-1358 be amended to allow receipt and processing
of urinia0-bearing potassium diorinate modi in a solution of petassitit
hydroxide/potassiumfluoride (KOH/KF) from Allied Signal, Inc. of Metropolis,
Illinois (Allied).
The details of the amendment request are discussed in the NRC staff's
Technical Evaluation Report (TER). The TER documents the basis for the NRC
staff's evaluation of the amendment request and is provided as Enclosure 1.
The NRC staff reviewed EFN's request in accordance with 10 CFR Part 40,
Appendix A, requirements and NRC staff guidance "Final Position and Guidance
on the Use of Uranium Mill Feed Material Other Than Natural Ores' (60 FR
49296; September 22, 1995). Based on its review, the NRC staff has found the
proposed amendment to be acceptable.
Therefore, pursuant to Title 10 of the Code of Federal Regulations, Part 40,
Source Material License SUA-1358 is hereby amended by adding License
Condition No. 59. All other conditions of this license shall remain the same.
The enclosed license is being reissued to incorporate the above modification
(Enclosure 2). An environmental review was not performed since this
administrative action is categorically excluded under 10 CFR 51.22(c)(11).
DMC0000457
M. Rehmann -2-
If you have any questions regarding this letter or the enclosures, please
contact the NRC Project Manager for the White Mesa mill, Mr. James Park, at
[phone]. .
Sincerely,
Joseph J. Holonich, Chief
Uranium Recovery Branch
Division of Waste Management
Office of Nuclear Material Safety
and Safeguards
cc: W.Sinclair, UT
Enclosures: As stated
DMC0000458
TECHNICAL EVALUATION REPORT
FOR REQUEST TO RECEIVE AND PROCESS MATERIAL FROM ALLIED SIGNAL, INC.
DOCKET NO. 40-8681
LICENSEE: biergy Fuels Nuclear, Inc.
FACILITY: White Mesa Uranium Mill
PROJECT MANAGER: James Park
SUMMARY AND CONCLUSIONS:
LICENSE NO. SUA-1358
The U.S. Nuclear Regulatory Commission staff has reviewed Energy Fuels
Nuclear, Inc.'s (EFN's) request to receive and process uranium-bearing
potassium diurinate (K21407) in a solution of potassium hydroxide/potassium
fluoride (KOH/KF) from AlTied Signal, Inc. of Metropolis, Illinois (Allied).
Based on its review of EFN's information provided by letters dated September
20, October 30, and November 11, 1996, the NRC staff considers the amendment
request to be acceptable.
DESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:
By submittal dated September 20, 1996, and amended by letters dated October 30
and November 11, 1996, EFN requested that NRC Source Material License SUA-1358
be amended to allow receipt and processing of uranium-bearing potassium
diurinate (K2U207) in a KOH/KF solution. This material would be shipped to
EFN's White Mesa mill from Allied, either in a "dry" form (moisture content
greater than 5 percent) in overpacked 55-gallon drums or as a slurry aboard
tanker trucks. • Approximately 2475 tons of the material will be shipped.
The uranium content of the material is between 7 and 10 percent.
Depending on whether the material arrives in a dry or slurry form, EFN will
implement slightly different methods for introducing it into the mill circuit.
Slurried material will be pumped from the tanker truck directly into a
transfer tank. After pH and density adjustments, the slurry will be
introduced into the leach circuit. The potential for airborne contamination
dispersion in this process is minimal.
For dry material, drums either will be (1) dumped into the transfer tank and
puMped to the leach circuit, or (2) dumped onto the ore loading beit,
processed through the semi-autogenous grinding (SAG) mill, and then introduced
into the circuit. Dust dispersion will be minimized through the use of
available water spray systems.
In either situation, no changes to the mill circuit are required to process
this material.
EFN will provide personal protective equipment, including respiratory
protection, to individuals engaged in processing the material. Airborne
particulate samples will be collected and analyzed for gross alpha
1
DMC0000459
concentrations and KOH/KF dust ,concentrations. Full-face respiratory
protection will be implemented during the entire sequence of material dumping
operations if KOH/KF dust concentrations or uranium airborne concentrations
exceed specified limits. Spills and splashed material that may be encountered
during this initial material processing will be wetted and collected during
routine work activity. Employees will be required to wear coveralls and
rubber glove-S-at all times when handling this material.
Trucks used to transport the material to the mill site will be radiometrically
scanned prior to their release from the site restricted area.
TECHNICAL EVALUATION:
The NRC staff has reviewed EFN's request in accordance with 10 CFR Part 40,
Appendix A, requirements and NRC staff guidance "Final Position and Guidance
on the Use of Uranium Mill Feed Material Other Than Natural Ores" (60 FR
49296; September 22, 1995). This guidance (referred to hereinafter as the
alternate feed guidance) requires that the staff make the following
determinations in its reviews of licensee requests to process material other
than natural uranium ores.
1. Whether the feed material meets the definition of "ore;"
2. Whether the feed material contains hazardous waste; and
3. Whether the ore is being processed primarily for its source-material
content.
Determination of whether the feed material is "ore"
For the tailings and wastes from the proposed processing to qualify as lle.(2)
byproduct material, the feed material must qualify as "ore." In the alternate
feed guidance, ore is defined as
"... a natural or native matter that may be mined and treated for
the extraction of any of its constituents or any other matter from
which source material is extracted in a licensed uranium or
thorium mill."
EFN is proposing to extract source material from the KOH/KF solution.
Therefore, the KOH/KF solution meets the definition, because it is a "matter
[that is not natural or native] from which source material is extracted in a
licensed uranium or thorium mill."
Determination of whether the feed material contains hazardous waste
EFN has certified and affirmed that the KOH/KF solutions do not meet the
classification as a "waste," as defined under the provisions of the Resource
Conservation and Recovery Act (RCRA). EFN certified and affirmed that the
Allied material is not discarded or abandoned, but is a Product for which EFN
will pay Allied in order to recover the uranium present.
2
DMC0000460
Determination of whether the feed material is beim_ Processed primarily for
its source-material content
To show that potential alternate feed material is being processed primarily
for its source-material content, a licensee must either (1) demonstrate that
the material_yould be approved for disposal in the tailings impoundment under
the "Final Revised Guidance on Disposal of Mon-Atomic Energy Act of 1954,
Section lle.(2) Byproduct Material in Tailings Impoundments;" or (2) certify
under oath or affirmation that the material is being processed primarily for
the recovery of uranium and for no other primary purpose.
The licensee has provided a signed affirmation that the Allied material is
being processed primarily for the recovery of uranium and for no other primary
purpose. For EFN, the high uranium content of the material (7 to 10 percent)
justifies processing this material to extract uranium.
Conclusions concerning alternate feed material designation
Based on the information provided by the licensee, the NRC staff finds that
the Allied material is alternate feed material because: (1) it meets the
definition of "ore," (2) it does not contain hazardous waste, and (3) it
is being processed primarily for its source-material content.
Other considerations
The NRC staff has also concluded that the processing of this material will not
result in (1) a significant change or increase in the types or amounts of
effluents that may be released offsite; (2) a significant increase in
individual or cumulative occupational radiation exposure; (3) a significant
construction impact; or (4) a significant increase in the potential for or
consequences from radiological accidents. This conclusion is based on the
following information:
a. Processing of this material will not result in an exceedance of the
currently-approved annual yellowcake production limit of 4380 tons of
1.1308.
b. No physical changes to the mill circuit are required to process this
material.
c. Processing this material will not require EFN to enlarge its tailings
facilities.
d. Trucks transporting the material to the mill site will be surveyed and
decontaminated, as necessary, in accordance with EFN's procedures,
before leaving the site.
e. Individuals will be provided with personal protective equipment,
including respiratory protection, and be required to wear coveralls and
rubber gloves while handling this material. Airborne particulate
samples will be collected and analyzed for gross alpha concentrations
and KOH/KF dust concentrations. Full-face respiratory protection will
3
DMC0000461
be implemented if specified limits/concentrations are exceeded. Spilled
and splashed material during initial material processing will be wetted
and collected during routine work activity.
RECOMMENDED LICENSE CHANGE:
--: Pursuant to Title 10 of the Code of Federal Regulations, Part 40, Source
Material License SUA-1358 is amended by the addition of License Condition
No. 59 as follows:
59. The licensee is authorized to receive and process source material from
Allied Signal, Inc. of Metropolis, Illinois, in accordance with the
amendment request dated September 20, 1996, and amended by letters dated
October 30, and November 11, 1996.
ENVIRONMENTAL IMPACT EVALUATION:
An environmental review was not performed since this action is categorically
excluded under 10 CFR 51.22(c)(11).
4
DMC0000462