DRC-2020-010068 - 0901a06880c89ec7

DRC-2020-010068 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
L. Scott Baird Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director

May 26, 2020

Kathy Weinel, Quality Assurance Manager Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228 RE: Processing Uranium Precipitate from Uranium Resources Inc.' s Kingsville Dome, Texas Uranium In-Situ Recovery Facility at the White Mesa Mill
Radioactive Material License Number UT 1900479
Dear Ms. Weinel: In a letter dated April 30, 2020, Energy Fuels Resources (USA) Inc. (EFRI) informed the Division of
Waste Management and Radiation Control (DWMRC) of EFRI’s intent to transfer a uranium precipitate
material from the Uranium Resources Inc.' s (URI) Kingsville Dome, Texas Uranium In-Situ Recovery Facility to the White Mesa Uranium Mill, located just south of Blanding, Utah. EFRI indicated that the uranium precipitate material could be transferred between the Kingsville Dome facility and the White Mesa Mill because both facilities are authorized to receive and transfer the licensed source material
(U3O8). EFRI asserted that this would be a legal transfer of licensed source material in accordance with
10 CFR 40.51(a)(5) [equivalent to UAC R313-19-41(2)(d)]. The purpose of this transfer is so the uranium precipitate can be processed to remove impurities, dried and then packaged as a useable yellowcake product at the White Mesa Mill. In the letter, EFRI explains that the uranium precipitate comes from an intermediate step in the Kingsville Dome facility’s process. Due to the impurities that
are present in the uranium precipitate, the Kingsville Dome facility is unable to make it into usable
yellowcake. The White Mesa Uranium Mill however, can remove the impurities. Thus, the request to transfer the uranium precipitate to complete the process of making usable yellowcake. (Over)

The DWMRC has evaluated the information provided by EFRI regarding this request. Based on the Nuclear Regulatory Commission’s (NRC) conclusions that milling processes may occur at locations
other than a uranium mill and that milling processes are not completed until the conversion process
begins (SECY-02-0095), and on the Utah Radiation Control Rules, DWMRC staff agree that the Kingsville Dome uranium precipitate is still in the milling process and that the yellowcake material from the Kingsville Dome facility can be transferred to EFRI’s White Mesa Uranium Mill under the provisions in R313-19-41(2)(d). Therefore, no amendment is necessary to EFRI's license for the
transfer of URI’s yellowcake material. The following provisions apply to the DWMRC's concurrence
for the transfer of the yellowcake material from URI's Kingsville Dome, Texas Uranium In-Situ Recovery Facility to the White Mesa Uranium Mill:
• This concurrence for transfer of materials is exclusively for the uranium precipitate material
from the URI' s Kingsville Dome, Texas Uranium In-Situ Recovery Facility and does not apply to other future projects. Any additional uranium precipitate material from other facilities will require Director approval.
• The yellowcake produced from this project must be counted toward the yellowcake production
limits in EFRI’s RML License Condition 10.1.A.
• Transportation of the uranium precipitate material in Supersaks® shall be within an enclosed transport conveyance to provide secondary containment for possible leakage.
• The Supersaks® containing the uranium precipitate shall be stored on the concrete near the
White Mesa Uranium Mill’s grizzly and inspected weekly for degradation and holes. If degradation or holes are identified, the Supersaks® shall be repackaged.
• The White Mesa Mill has 365 days to process the uranium precipitate from the date of receipt. If
the material is not processed within 365 days, it shall be put into the tailing impoundment as
11e.(2) disposal. The DWMRC will inspect compliance aspects of this project during future inspections at the White Mesa Mill. If you have any questions, please contact Ryan Johnson, at 801-536-4255.
Sincerely, Ty L. Howard, Director
Division of Waste Management and Radiation Control TLH/RMJ/as
c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department Russell Seeley, UDEQ District Engineer Logan Shumway, Manager, White Mesa Uranium Mill