DRC-2016-010681 - 0901a068806781af

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

October 19, 2016

Harold Roberts
Executive Vice President
Conventional Operations
Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600
Lakewood, CO 80228

RE: Concentration and Purification of Yellowcake Material from Honeywell
Radioactive Material License (RML) UT1900479
Dear Mr. Roberts:

In a letter dated October 4, 2016, Energy Fuels Resources (USA) Inc. (EFRI) informed the Division of
Waste Management and Radiation Control of its intent to transfer a yellowcake material from the Honeywell Metropolis Works facility located in Illinois to the White Mesa Uranium Mill. EFRI
indicated that the yellowcake material could be transferred between the Honeywell 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 yellowcake material can be reconcentrated and purified, dried and then packaged as a
useable yellowcake product at the White Mesa Mill. The reconcentrated yellowcake will then be sent
back to the Honeywell facility.

The Division has completed its evaluation of the information provided by EFRI regarding this request. Based on this evaluation and 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 the Utah Radiation Control Rules, the Division
agrees that the Honeywell yellowcake material is still in the milling process and agrees that the
yellowcake material from the Honeywell Metropolis facility can be transferred to the White Mesa Mill under the provisions in R313-19-41(2)(d). Therefore, no amendment is necessary to EFRI’s license for the transfer of the Honeywell yellowcake material. The Division’s concurrence is based upon the
following:

DRC-2016-010681 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

• This transfer of materials is exclusively for the yellowcake material from the Honeywell
Metropolis facility and does not apply to other future projects. Any additional yellowcake
material from other facilities will require Director approval; and
• The yellowcake produced from this project must be counted toward the yellowcake production limits in EFRI’s RML License Condition 10.1.A.

The Division will inspect compliance aspects of this project during future inspections at the White Mesa
Mill. If you have any questions, please call Ryan Johnson at [phone]. Sincerely,

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

STA/RMJ/ka