DRC-2013-002916 - 0901a068803ae542

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
"DRC-201 3-002916" Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
August 6,2013
VIA EMAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") Email Questions Regarding Yellowcake
Received from Honeywell
Dear Mr. Lundberg:
This letter responds to an email dated July 29, 2013 from Mr. Ryan Johnson of DRC regarding Energy Fuels
Resources (USA) Inc.'s ("EFRI's") letter of July 25, 2013 describing EFRI's plans to concentrate and purify
yellowcake (the "Honeywell Yellowcake"), that is adhered to drum shreds, from Honeywell Inc.'s
("Honeywell's") Metropolis, Illinois works (the "Metropolis Works") at the White Mesa Mill (the "Mill"). This
letter also addresses two additional questions raised by Mr. Johnson during a telephone call with EFRI on July
31,2103.
Under the proposed transaction, Honeywell will transfer the Honeywell Yellowcake to the Mill under 10 CFR
40.51, and the Mill will receive the Honeywell Yellowcake under its existing Radioactive Materials License No
UT 1900479 (the "Mill License") as a "licensee-to-licensee" transfer of source material. The Honeywell
Yellowcake will be concentrated and purified as a further step in the uranium milling process. It is not an "ore"
and hence is not an alternate feed material. It is EFRI's understanding that an environmental analysis specific
to this transaction is not required under these circumstances.
It is important to note that there are no additional environmental, health, or safety concerns associated with the
receipt of the Honeywell Yellowcake and associated drum shreds, or the separation, precipitation, drying and
packaging of the yellowcake and the disposal of the drum shreds in the Mill's tailings cells. The Honeywell
Yellowcake has the same chemical composition as yellowcake produced or reprocessed in the Mill, and the
associated drum shreds have the same composition as drums disposed of at the Mill on a regular basis.
However, EFRI has provided the requested information below to clarify the information provided in our July
25, 2013 letter. For ease of review, DRC's comments are provided verbatim, in italics, below followed by
EFRI's response.
ENERGYFUELS
20^
N:\WMM\Altemate Feeds\Honeywell Converdyne\Drum Shreds determination process\Response to DRC comments Drum shredsVLr to R
Lundberg response to questions Honeywell Yellowcake 7 3113 draft final.docx
Letter to R. Lundberg
August 6,2013
Page 2 of 7
Questions from DRC Email of July 29.2103
1. When do you estimate the starting time of the project? How long do you estimate the project will last?
EFRI Response
The project will begin immediately upon receipt of DRC acceptance of the information provided by EFRI. The
Mill anticipates a period of four to six weeks for construction of equipment for separating the hardened
yellowcake from the drum shreds as the first step in the concentration and purification process. Yellowcake
concentration and purification would begin immediately following construction.
It is estimated that the drums would be shipped in approximately 40 to 50 truckloads over a period of
approximately 10 to 15 weeks.
The Mill estimates that separation of the hardened yellowcake and reintroduction into the Mill circuit could be
completed in approximately 20 weeks.
2. Is the 4,800 drums the exact number of drums or could there be more?
EFRI Response
Honeywell has provided EFRI an initial estimate of 4,803 drums. Although the number may increase
somewhat, Honeywell does not expect it to exceed approximately 4850 drums.
3. How will this project be documented at the Mill and where will that documentation be kept in case the
DRC needs to review it?
EFRI Response
Analytical results from sampling of the hardened pulverized yellowcake at the Honeywell facility will be
maintained at the Mill and available for inspection by DRC.
Transportation records for truckloads will be maintained on site at the Mill consistent with applicable
Department of Transportation requirements and available for inspection by DRC.
Licensee-to-licensee product transfer records will be maintained on site and reported to the U.S. Department of
Commerce and U.S. Nuclear Regulatory Cornmission as required by 10 CFR 75.11 and any other applicable
regulations. Information regarding the kilograms of material transferred to and from the Mill will be tracked
through the National Nuclear Security Administration (NNSA, formerly entitled NMMSS). Such
documentation will be available for inspection by DRC.
Ambient and worker exposure monitoring data will be maintained on site at the Mill consistent with the Mill's
Radiation Protection Manual and applicable SOPs, and will be available for inspection by DRC.
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Letter to R. Lundberg
August 6, 2013
Page 3 of7
4. In the "Drum Characterization Data " section, I had a hard time following the 2nd paragraph. Third
sentence says "Samples from each of the 48 drums were composited into one lot". What 48 drums are you
talking about?
EFRI Response
Honeywell shredded approximately 15,000 drums of hardened yellowcake. This process produced:
• shredded/pulverized hardened yellowcake freed from the drum shreds and placed in approximately
17,000 drums; and
• hardened yellowcake adhered to dram shreds and placed in approximately 4,800 drams, referred to
herein as "Honeywell Yellowcake".
Since the yellowcake adhered to the dram shreds is identical to the pulverized yellowcake freed from the dram
shreds, Honeywell sampled the pulverized yellowcake freed from the dram shreds, which made up the 17,000
drams. At the time of submittal of the July 25, 2013 letter, Honeywell had initially collected 196 composite
samples (also referred to as lots) of the pulverized yellowcake freed from the dram shreds, which were analyzed
for uranium content and impurities. Each composite sample or lot was made up from a composite of material
from its own set of 48 drams. Hence, the 196 samples represented material from 9,408 of the 17,000 drams, as
calculated below:
(Material from 48 drams in each composite) x (196 composite samples) = 9,408 drams originally sampled
(9,408 drams originally sampled)/( 17,000 drams) ~ 55% of the population originally sampled
For internal accounting purposes, Honeywell chose to analyze the uranium value and metals content of all
17,000 drams by making composite samples from sets of 48 drams as described above. At the time of EFRI's
July 25, 2013 letter, Honeywell had received and summarized results from composites from the 9,408 drums
discussed above. Honeywell has since received and summarized uranium results from composites from the
remainder of the 17,000 drums or 100% of the drams, and impurities results from 80% of the drams. The table
below demonstrates that the dram population is extremely well represented by the sample fraction:
Composites
(Lots)
355
280
Drums
per Lot
48
48
Total
Drums
Sampled
17,000
13,440
Fraction
of Total
Drum
Population
100.0%
79.1%
Analyzed for
Uranium
Impurities (Metals and
Anions)
Note: One composite lot would have been composed of fewer than 48 drum samples.
A revised Table 1 has been attached to this letter summarizing the uranium impurity data from all 17,000
drams, and the impurity data from 13,440 drums.
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Letter to R. Lundberg
August 6, 2013
Page 4 of 7
5. In that same paragraph it says that 9,408 drums were sampled, which is 55% of the original 17,000
drums that were shredded. Was the number of drums sampled (9,408) determined through a statistical
calculation? If so, will you provide the formula used or how that number was determined?
EFRI Response
Approximately 15,000 (not 17,000) drums were shredded. The shredding produced 17,000 drums of
shredded/pulverized hardened yellowcake freed from the drum shreds, due to expansion as a result of the
shredding process.
As discussed during our phone call of July 31, 2013 and in the response to Comment 5, above, uranium data is
currently available for all 17,000 drums (100% sampling frequency) of shredded/pulverized hardened
yellowcake. Impurity data is also available for 79% of the drums of shredded/pulverized hardened yellowcake.
Given a uranium sampling frequency of 100%, and an impurity sampling frequency of 79%, no statistical
justification should be necessary to demonstrate that the resulting data is representative.
6. Can we get electronic copies of the analytical reports of the drums that will be coming to the Mill?
EFRI Response
Electronic copies of analyses for the 17,000 drums sampled, which consists of several thousand sheets of lab
reports, are available for review at the Mill.
7. Did they sample for RCRA ?
EFRI Response
EFRI assumes that by "sampling for RCRA", DRC refers to a) sampling for RCRA characteristics (ignitability,
corrosivity, reactivity or toxicity), and b) sampling for any additional analytes appropriate to determine the
presence of RCRA-listed waste. Neither type of sampling is required or appropriate for the Honeywell
Yellowcake for the following reasons.
As discussed in our letter, the Honeywell Yellowcake consists of the same yellowcake product as produced by
EFRI at the Mill, and in fact, may include yellowcake produced in the past at the Mill. The Honeywell
Yellowcake consists of U308 yellowcake concentrate, which is source material. Because the Honeywell
Yellowcake is clearly source material it is exempt from RCRA under 40 CFR 261.4, and no further RCRA
analysis is required.
No listed hazardous waste processes occurred at the Honeywell facility. As discussed in our letter, the drums
were opened only momentarily for collection of samples. There was no opportunity for wastes or other
constituents to be added to the drums. Hence no RCRA listings could possibly apply.
It is expected that U308 yellowcake concentrates would contain elevated levels of metals. Yellowcake
concentrates produced at the Mill, along with product drums, likewise contain elevated levels of metals, in
excess of RCRA TCLP thresholds; but since these concentrates are source material, they are exempt from
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Letter to R. Lundberg
August 6, 2013
Page 5 of 7
RCRA regulation for their metal content. The Honeywell Yellowcake is expected to contain the elevated levels
of the same metals as Mill yellowcake, and similarly is exempt from regulation for RCRA TCLP metals.
No RCRA-related analysis was conducted because it is not appropriate or applicable.
8. How many trucks loads do you estimate will be used to deliver the 4,800 drums to the Mill? Will they
be transported as exclusive use shipments?
EFRI Response
Honeywell estimates that approximately 40 to 50 truckloads will be used to transport the estimated 4,803 drums
to the Mill. These may be shipped to the Mill at a rate of approximately 4 trucks per week, over a period of 10
to 15 weeks. They will be transported as exclusive use shipments.
9. This one is more of a comment. According to the U.S. DOT the term "natural uranium" can only be
used for material that has not been altered by mechanical means. Below are a couple of things to be aware of.
The DOT in 49 CFR 173.401 (b)(4) adds this definition for the use of the word "Natural" in classification:
"Natural material and ores containing naturally occurring radionuclides which are not intended to be
processed for use of these radionuclides, provided the activity concentration of the material does not exceed 10
times the values specified in Sec. 173.436
DOT interpretation 06-0003 states in Al second paragraph: "The term "natural materials" in 173.401(b)(4)
means material and radionuclides existing in nature, not produced by humans. Radionuclides addressed by
173.401(b)(4) do not include those contained in filters used to remove radionuclides from drinking water,
produced in nuclear reactors or by other technological means."
I am suggesting that you do not call this material "natural uranium". It would be better to call it "yellowcake"
or U308.
EFRI Response
EFRI has identified the material as containing natural uranium as defined by 10 CFR 71.4 [Title 10 - Energy;
Chapter I — Nuclear Regulatory Commission; Part 71 - Packaging and Transportation of Radioactive Material;
Subpart A — General Provisions], the term:
"(1) Natural uranium means uranium with the naturally occurring distribution of uranium isotopes
(approximately 0.711 weight percent uranium-235, and the remainder by weight essentially
uranium-238)."
10 CFR 110.2 states:
"Natural uranium means uranium as found in nature, containing about 0.711 percent of uranium-
235, 99.283 percent of uranium-238, and a trace (0.006 percent) of uranium-234.
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Letter to R. Lundberg
August 6,2013
Page 6 of 7
Honeywell Yellowcake contains the naturally occurring distribution of uranium isotopes and meets the
definition of natural uranium in 10 CFR 71.4 and 10 CFR 110.2, just like any other yellowcake produced at the
Mill. Its uranium content was not the result of a human process, such as the blending of enriched or depleted
uranium, but resulted solely from the extraction of natural ores, which uranium isotope distribution is not
affected by the chemical concentration processes in uranium milling.
However, EFRI agrees that the Honeywell Yellowcake should be shipped ti the Mill as "U308 in the form of
Yellowcake" for the purposes of shipping documentation, as recommended in DRC's comment, the same as any
other yellowcake produced at the Mill.
Questions from Phone Call of July 31.2103
1. What kind of equipment will be installed for filling, shaking and emptying the yellowcake drums, and
where will it be located?
EFRI Response
The Mill plans to separate the adhered yellowcake from the drum shreds by filling the overpack drums
containing the drum shreds with sulfuric acid to re-dissolve the yellowcake. The Mill plans to construct a drum
processing station to add acid solution to the overpacks, agitate the filled overpacks, and empty the dissolved
yellowcake in acidic solution from the overpacks into a receiving tank. The acidic yellowcake solution would
be reintroduced into the Mill's main circuit for further concentration and purification. The drum shreds would
be disposed of in the Mill's tailings cells.
To perform the re-dissolution step, Mill will construct a concrete pad to contain the solutions. The yellowcake
dissolution process including the overpack filling and agitation equipment will be located on this pad.
The concrete pad and process equipment will be located at the existing Alternate Feed process area, that is,
within the footprint of the existing Mill process area.
2. Identify whether worker safety and radiation protection issues will be addressed by a SOP, Radiation Work
Plan or other controls.
EFRI Response
The separation steps described above of the yellowcake concentration and purification process will be
documented in a SOP, specific to the process, which will be evaluated by the Mill's SERP. The SERP will
specify whether specific RWPs, and/or additional worker exposure or area monitoring will be required.
Because the Honeywell yellowcake is yellowcake, the Mill proposes to use the yellowcake packaging DAC and
worker protection methods and requirements associated with handling of yellowcake. The Mill RSO will be
responsible for implementation and documentation of monitoring data. The remaining steps of the
concentration and purification process are the same as for any other yellowcake produced at the Mill, and are
adequately covered by existing Mill SOPs.
Please advise us as soon as possible whether DRC concurs with EFRI's determination in our letter of July 25,
2013, and plans regarding the Honeywell Yellowcake. If DRC is not able to concur with EFRI's determination
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Letter to R. Lundberg
August 6, 2013
Page 7 of 7
based on the written materials provided, EFRI would appreciate an opportunity to discuss any remaining issues
with DRC at a meeting prior to DRC's making its final determination. If you should have any questions
regarding the above information, please contact me at 303-389-4132.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Jo Ann Tischler
Manager, Mill Compliance
cc: David C. Frydenlund
Dan Hillsten
John Hultquist (DRC)
Harold R. Roberts
Al Stratemeyer, Honeywell/Converdyne
David E. Turk
Katherine A. Weinel
Attachments
Table 1 Updated
Analysis of Honeywell UOC on Drum Shreds
UOC Material %Be %B %Na %Mg %Si %P %K %Ca %Ti %V %Cr %Mn
Average <0.0001 0.0003 0.28 0.0160 0.0559 0.0326 0.11 0.15 0.0035 0.0330 0.0006 0.0069
Max 0.0001 0.0018 1.53 0.1248 0.2297 0.1708 9.10 2.31 0.0215 0.1873 0.0043 0.0414
Min <0.0001 <0.0001 0.03 0.0024 <0.0001 <0.0001 <0.01 0.02 0.0004 0.0010 <0.0001 0.0010
Honeywell
Acceptance
Specification
(max) NA 0.10 3.00 0.50 3.50 1.00 2.00 1.00 0.05 0.75 0.04 NA
UOC Material %Co %Ni %As %Se %Zr %Mo %Ag %Cd %Sb %Ba %Hg %Pb
Average 0.0003 0.0041 0.0112 0.0040 0.0291 0.0576 0.0001 0.0002 0.0003 0.0014 <0.0001 0.0012
Max 0.0040 0.5006 0.0396 0.2286 0.1535 0.4842 0.0016 0.0034 0.0058 0.0161 0.0003 0.0331
Min <0.0001 <0.0001 0.0011 0.0000 0.0015 0.0033 <0.0001 <0.0001 <0.0001 0.0001 <0.0001 0.0001
Honeywell
Acceptance
Specification
(max) NA NA 0.10 0.04 1.00 0.30 0.04 0.04 NA 0.04 NA 0.04
UOC Material
Average
Max
Min
Honeywell
Acceptance
Specification
(max)
ppm U-234
53.31
54.87
51.56
%235U
0.7115
0.714
0.706
%238U
76.65
81.83
67.66
%SQ4
=
1.47
7.10
0.59
% cr
0.012
0.24
<0.01
%F
0.07
1.36
<0.01
%H2Q
9.19
25.48
1.20
62.00 NA NA 4.00 NA 0.15
Note:
Samples collected and analyzed in 2013 at Honeywell's Metropolis Works