DRC-2014-002661 - 0901a0688041d135

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
April 1,2014
DRC-2014-002661
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Radioactive Material License No. UT1900479
2014 Radiation Protection Inspection, Module RADMOD-DRM-01
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on March 20, 2014 by a representative of the Division of Radiation Control (DRC), Utah Department of
Environmental Quality.
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Materials License Number UT 1900479. The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector.
The activities and practices reviewed during the inspection with respect to Drum Handling and
Management were found to be in compliance with relevant requirements.
A copy of the Inspection Report is enclosed.
If you have any question, please contact Boyd Imai at [phone].
Sincerely,
RL/BMI:bi
Enclosure
cc/enc: Ronnie Nieves, RSO, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www. deq. utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-DRM-01: Drum Handling and Management
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 20, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dan Hillsten, Karsen Lacy, Heath Latham, Ronnie Nieves, Travis O'Neil,
Inspection Summary
The inspection was opened on March 20, 2014 with a meeting with D. Hillsten, and R. Nieves.
Kevin Carney from the DRC was also in attendance.
Areas/Topics inspected included:
• Pressurized Drums
• Honeywell Yellowcake Project
• Drum Management
The inspector held a closeout meeting on March 20, 2014 with D. Hillsten, R. Nieves, and Dave
Turk of Energy Fuels Resources with K. Carney of DRC to review the inspection activities,
observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Pressurized Drums
On March 4, 2014 the Nuclear Regulatory Commission (NRC) issued an Information Notice 1999-
03, Rev 1 entitled "EXOTHERMIC REACTIONS INVOLVING DRIED URANIUM OXIDE
POWDER (YELLOWCAKE)." The focus of the notice was to discuss the problems encountered
with increased internal drum pressures as a result of yellowcake processing. Since the Licensee is
engaged in the production of yellowcake this inspection was fashioned, in part, to evaluate the
potential problems associated with drums becoming pressurized due to chemical reactions taking
place after the lids are installed and sealed.
The conclusion of the Information Notice was that the problem was a concern for "facilities
utilizing hydrogen peroxide precipitation and drying temperatures below 800°C (1472°F)." The
Licensee utilizes an ammonia precipitation process and dries the material at approximately 1400°F
David Turk, Kathy Weinel
Page 1 of 3
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-DRM-01\InspectionReportRev0.doc
and therefore the conditions are not conducive to generating increased drum pressures in the manner
discussed in the notice.
The Licensee participated in the survey conducted by the NRC on this matter. The Licensee shared
the responses with the inspector but a hardcopy was not available for public release. In essence, the
conclusions based on all of the responders to the survey questions suggest that the problems
encountered at other uranium recovery facilities do not pertain to this Licensee's operations.
When asked if other causes of pressurized drums had been assessed, e.g. temperature fluctuations,
the Licensee responded that over the years of operation no incident of an overly pressurized drum
has occurred nor has there been any indication of drums experiencing increased pressurization;
therefore, no such assessment was deemed necessary. For the same reasons drums are not tested for
excessive pressure buildup in drums after packing.
Honeywell Yellowcake Project
This uranium recovery project involved the removal of yellowcake residues from shredded drums
originating from the Honeywell Inc's Metropolis, Illinois works. The drums once contained U3O8
(yellowcake) that had hardened and was not readily removable from the drums. The yellowcake
was separated from the drums by shredding the drums with the yellowcake contents. The shredded
drums had amounts of yellowcake residues adhering to the surfaces worthy of recovery. The drum
shreds were packaged (in drums) and sent to the Licensee for uranium recovery. There were
roughly 5000 drums sent for processing.
The process of "cleaning" the drum shreds of yellowcake was observed during the inspection. The
process is guided by procedures which are found in procedure manual No.: PBL-12, rev. No.: R-0,
Date: November 1, 2013. Procedure, Shredded Drum Acid Leach, provides step-by-step
instructions for handling the material. A sulfuric acid/sodium chlorate solution, described in
procedure, Shredded Drum Reagent Make-up, was added to the drums containing the drum shreds.
After the material is tumbled in the drums on an electric drum roller for approximately 30 minutes
the liquid containing the now dissolved uranium was drained from the drum and collected in a
sump. The liquid would then be pumped into the solvent extraction circuit for routine SX
(precipitation and drying) processing.
The drum rolling process began on November 11, 2013 and at the time of the inspection (March 20,
2014) approximately half of the inventory had been processed. The drum rolling apparatus could
accommodate six drums at a time. Setting and removing drums from the rolling device is labor
intensive; however, the operating design is such that the workers can perform the manual tasks
safely. Workers handled the drums relatively easily with the use of a hand truck/dolly. Proper PPE
was observed to be worn. The primary concern was the corrosivity of the solution added to the
drums. No radiological incidences were reported during the time since operations began.
Preliminary air sampling during the operations indicated that airborne contamination is not an issue;
therefore, no respiratory protection was required during operations based on the air sampling results.
After the liquid is drained from the drums, the drums with the shredded metal are transported to the
tailings cell for disposal.
Page 2 of 3
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The work area was organized and clean. A post inspection review of the work area photographs
indicate potential tripping hazards, e.g. hoses, electrical cords and drum lid on the floor.
Drum Management
Feed material drums are stored on a hard surface pad. Drums are stacked in an orderly fashion. A
Radiation Area was established around a portion of the stored drums. A number of drums in a
particular lot of feed material had reported exposure rates of 5.0 mR/hr at 30 cm from the surfaces
of the drums.
Drums are filled with yellowcake product in an enclosed area with a negative air pressure.
Respiratory protection is required in the area where the filling takes place. No activities were taking
place in this area at the time of the inspection.
Drums containing product yellowcake are stored in the product storage area on a hard surface. The
compound was locked; no activities were taking place. Drums which could be seen from outside
the compound were neatly arranged in lots within the compound. Drums are prepared for shipment
in this area. Each individual who prepares drums for shipment are trained in the process. The
training is documented on a declaration form which covers Product Preparation and Shipping
and Loading trailer and trailer preparation. Radiological surveys of the product drums are
performed in this area for transportation purposes.
Forklifts and flatbed trucks are utilized to transport drums from one location to another on the site.
A flatbed truck was observed transporting a load of drums. It did not appear that the drums were
secured to the vehicle in any manner. This was brought to the attention of the Licensee.
Conclusion
Drums containing material are handled and stored in a radiologically safe and compliant manner.
No issues were encountered in this regard during the inspection.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, R. Nieves, and D. Turk of Energy Fuels
Resources (USA) on March 20, 2014. Also in attendance was K. Carney of the DRC. The
observations described above were summarized during the meeting.
Recommendations for the Licensee
• Evaluate the method of transporting drums around the mill site. Determine if there is any
risk of drums sliding off or falling off of the transport vehicles. If necessary, take actions to
reduce risks.
• Maintain clear walkways at the drum rolling operations.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai
(Name) (Signature)
March 28, 2013
(Date)
Page 3 of 3
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Inspection Report
anil
Inspection Checklist
FJADMOD-DHM-01
INSPECTION REPORT
Inspection Module: RADMOD-DRM-01: Drum Handling and Management
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 20, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dan Hillsten, Karsen Lacy, Heath Latham, Ronnie Nieves, Travis O'Neil,
Inspection Summary
The inspection was opened on March 20, 2014 with a meeting with D. Hillsten, and R. Nieves.
Kevin Carney from the DRC was also in attendance.
Areas/Topics inspected included:
• Pressurized Drums
• Honeywell Yellowcake Project
• Drum Management
The inspector held a closeout meeting on March 20, 2014 with D. Hillsten, R. Nieves, and Dave
Turk of Energy Fuels Resources with K. Carney of DRC to review the inspection activities,
observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Pressurized Drums
On March 4, 2014 the Nuclear Regulatory Commission (NRC) issued an Information Notice 1999-
03, Rev 1 entitled "EXOTHERMIC REACTIONS INVOLVING DRIED URANIUM OXIDE
POWDER (YELLOWCAKE)." The focus of the notice was to discuss the problems encountered
with increased internal drum pressures as a result of yellowcake processing. Since the Licensee is
engaged in the production of yellowcake this inspection was fashioned, in part, to evaluate the
potential problems associated with drums becoming pressurized due to chemical reactions taking
place after the lids are installed and sealed.
The conclusion of the Information Notice was that the problem was a concern for "facilities
utilizing hydrogen peroxide precipitation and drying temperatures below 800°C (1472°F)." The
Licensee utilizes an ammonia precipitation process and dries the material at approximately 1400°F
David Turk, Kathy Weinel
Page 1 of3
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-DRM-01\InspectionReportRev0.doc
and therefore the conditions are not conducive to generating increased drum pressures in the manner
discussed in the notice.
The Licensee participated in the survey conducted by the NRC on this matter. The Licensee shared
the responses with the inspector but a hardcopy was not available for public release. In essence, the
conclusions based on all of the responders to the survey questions suggest that the problems
encountered at other uranium recovery facilities do not pertain to this Licensee's operations.
When asked if other causes of pressurized drums had been assessed, e.g. temperature fluctuations,
the Licensee responded that over the years of operation no incident of an overly pressurized drum
has occurred nor has there been any indication of drums experiencing increased pressurization;
therefore, no such assessment was deemed necessary. For the same reasons drums are not tested for
excessive pressure buildup in drums after packing.
Honeywell Yellowcake Project
This uranium recovery project involved the removal of yellowcake residues from shredded drums
originating from the Honeywell Inc's Metropolis, Illinois works. The drums once contained U3O8
(yellowcake) that had hardened and was not readily removable from the drums. The yellowcake
was separated from the drums by shredding the drums with the yellowcake contents. The shredded
drums had amounts of yellowcake residues adhering to the surfaces worthy of recovery. The drum
shreds were packaged (in drums) and sent to the Licensee for uranium recovery. There were
roughly 5000 drums sent for processing.
The process of "cleaning" the drum shreds of yellowcake was observed during the inspection. The
process is guided by procedures which are found in procedure manual No.: PBL-12, rev. No.: R-0,
Date: November 1, 2013. Procedure, Shredded Drum Acid Leach, provides step-by-step
instructions for handling the material. A sulfuric acid/sodium chlorate solution, described in
procedure, Shredded Drum Reagent Make-up, was added to the drums containing the drum shreds.
After the material is tumbled in the drums on an electric drum roller for approximately 30 minutes
the liquid containing the now dissolved uranium was drained from the drum and collected in a
sump. The liquid would then be pumped into the solvent extraction circuit for routine SX
(precipitation and drying) processing.
The drum rolling process began on November 11, 2013 and at the time of the inspection (March 20,
2014) approximately half of the inventory had been processed. The drum rolling apparatus could
accommodate six drums at a time. Setting and removing drums from the rolling device is labor
intensive; however, the operating design is such that the workers can perform the manual tasks
safely. Workers handled the drums relatively easily with the use of a hand truck/dolly. Proper PPE
was observed to be worn. The primary concern was the corrosivity of the solution added to the
drums. No radiological incidences were reported during the time since operations began.
Preliminary air sampling during the operations indicated that airborne contamination is not an issue;
therefore, no respiratory protection was required during operations based on the air sampling results.
After the liquid is drained from the drums, the drums with the shredded metal are transported to the
tailings cell for disposal.
Page 2 of 3
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-DRM-01\InspectionReportRev0.doc
The work area was organized and clean. A post inspection review of the work area photographs
indicate potential tripping hazards, e.g. hoses, electrical cords and drum lid on the floor.
Drum Management
Feed material drums are stored on a hard surface pad. Drums are stacked in an orderly fashion. A
Radiation Area was established around a portion of the stored drums. A number of drums in a
particular lot of feed material had reported exposure rates of 5.0 mR/hr at 30 cm from the surfaces
of the drums.
Drums are filled with yellowcake product in an enclosed area with a negative air pressure.
Respiratory protection is required in the area where the filling takes place. No activities were taking
place in this area at the time of the inspection.
Drums containing product yellowcake are stored in the product storage area on a hard surface. The
compound was locked; no activities were taking place. Drums which could be seen from outside
the compound were neatly arranged in lots within the compound. Drums are prepared for shipment
in this area. Each individual who prepares drums for shipment are trained in the process. The
training is documented on a declaration form which covers Product Preparation and Shipping
and Loading trailer and trailer preparation. Radiological surveys of the product drums are
performed in this area for transportation purposes.
Forklifts and flatbed trucks are utilized to transport drums from one location to another on the site.
A flatbed truck was observed transporting a load of drums. It did not appear that the drums were
secured to the vehicle in any manner. This was brought to the attention of the Licensee.
Conclusion
Drums containing material are handled and stored in a radiologically safe and compliant manner.
No issues were encountered in this regard during the inspection.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, R. Nieves, and D. Turk of Energy Fuels
Resources (USA) on March 20, 2014. Also in attendance was K. Carney of the DRC. The
observations described above were summarized during the meeting.
Recommendations for the Licensee
• Evaluate the method of transporting drums around the mill site. Determine if there is any
risk of drums sliding off or falling off of the transport vehicles. If necessary, take actions to
reduce risks.
• Maintain clear walkways at the drum rolling operations.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai March 28, 2013
(Name) Cy(Signature) (Date)
Page 3 of 3
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UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-DRM-01
DRUM HANDLING and MANAGEMENT
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
This inspection is focused on drum handling and management. A review of relevant procedures in this regard
will be performed. Applicable Radiation Work Permits are also to be reviewed. Placement in drums of
specific feed material processing will be assessed regarding unique characteristics of the feed material.
PRESSURIZED DRUMS
1) Was NRC's Information Notice 1999-03, REV 1 reviewed? Yes X No
Comments:
A^AArg^*vv- ya-vo-y /db? preem pt plWi^S V^S ^3^rLs4^^£ *~
2) Was a determination made regarding the relevance of the Information Notice 1999-03, REV 1 to drums
managed at the mill?
Comments: . Yes ,X No
3) Has the potential of drums becoming pressurized been assessed and evaluated at the mill site?
Yes X No
Comments:
4) What actions, if any, does the mill take to prevent drums from becoming pressurized?
Comments: < .
U^UJL &U*esA (ju\ A\SQJBS3 /^ou^b^Q^ sc~-J^c&^-*f ^^4^AMJ-^O
5) What are the procedures for drying and packing yellowcake into drums? (Drying times, moisture content
evaluation, time interval before closing and sealing drums, drum storage)
Vvifc pvsL^e^^A ^^OX^A r^yns^ j^WU:^^^ ^4V<A^/c^a5?^<y<K/6>-4^<^
U:\DIRECTOR\COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2014\RADMOD-DRM-01.docx
Dona 1 A
6) What are the procedures for closing and sealing drums containing yellowcake?
Comments: Q^L^
7) Are closed and sealed drums containing yellowcake checked/tested for increased internal pressures?
Yes NoA?
Comments: .
Mfe-V -^vc^u^-k *\X-*C ys, <s^ s^^^W^
8) What are the procedures to address pressurized drums?
Comments:
HONEYWELL YELLOWCAKE PROJECT
9) What is the status of the Honeywell Yellowcake Project?
Comments: - nil
|H pka6?5^ wJL*A*+*ck ^risx Jbr^AA^ ron/^ ^xx>ss
10) Due to the uniqueness of this project were special procedures implemented to process this material?
Yes /*C No
If not, are the procedures adequate to ensure safe handling of the material? f^Pr Yes No
Comments:
11) Is the yellowcake from Honeywell hydrogen peroxide precipitated? Yes No
Comments:
U:\DIRECTOR\COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2014\RADMOD-DRM-01.docx
12) Is there a potential for the drums containing the processed Honeywell yellowcake to become pressurized?
Yes No X"
Comments:
13) What RWP(s) govern(s) the Honeywell yellowcake processing work?
Comments: ((o//6/'3) n n
14) Are workers handling the Honeywell material wearing the appropriate PPE? Yes X. No
Comments: lit n
15) Are workers observed to be handing the Honeywell material safely? Yes X No
Comments:
r^YUA^ ./6-^O\A^ r&lVA kg-c^A^P o>-c^L ,
DRUM MANAGEMENT
16) What are the closing and sealing procedures for drums filled with yellowcake?
Comments:
17) Where are the yellowcake drums closed and sealed (processed ore and alternate feed)?
Comments:
U:\DIRECTOR\COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2014\RADMOD-DRM-01.docx
Dona 1 rsf A
18) Where and how are drums containing feed material stored?
Comments: «
19) Where and how are drums containing yellowcake product stored?
Comments:
20) How are drums filled with feed material moved around the mill site:
Comments: *
21) How are drums filled with yellowcake transported around the mill site?
Comments:
Comments:
U:\DIRECTOR\COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2014\RADMOD-DRM-01.docx
Dona /I y-*f A
NCH Survey
Exothermic Reactions Involving
Dried Uranium Oxide Powder
[Yellowcake]
SURVEY
Exothermic Reactions Involving Dried Uranium Oxide Powder (Yellowcake)
IN 99-03
Nuclear Regulatory Commission (NRC) management has decided to update Information Notice
- IN 99-03, "Exothermic Reactions Involving Dried Uranium Oxide Powder (Yellowcake)," to
notify the industry of events that have occurred since it was last updated in 1999. An Information
Notice (IN) is a type of generic communication that is issued to inform licensees and the public
of recently identified safety issues. As part of this process, NRC has formed a working group
which is tasked with updating IN99-03 with any new information that has become available.
No facility names or locations will be used in the final IN and every effort will be made to
properly control proprietary information. NRC intends to make a presentation on the findings of
the working group at the annual NMA/NRC meeting in early May 2013.
Thank you for your assistance and cooperation in this matter.
The questions are as follows:
1. What type of dryer do you run (e.g., vacuum, calciner, low temperature gas fired)?
1a. What is the name of the manufacturer, and what is the model number?
1b. How long has the dryer been in service?
1c. Does the drying process allow for off-gassing of the uranium yellowcake product prior to
being drummed?
2. What is the maximum dryer temperature during the yellowcake drying cycle?
2a. How long is the yellowcake dried at the maximum dryer temperature?
2b. Is the dryer temperature constant during the entire drying cycle? If not, what is the total
drying time?
2c. Is maximum yellowcake product temperature measured directly, and if so, what is it?
3. Have you experienced any pressurized yellowcake barrels since 1999? If so, when was
it and what was the resolution?
3a. Did you identify the causes of the pressurized drums?
4. Did you make any procedural or chemical changes in the uranium oxide
production/precipitation step in your process since 1999, as a result of the publication of
IN 99-03? If so, what were the changes and effects?
5. Do you add hydrogen peroxide to the process, and does it carry over into the end
product?
5a. Please describe your precipitation process including chemicals used and temperature of
precipitation.
1
5b. Do you test the wet and dry yellowcake product for hydrogen peroxide concentrations? If
so, what were the results?
6. Did you make any procedural changes in your process, particularly the drying stage
since 1999, as a result of the publication of IN99-03? If so, what were the changes?
7. Packaging of yellowcake: Have you made any changes in your packaging of yellowcake
since 1999, as a result of the publication of IN 99-03?
7a. Have there been any changes in barreled yellowcake cooling time (before sealing) since
1999?
7b. What is the cooling time?
7c. Have there been any changes in barrel handling, attention to seals, or barrel
maintenance since 1999?
7d. Do you know the temperature of the yellowcake product when it is placed into the
barrel?
7e. Do you measure the moisture content of the final yellowcake product? What is the range
of these measurements? Is there an upper limit for moisture content?
8. Have there been any changes in dryer maintenance since 1999?
8a. Have you experienced an exothermic reaction in the yellowcake product due to
hydrocarbons in the product?
8b. Has there been any special attention given to hydrocarbon contaminants from the
processing tanks, piping, dryer, and barrels?
8c. Do you recycle sump water in the process circuit, and do hydrocarbons have the
potential of entering the sump?
8d Do you use new or reconditioned drums for shipping yellowcake? If reconditioned
drums are used, do you know what process is used for reconditioning and do you perform
any checks on the drum prior to use?
8d. Have you experienced a chemical or exothermic interaction between the yellowcake and
the surfaces of the drum, or from cleaning agents/contaminants on the internal drum
surfaces? If so, please explain.
9. Please provide any other pertinent comments regarding this topic.
Paperwork Reduction Act Statement
This survey contains information collections that are covered by the Office of Management and Budget
clearance number 3150-0008, which expires 05/31/2013. The information provided will be used by the
2
Nuclear Regulatory Commission to inform licensees and the public of recently identified safety issues.
The burden to the public for these voluntary information collections is estimated to average 4 hours per
response, including the time for completing and submitting the information collection. Send comments
regarding this burden estimate or any other aspect of these information collections, including
suggestions for reducing the burden, to the Information Services Branch (T-5 F53), U.S. Nuclear
Regulatory Commission, Washington, DC 20555-0001, or by email to
[e-mail]: and to the Desk Officer, Office of Information and Regulatory
Affairs, NEOB-10202, (3150-0008) Office of Management and Budget, Washington, DC 20503.
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number.
NRC Information Notice
1999-03, RBI. 1
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF FEDERAL AND STATE MATERIALS
AND ENVIRONMENTAL MANAGEMENT PROGRAMS
WASHINGTON, D.C. 20555
March 4, 2014
NRC INFORMATION NOTICE 1999-03, REV. 1: EXOTHERMIC REACTIONS INVOLVING
DRIED URANIUM OXIDE POWDER
(YELLOWCAKE)
ADDRESSEES
All operating uranium recovery facilities that produce uranium oxide powder (yellowcake). All
Agreement States with the authority to regulate uranium mills (i.e., Utah, Colorado, Texas, Ohio,
Illinois, and Washington).
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this Information Notice (IN) to alert
licensees to recent events involving pressurized drums of dried uranium oxide powder
(yellowcake). This IN is a revision to IN 99-03 which previously discussed industry experience
with pressurized 208-liter (55-gallon) metal drums (hereafter referred to as drums) and related
exothermic reactions involving yellowcake material. It is expected that recipients will review this
information for applicability to their licensed activities and consider actions, as appropriate, to
avoid similar problems. However, suggestions contained in this IN are not NRC requirements;
therefore, no specific action or written response is required.
DESCRIPTION OF CIRCUMSTANCES
The NRC is aware of at least nine different sites that have encountered problems with
pressurized drums. A brief description of two events is provided below. Both events resulted in
uptakes of uranium by workers, and both have similar root causes.
In 2006 at a conventional mill, a worker attempted to open a drum filled with yellowcake that
exhibited bulging. Unbeknownst to the worker, the sealed drum was pressurized. The pressure
was apparently caused by the generation of oxygen gas within the drum from the decomposition
of hydrogen peroxide precipitated yellowcake product. When the drum sealing bolt was
loosened, the pressure in the drum caused the lid to blow off the drum and strike the worker.
The worker received an uptake of uranium, although the uptake was less than regulatory limits.
Records indicate that the drum lid had remained unsealed for three hours after the drum had
been filled with yellowcake product, as required by site procedures.
ML14028A175
IN 1999-03, Rev. 1
Page 2 of 5
The facility operator conducted an investigation and identified the root cause as less than
adequate procedures. The facility operator concluded that the product did not completely cool,
or off-gas, within the three-hour time interval. Corrective actions included revising the
applicable procedure to extend the drum sealing interval from three to four hours and providing
additional training to site workers.
The second incident occurred in 2012 at a uranium refinery in Canada while workers were
opening a drum of yellowcake supplied by an in-situ uranium recovery facility. When a refinery
worker loosened the ring clamp on the drum lid, the pressure in the drum (produced by an
unexpected build-up of oxygen gas) caused the lid to buckle. The escaping gas ejected
approximately 20 kilograms (44 pounds) of dried, powder-like yellowcake material from the
drum. The incident resulted in three refinery workers receiving uptakes of uranium. The
refinery operator subsequently identified several other drums, supplied by the same uranium
recovery facility, which also showed signs of internal pressurization. The uranium recovery
facility operator conducted an investigation to determine the causes of the pressure buildup in
the drums. The facility operator concluded that the drums became pressurized due to:
(1) inadequate cooling and venting of the dried yellowcake product priorto sealing the drum lid;
and (2) inadequate drying of the yellowcake product (i.e., inadequate dryer residence time).
The NRC later determined that inadequate procedures were contributing causes of the event.
BACKGROUND
The NRC issued IN 99-03 on January 29, 1999, to alert licensees to incidents involving
exothermic reactions that occurred after packaging hydrogen peroxide precipitated yellowcake
powder into drums. The original IN discussed two types of exothermic reactions—oxygen
generation as a byproduct of the drying process and hydrocarbon contaminants reacting with
the yellowcake product. At that time, industry took corrective actions which included leaving the
drums unsealed for a minimum of three hours and preventing oil and grease from being
introduced into the precipitation and drying circuits.
Since 1999, the uranium recovery industry has experienced several more pressurized drum
events. Because these events continued to occur, the causes may not be well understood by
the industry. Further, past actions taken by industry to prevent pressurized drums may not have
been fully effective.
The IN 99-03 also advised facility operators about exothermic reactions of yellowcake with
organic materials. These reactions can cause spontaneous combustion of flammable materials
such as oil that may enter the process circuit. Refer to Enclosure 1 for an expanded discussion
of this hazard.
DISCUSSION
In both the 2006 and 2012 instances, the fundamental cause of the pressurized drums was
attributed to the build-up of oxygen gas in sealed containers. The oxygen gas apparently
originated from the decomposition of residual uranyl peroxide hydrates or hydrogen peroxide in
the dried yellowcake product. Both incidents indicate that the drum lids may have been sealed
onto the drums prior to the completion of the uranyl peroxide hydrate decomposition process.
Both sites used a minimum three-hour time delay as mentioned in IN 99-03; however, this time
delay must have been insufficient based on site-specific operational parameters.
IN 1999-03, Rev. 1
Page 3 of 5
In early 2013, the NRC established a working group to: (1) review the generic implications of the
most recent pressurized drum incident including the reasons why drums continue to become
pressurized; (2) identify industry experience with pressurized drums; and (3) ascertain whether
there were any related trends across the industry. The working group consisted of NRC staff,
industry representatives, and subject-matter experts. The NRC used the findings of the working
group, as well as information solicited from 14 current and former uranium recovery facilities, in
the development of this revision to IN 99-03. As part of the revision process, the NRC is also
correcting some of the chemical nomenclature used to describe the thermal decomposition
process provided in the original IN. More importantly, as a result of industry experience gained
since the NRC issued IN 99-03, this revised IN recognizes a broader range of relevant factors
that could result in pressurized drums.
The working group developed a questionnaire that was submitted to various national and
international companies having direct experience processing or handling yellowcake. The
working group received 14 responses from various entities. The responses were subdivided
into two basic categories—sites using ammonia precipitation circuits and sites using hydrogen
peroxide precipitation circuits. The survey responses provided the working group with detailed
information about dryer and packaging operations at each site as well as industry experience
with pressurized drums. If the facilities had experienced pressurized drum problems, the survey
asked the respondents to explain the possible causes for the pressurizations. As discussed in
Enclosure 1, sites using the ammonia precipitation process with high-temperature calciners
have not experienced pressurized drums. Only sites using the hydrogen peroxide precipitation
circuits have experienced pressurized drums. Enclosure 3 provides a matrix of the operating
parameters for the 11 sites using hydrogen peroxide precipitation circuits and the suspect
causes of past drum pressurizations.
The working group concluded that many drum pressurizations were apparently caused by
changes in the chemical composition of the yellowcake product after it had been placed into a
sealed container. The level of pressurization appears to be related to the cooling and venting
time of the product prior to sealing of the drum. The working group determined that the
minimum required cooling and venting time for recently dried yellowcake in an unsealed drum
depends on the type of dryer, drying temperature, residence time (time product remains in
dryer), hold-up time (time interval between completion of drying cycle and when product is
placed into drum), dryer feed rate, and product moisture content. These various operational
parameters may ultimately contribute to oxygen gas buildup in yellowcake drums.
As noted earlier, multiple operators reported that they had experienced pressurized drum
problems, but the specific chemical reactions causing the pressurizations were not always clear.
In their survey responses, facility operators provided two general corrective actions to address
the pressurized drum issue—increasing the cooling/venting time before the lid is sealed onto the
drum and conducting visual inspections of the drums for signs of pressurization prior to
shipment. These operators found that increasing the cooling and venting time before sealing
the drums and inspecting the drums before shipment appear to have resolved the problem. A
range of cooling and venting times was reported, from 4 to 24 hours (see Enclosure 3). In
several instances, facility operators chose to extend the cooling and venting times in response
to past experiences with pressurized drums. Each facility operator should evaluate their
operations and decide how to implement site-specific corrective actions as necessary to prevent
pressurized drums.
IN 1999-03, Rev. 1
Page 4 of 5
The working group found that many operators did not measure their product temperature
directly, and that discrepancies existed between the maximum dryer temperature and the
chemical composition of their final product. It is product temperature, not dryer temperature,
which ultimately drives the thermal decomposition process. The working group concluded that,
for typical U.S. facilities utilizing hydrogen peroxide precipitation and drying temperatures below
800 degrees Celsius (°C) [1472 degrees Fahrenheit (°F)], a cooling and venting period of 12 to
24 hours appears sufficient to prevent oxygen gas buildup in yellowcake drums. Above dryer
temperatures of approximately 800 °C (1472 °F), it is expected that the uranyl peroxide product
will be converted to U03 (uranium trioxide) product. Oxygen production is not expected to occur
after the uranyl peroxide product has been completely converted to U03 product. For dryers
operating below 800 °C (1472 °F), shorter periods of yellowcake cooling and venting priorto
securing the drum lid may be ineffective to prevent oxygen buildup in sealed drums.
CONCLUSION
Based on its working group findings and questionnaire responses, NRC concludes that:
• The most likely cause for the drum pressurization events was attributed to continued
decomposition of dried uranium product and the production of oxygen after the drums have
been filled and sealed.
• For facilities utilizing hydrogen peroxide precipitation and drying temperatures below 800°C
(1472°F), a cooling and venting period of at least 12 hours appears to be necessary to
prevent oxygen gas build-up in yellowcake drums. Shorter periods may be ineffective.
Many operators have elected to implement a cooling and venting time of 24 hours.
• To prevent drum pressurizations, facility operators have implemented two basic corrective
actions—increasing the cooling/venting time before the lid is sealed and conducting visual
inspections of the drums for signs of pressurization prior to shipment.
• Facility operators should evaluate the potential for organic-based exothermic reactions, as
discussed in Enclosure 1. Facility operators should develop protocols to minimize the
potential for organics, including oils and greases, to enter into yellowcake process circuits.
• In addition to being industrial and radiological hazards to workers, shipments of uranium
yellowcake in packages with internal pressures that reduce the effectiveness of the
packages are prohibited by U.S. Department of Transportation regulations. Enclosure 1
provides additional information about these regulations.
fgf W IN 1999-03, Rev. 1
Page 5 of 5
CONTACT
This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts listed
below.
/RA Aby Mohseni for/
Larry W. Camper, Director
Division of Waste Management
and Environmental Protection
Office of Federal and State Materials
and Environmental Management Programs
Contacts: Robert Evans, Region IV
[phone]
[e-mail]
Ronald Burrows, FSME
[phone]
[e-mail]
Thomas McLaughlin, FSME
[phone]
[e-mail]
Enclosures:
1. Detailed Technical Discussion
2. Bibliography
3. Survey Results for Facilities Using Hydrogen Peroxide Precipitation
4. FSME Recently Issued Generic Communications
ML14028A175
RIV:DNMS/RSFS C:DNMS/RSFS DD:DNMS D:DNMS
RJEvans DBSpitzberg VHCampbell AVegal
IRA/ Via email Via email Via email
10/24/13 11/06/13 01/02/14 12/31/13
FSME:DMSSA FSME:DWMEP DWMEP/DURLD C:DWMEP/DURLD
ARMclntosh RABurrows TGMcLaughlin BvonTill
Via email Via email Via email Via email
10/24/13 10/28/13 10/28/13 10/29/13
NSIR FSME:DMSSA FSME:DILR OGC/GCLR/RMR
CGrigsby DWhite JCai TLStokes
Via email Via email Via email Via email
10/28/13 10/24/13 11/05/13 12/17/13
OE/EB NMSS DD:DWMEP/DURLD D: MSSA
TMarenchin HJGonzalez DPersinko JMoses for
LDudes
Via email Via email /RA/ IRA/
11/14/13 11/08/13 01/24/14
D:DWMEP
AMohseni for
LWCamper
/RA/
03/04/14
02/28/14
OFFICIAL RECORD COPY
IN 1999-03, Rev. 1
Page 5 of 5
CONTACT
This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact one of the technical contacts listed
below.
/RA Aby Mohseni for/
Larry W. Camper, Director
Division of Waste Management
and Environmental Protection
Office of Federal and State Materials
and Environmental Management Programs
Contacts: Robert Evans, Region IV
[phone]
[e-mail]
Ronald Burrows, FSME
[phone]
[e-mail]
Thomas McLaughlin, FSME
[phone]
[e-mail]
Enclosures:
1. Detailed Technical Discussion
2. Bibliography
3. Survey Results for Facilities Using Hydrogen Peroxide Precipitation
4. FSME Recently Issued Generic Communications
IN 1999-03, Rev. 1
Enclosure 1
Page 1 of 7
Detailed Technical Discussion
At least nine uranium recovery facilities have experienced pressurized drum events. The
reasons for these pressurization events varied from facility to facility (see Enclosure 3 for a
complete list of suspected causes for the drum pressurizations). The actual causes of previous
drum pressurization events are still in question. The causes may include the decomposition of
free hydrogen peroxide (H202) carried over with the dried yellowcake, decomposition of uranyl
peroxide product, production of steam from residual water, reaction of uranium compounds with
inorganics, or perhaps a combination of these causes. In addition, a reliable and accurate
chemical test for free hydrogen peroxide in yellowcake has not been validated which would
allow facilities to precisely determine the actual causes for these types of incidents.
The NRC's working group identified several topics that are discussed in detail below. The
working group's findings are based on the information that was identified or made available to
the group, in part, through uranium recovery facility responses to surveys. Two of the 14
surveys were conducted for sites that are no longer in service, meaning that some of the
information presented in the survey may be based on individual recollections versus formal
documentation.
Precipitation with Ammonia and Use of a Calciner to Dry Yellowcake
Three facility operators out of 14 reported using ammonia precipitation instead of hydrogen
peroxide precipitation. These operators also dried their precipitated product at high
temperatures in a calciner. There was no evidence that the ammonia precipitation process, in
combination with a calciner, had ever resulted in pressurized drums. Therefore, these types of
facilities are excluded from the current discussion about H202 precipitated product.
The Chemistry of Hydrogen Peroxide Precipitated Yellowcake
Facilities using the hydrogen peroxide precipitation process may create pressurized drums if
their operational processes are not appropriately controlled. The chemical product of
precipitation depends on the temperature of the solution undergoing precipitation. Based on the
survey results, hydrogen peroxide precipitation typically occurs under ambient conditions. At
temperatures below 50°C (122°F), the precipitate is generally of the form U04 • 4H20 (uranyl
peroxide tetrahydrate). The final desired product is U04 • 2H20 (uranyl peroxide dihydrate).
Converting the tetrahydrate form (U04 • 4H20) of uranyl peroxide to the desired dihydrate form
(U04 • 2H20) occurs quickly under typical drying conditions. For example, laboratory samples
of U04 • 4H20 will dehydrate to U04 • 2H20 in about one hour when dried at 100°C (212°F)
(product temperature, not dryer temperature). Typical maximum dryer temperatures at facilities
using hydrogen peroxide precipitation range from 130°C (266°F) to 649°C (1200T), with most
facilities operating well below 300°C (572°F). Of course, laboratory studies do not take into
account industrial scale production issues such as difficulty in ensuring uniform drying
temperature of the product and desired moisture content. The composition of the final product
will depend on a variety of drying conditions including dryer temperature, heating time, heating
rate, feed rate, product temperature, water content, hydrogen peroxide content, pressure, etc.
As a result of all of these variables affecting the final product, it is likely that other chemical
species are forming. The compound U04 • 2H20 does not undergo dehydration like U04 •
IN 1999-03, Rev. 1
Enclosure 1
Page 2 of 7
4H20, but rather loses oxygen and water simultaneously (i.e., it decomposes to another
compound). Uranium trioxide (U03) will form at around 500°C (932°F) (product temperature),
so for most facilities this reaction is not expected to occur. However, a range of uranium
compounds between U04 • 2H20 and U03, are likely to form under current typical drying
temperatures and drying times. As a group, these intermediate compounds are referred to as
amorphous UOx, where (3<x<3.5). While U04 • 2H20 is considered the most stable form of
uranyl peroxide, amorphous UOx is considered unstable with respect to the decomposition to
U03 even at room temperature. Table 1 demonstrates one example of dryer temperature
versus product formation.
Table 1
Drying Temperature and product composition: Phases identified in hydrogen peroxide
precipitated yellowcake dryer product by X-ray diffractometry"
Sample
ID
Dryer
Discharge
Temperature
ro
U04-2H20 Am<j;Phous U0;
525
575
625
769
empty cells indicate not detected
In addition, amorphous UOx has been reported to react with free water to liberate oxygen gas.
It is not clear whether this is a reaction resulting in U03, or some other type of reaction.
Experiments to date have demonstrated this effect by mixing relatively large amounts of water
with amorphous UOx. Figure 1 demonstrates this phenomenon. It is unknown what effect
residual moisture at levels typical of uranium recovery facilities has on amorphous UOx. It has
also been found that neither U04 • 2H20 nor U03 react with water in this manner.
IN 1999-03, Rev. 1
Enclosure 1
Page 3 of 7
Figure 1
Product chemistry: Dried hydrogen peroxide precipitated yellowcake reactivity with water
ve with
10Q 150 200 250 300
Outlet Prodyct
$00
Addition of Excess Hydrogen Peroxide During Precipitation Process
A stoichiometric excess of hydrogen peroxide is required to optimize precipitation of uranyl
peroxide yellow cake. The degree of excess is determined by the composition of the uranium
bearing solution (feed stock for precipitation). Molybdenum, vanadium, and other reactive
metals contained in the feed stock react with hydrogen peroxide to form soluble complexes. In
addition, some fraction of hydrogen peroxide may decompose during the precipitation process.
Facility operators should be aware that some of this excess hydrogen peroxide may be carried
over into the drying process. The working group understands that an effective drying cycle
should eliminate this excess hydrogen peroxide.
Stability of Hydrogen Peroxide in the Presence of Uranyl Peroxide Solids
Precipitation of dissolved uranium by the addition of hydrogen peroxide is a well-known and
common process within the uranium recovery industry. It has been demonstrated that this
precipitation process is a reversible chemical reaction. One consequence is that an excess of
dissolved hydrogen peroxide must be maintained in solution to drive the precipitation reaction to
completion and, hence, to minimize dissolved uranium losses in resulting waste streams. The
use of excess hydrogen peroxide is a common practice in the uranium industry where the
maintenance of low uranium tails in the precipitation process is desired. The filtrate fluids
associated with the resulting uranyl peroxide slurry must also contain a modest but finite
concentration of dissolved hydrogen peroxide to avoid dissolution of uranyl peroxide solids. As
a result, moist uranyl peroxide slurries entering any drying equipment may contain a small but
finite concentration of dissolved hydrogen peroxide.
IN 1999-03, Rev. 1
Enclosure 1
Page 4 of 7
Industrial hydrogen peroxide solutions are relatively stable as long as they are properly stored at
moderate temperatures, maintained at a pH below 5, and do not come into contact with
impurities, especially metals. Uranyl peroxide solids are typically precipitated at low pH (2-4)
under ambient conditions in the presence of small amounts of excess hydrogen peroxide. The
resulting slurries are usually pressed and washed at ambient conditions in a filter press
operation to remove soluble filtrate impurities from the filter cake. The acidity of the wet cake
will likely remain low keeping any residual free hydrogen peroxide relatively stable. This free
hydrogen peroxide will, however, begin to decompose over time to oxygen gas and water as it
remains in contact with the uranyl peroxide solids. The rate of this decomposition is unknown
and, if a test were to be performed to measure residual free hydrogen peroxide, it would have to
be performed on fresh uranyl peroxide solids to minimize the subsequent decomposition of
hydrogen peroxide. This may explain why it has been difficult to measure free hydrogen
peroxide in filter cake samples as the time to perform the tests might be too long for the
hydrogen peroxide to remain stable and not decompose.
The other condition under which hydrogen peroxide can decompose is elevated temperature.
Hydrogen peroxide will slowly decompose at room temperature. The rate of decomposition will
increase as temperature increases. If any free hydrogen peroxide enters the dryer it will likely
decompose as the temperature of the uranyl solids increases. However, if the free hydrogen
peroxide fails to instantly decompose upon entry into the drying chamber, the residual hydrogen
peroxide may be captured in the uranyl peroxide crystalline structure during the drying process.
Facility operators should try to minimize the amount of residual free hydrogen peroxide in the
product prior to the drying process.
Drying Temperature of Uranyl Peroxide in Rotary Vacuum Dryers
While different dryer types and precipitation processes are utilized in the industry, the majority of
facility operators uses hydrogen peroxide precipitation and employs some type of rotary vacuum
dryer that operates at a relatively low temperature. These systems are typically batch
operations with ambient temperature yellowcake slurry introduced into a pre-heated chamber at
atmospheric pressure. The chamber is then sealed and depressurized. The sub-atmospheric
pressure within the chamber (i.e., the vacuum) does not remain constant during the drying
cycle. Rather, the pressure continuously decreases as water vapor is liberated and evacuated
from the chamber via the vacuum pump circuit. The vapor capacity of the vacuum pump limits
the operational vacuum (pressure) within the chamber. During the period in which boiling of
free moisture is the principle process within the drying chamber, the temperature of the
yellowcake solids is tied to the boiling point of water at that pressure. Near the end of the drying
cycle, sufficient free moisture has been removed and the pressure within the chamber
decreases and approaches a steady state. As this condition is reached, the yellowcake
temperature rapidly rises toward the temperature of the heating surfaces within the drying
chamber. Essentially, there are two phases to the batch vacuum drying cycle. The first is
controlled by the temperature-pressure relationship of boiling water and the capacity of the
vacuum pump to remove water vapor. In the second phase, the vacuum pump vapor capacity
is no longer limiting and the temperature of the solids is controlled by heat transfer between the
vessel surfaces and the yellowcake solids.
Regardless of the temperature of the dryer, there is still a minimum time necessary where
moisture is driven off before the yellowcake is heated to above 100°C (212°F), the point where
U04 • 2H20 starts to be created. Continued heating of the product can therefore lead to
IN 1999-03, Rev. 1
Enclosure 1
Page 5 of 7
conversion to hydrated U04 (uranyl peroxide); however, there is likely limited time for conversion
of U04 to UO3 (uranium trioxide). As such, any remaining U04 that does not convert to the
more stable U03 could lead to drum pressurization. Therefore, it is important for facility
operators to control the drying process parameters, including temperature, to control product
chemistry.
Potential Reactions for Uranyl Peroxide Yellowcake in the Presence of Organic Matter
Five of 11 respondents that used hydrogen peroxide (H202) precipitation process reported that
they have experienced exothermic reactions in yellowcake due to organic contamination, and
five of 11 reported that they pay special attention to hydrocarbon contamination.
The reaction of H202with organics is a well-known but complex reaction. When H202is in the
presence of most organic matter, the hydrogen peroxide can react with the organic to form
organic peroxide compounds which are usually unstable or can cause the organic to be
oxidized, i.e., "chemically burned." When organic peroxide compounds are formed they have
been known to detonate, i.e., cause spontaneous combustion or cause oxidation reactions to
occur. These latter reactions result in the evolution of heat (from the "burning" of the organics)
and the evolution of C02 (carbon dioxide), CO (carbon monoxide), and H20 (water) depending
upon the completion of the reaction. When hydrogen peroxide reacts in this way with organics
there is always a signature gas evolution which will be indicative of the reaction taking place.
Under certain conditions of temperature, metal catalysts, and reactant concentrations, organics
can react with the hydrogen peroxide. This interaction results in a complex, multi-step reaction
which typically forms many intermediate hydroxyl radicals as the oxidation reaction is on-going.
This process can be simplified as follows:
H202+ Organics (CxHy) ->A-»B ->C... ->C02 + CO + H20 + Heat
Where A, B, C, etc. are the intermediate compounds that form prior to full oxidation (compounds
that contain OOHor OH" radicals). The end result of this chain of reactions is that the organic is
"chemically burned" and the signature off-gases of this reaction are C02 + CO + H20 plus heat.
When these intermediate compounds form, they combine unstably bound oxygen together with
hydrogen and carbon in the same molecule, and these organic peroxides can ignite easily and
burn rapidly and intensely. When organic peroxide begins to decompose, the heat produced by
its decomposition may not dissipate as quickly as it is generated which can result in increasing
temperatures which further intensifies the rate of exothermic decomposition. This can create a
dangerous situation known as a self-accelerating decomposition.
When wet yellowcake is introduced into a dryer system it is important that the product not
contain organic matter as the reactions of any residual H202or decomposed uranyl peroxide
hydrate can occur. For trace amounts of organics, this will likely not be an issue as the dryer
can dissipate any heat that is formed by these reactions, or the organic will be driven off by the
heat of the drying operation. If, however, larger amounts of organics were to be introduced into
the dryer, a self-accelerating reaction can occur where the heat cannot be dissipated, high
temperatures are generated, and a violent reaction is possible. This has occurred in some dryer
facilities when there was a mechanical failure in the dryer which caused large quantities of
organics such as oil to be introduced into the dried yellowcake at elevated temperatures.
IN 1999-03, Rev. 1
Enclosure 1
Page 6 of 7
If the yellowcake is dried at high temperatures as in a calciner, the problem of organic reactions
is less likely since the higher temperatures encountered in the dryer will drive off the volatile
organics and decompose any organic peroxides that might have been formed. In a low
temperature dryer, some organics can remain with the dried uranyl peroxide hydrates and
become unstable in the dryer or when removed from the dryer. This could have consequences
for drummed material as the decomposition of any organic peroxide can generate heat plus
C02, CO, and H20. The consequence of this could be the slow generation of combustion gases
(for small amounts of organics) or a more violent reaction if large amounts of organic peroxides
begin to decompose and generate heat which can cause a self-accelerating reaction to occur.
In summary, facility operators should be aware that organic reactions are possible with
yellowcake product, and operators should try to locate and eliminate potential sources of
organic matter from entering into the precipitation and drying circuits.
Packaging (Drumming) of Yellowcake
Dried yellowcake is almost exclusively stored and shipped in 208-liter (55 gallon) steel drums.
In the U.S., the drums must meet U.S. Department of Transportation specifications if the facility
operator plans to ship yellowcake material in the drums. Facilities use new drums,
reconditioned (used) drums, or a combination of both, depending on drum availability and/or
cost. It is critical that operators ensure that drums used to ship yellowcake do not have any
organic material (such as oil or grease) in them. Employees must be trained and informed
about the serious complications of organic material in drums to ensure that drums used for
shipment are received from the suppliers in acceptable condition and the facility does not
inadvertently use such drums for another purpose that could result in organic material
contamination prior to filling with yellowcake.
Information Notice 99-03 cautioned that new drums and lids could be a potential causal factor in
drum pressurization incidents due to the tighter seal of such drums compared to reconditioned
drums and lids. The tighter seal could prevent the off gassing from escaping the drum, thereby
leading to pressurization. Although this condition is still possible with new drums or
reconditioned drums that happen to have better seals, the working group believes that
appropriate controls, such as adequate cooling and venting times, will prevent any significant
potential for gas build up and drum pressurization.
To limit the potential of shipping a drum of yellowcake that has been pressurized due to an
unexpected cause, including a human factor, it is strongly suggested that operators include as
part of their final pre-shipment inspection a procedure to check each drum for pressurization.
This can be accomplished by a visual inspection of drum lids and a physical check by pushing
on the lid and checking for deflection and/or tapping the lid with a rubber mallet to assess
deflection and the tone resulting from the tapping. Any drums suspected of pressurization
should be returned to the drumming area and carefully depressurized and opened to confirm
conditions and causes, if appropriate. Operators should also develop controls to manage the
risk of the addition of excess free moisture/water to open drums of product. The working group
is aware that one study indicated that pressure is generated from the addition of water into
amorphous product. For example, operators should avoid spraying unsealed drums with water
to avoid the possibility of adding free water to the dried product.
IN 1999-03, Rev. 1
Enclosure 1
Page 7 of 7
Shipment of Pressurized Drums
A facility operator who ships pressurized drums may be in violation of U.S. Department of
Transportation regulations. In particular, the shipment of pressurized drums may violate
regulations 49 CFR 173.24(b)(3) and 49 CFR 173.475(a). Regulation 173.24(b)(3) states that
there will be no mixture of gases or vapors in the package which could, through any credible
spontaneous increase of heat or pressure, significantly reduce the effectiveness of the
packaging. Regulation 173.475(a) states that, before each shipment of any Class 7
(radioactive) materials package, the offeror (the facility operator who offers the drum for
shipment) must ensure, by examination or appropriate tests, that the packaging is proper for the
contents to be shipped. Based on these two regulations, a standard metal drum may not be the
proper package for pressurized uranium product because the pressurization reduces the
effectiveness of the packaging. Further, the packaging process may be inadequate if it allows
gases and vapors to increase the internal pressure of the package (the drum), resulting in rapid
and uncontrolled depressurization when the package is opened.
Facility operators should also be aware of regulation 49 CFR 173.22(a)(4). This regulation
requires persons who offer hazardous material for transportation to comply with the
manufacturers' instructions for packaging. This regulation applies to drums that have been
certified by the Department of Transportation and marked or stenciled accordingly. Many drum
manufacturers provide specific instructions for proper closure of the drum, including a
requirement to torque the drum seals. Facility operators should be aware of any specific
closure instructions provided by the manufacturer or distributer of their certified drums, if these
drums are used to transport yellowcake material.
Suggestions for the Uranium Recovery Industry
The working group suggests that the information presented in this IN be supplemented by the
uranium recovery industry. The working group suggests that the industry consider expanding
the information by determining the chemical species of their product, product temperature
versus holding time prior to sealing, impact of excess hydrogen peroxide on the decomposition
process, rate of moisture reduction in the dryer, optimum drying parameters (feed rate,
temperature, and residence time), and development of procedures and training program to alert
workers of the potential risks. For example, facility workers should be made aware that drying is
a dynamic process and the change of any process parameter, such as feed rate or dryer
temperature, may result in a product that is incompletely dried. Facility operators should use
this information to establish site-specific parameters to assure that drum pressurizations do not
occur.
Facility operators should consider establishing procedures or other protocols to identify and
manage pressurized drums. These procedures should include inspections of the drums for both
pressurization and integrity prior to transport. This inspection should be complete even if the
drum is stored for an extended period of time prior to actual shipment. Finally, the receiver of
shipped drums should also inspect drums for pressurization upon receipt and before opening a
sealed drum.
IN 1999-03, Rev. 1
Enclosure 2
Page 1 of 2
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IN 1999-03, Rev. 1
Enclosure 2
Page 2 of 2
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Rich, R. L. (2007). Inorganic reactions in water. Berlin: Springer-Verlag.
Rodgers, C, & Dyck, B. (2012). Uranium peroxide precipitate drying temperature relationships.
CIM Journal 3(3), 149-156.
Sato, T. (1961). Uranium peroxide hydrates. Die Naturwissenschaften 48(21), 668.
Sato, T. (1963). Preparation of uranium peroxide hydrates. Journal of Applied Chemistry 13(8),
361-365.
Sato, T. (1976). Thermal decomposition of uranium peroxide hydrates. Journal of Applied
Chemistry and Biotechnology 26(4), 207-213.
Silverman, L. & Sallach, R. A. (1961). Two uranyl peroxides. Journal of Physical Chemistry
65(2), 370-371.
Thein, S. M., & Bereolos, P. J. (2000). Thermal stabilization of233U02, 233U03, and233U308,
Report ORNL/TM-2000/82. Oak Ridge, TN: Oak Ridge National Laboratory.
Walenta, K. (1974). On studtite and its composition. American Mineralogist 59, 166-171.
The data for Table 1 comes from "Laboratory Characterization of Dryer Test Products," Cameco
Corporation, Gerhard Heinrich, John Krause, Mike Murchie, November 2009.
The data for Figure 1 comes from "Laboratory Characterization of Dryer Test Products,"
Cameco Corporation, Gerhard Heinrich, John Krause, Mike Murchie, November, 2009 but was
adapted and updated for a presentation to the CNSC: "Rabbit Lake UOC Drying Process,"
Cameco Corporation, Kirk Lamont, November 2012.
IN 1999-03, Rev. 1
Enclosure 3
Page 1 of 1
Time in Dryer
(hours)
12-16
Dryer
Temp (°C)
232
Survey Results for Facilities Using Hydrogen Peroxide Precipitation
Cooling and Percent (%) Have You Experienced
Venting Moisture in Dried Any Drum
Time (hours)* Yellowcake Pressurizations?
Yellowcake Temp
(°C) When
Barreled
Not measured
Suspected Causes of
Drum Pressurizations
>12 0-1.5
Limit of 2
No
18-20 164 130 24-72 <1 Yes Decay of residual H202
36-48 160 160 24 <1 Yes Not determined
21-22 163 138 24 1-8,
Typically
3-5
Yes Moisture vaporizing
(steam)
130 <80 Described as
"minimal"
<2 No
16-20 235 Not measured >12 0.5-1.5
Limit of 2
Yes Decay of H202 and
sealing drums too soon
4.5-6 649 66 Previously 3,
changed to 24
1-4 Yes Cooling time and drying
time too short
371 < 371 "no moisture" Yes Decay of H202
Unknown Not given Unknown 'a number of
hours"
Not measured Yes Excess H202 added
during precipitation
20-30 150 <90 12 1 -4 w/w Yes Hot yellowcake added
to moist drum
1.5 245 80 >3 0.5-2.0 Yes Unknown
* Cooling and venting times are current times, or the most recent times for facilities that are no longer in operation. Several sites increased their
cooling and venting times in response to previous pressurized drum events or in response to IN 1999-03.
IN 1999-03, Rev. 1
Enclosure 4
Page 1 of 2
List of Recently Issued Office of Federal and State Materials
and Environmental Management Programs Generic Communications
Date GC No. Subject Addressees
11/15/2013 IN-2013-22 Recent Licensing
Submittals Containing
Personally Identifiable
Information
All materials licensees, certificate
holders, applicants, and other
entities subject to regulation by the
U.S. Nuclear Regulatory
Commission for the use of source,
byproduct, and special nuclear
material. All Radiation Control
Program Directors and State
Liaison Officers.
10/17/2013 RIS-2013-17 Resuming Normal
Interactions Between the
NRC and NRC
Stakeholders Following an
Agency Shutdown
All U.S. Nuclear Regulatory
Commission (NRC) licensees,
certificate holders, permit holders,
and applicants; all Agreement and
Non-Agreement States, and State
Liaison Officers; and other
interested stakeholders.
10/09/2013 RIS-2013-16,
Supp. 1
Interactions Between the
NRC and NRC
Stakeholders During a
Lapse of Agency
Appropriations
All U.S. Nuclear Regulatory
Commission (NRC) licensees,
certificate holders, permit holders,
and applicants; all Agreement and
Non-Agreement States, and State
Liaison Officers; and other
interested stakeholders.
10/01/2013 RIS-2013-16 Interactions Between the
NRC and NRC
Stakeholders During a
Lapse of Agency
Appropriations
All U.S. Nuclear Regulatory
Commission (NRC) licensees,
certificate holders, permit holders,
and applicants; all Agreement and
Non-Agreement States, and State
Liaison Officers; and other
interested stakeholders.
09/16/2013 IA-03-02 Criteria for Reporting
Cybersecurity Incidents
All Radiation Control Program
Directors and State Liaison
Officers. All Increased Controls
(IC) materials licensees. All
licensees possessing Category 2
and higher materials.
IN 1999-03, Rev. 1
Enclosure 4
Page 2 of 2
List of Recently Issued Office of Federal and State Materials
and Environmental Management Programs Generic Communications
Date GC No. Subject Addressees
09/11/2013 RIS-2013-14 Reporting Transactions
Involving Temporary
Jobsites to the National
Source Tracking System
All industrial radiography and well
logging licensees, and all Radiation
Control Program Directors and
State Liaison Officers
Note: This list contains the six most recently issued generic communications, issued by the
Office of Federal and State Materials and Environmental Management Programs. A full listing
of all generic communications may be viewed at the NRC public Web site at the following
address: http://www.nrc.qov/readinq-rm/doc-collections/qen-comm/index.html
Honeywell Yellowcake
Concentration ana Purification
BackgroundInformation
ENERGYFUELS
I ncrgv Fuels Resources (USAj Inc,
•»n Blvd. Suite 600
Lakewood, CO, I S 30228
3D3 974 2140
ww. w .energy fuel^eom
July 26, 2013
VIA EMAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
RO. Box 144850
Salt Lake City, UT 84114-4820
Re: Follow-up to Utah Division of Radiation Control ("DRC") on Discussion Regarding
Concentration and Purification of Yellowcake Received from Honeywell
Dear Mr. Lundberg:
This letter is a follow-up to discussions during Energy Fuels Resources (USA) Inc's C'EFRIV) meeting with
DRC staff on October 17, 2012 and subsequent telephone discussion with John Hultquist on June 6, 2013
regarding concentration mid purification of yellowcake (the "Honeywell Yellowcake"), that is adhered to drum
shreds, from Honeywell inc's ("HoneywellV) Metropolis, Illinois works (the "Metropolis Works'*) at the
White Mesa Mill (the "Mill").
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 "l.icensee-to4^censee,* transfer of source material. This will in substance
be no different from the receipt of yellowcake in drums. The only difference is that the drums have been
shredded. The Honeywell Yellowcake will then be concentrated and purified by removing the yellowcake from
the drum shreds, and adjusting the moisture content and physical form, to produce a yellowcake product that
meets commercial specifications for introduction into the conversion process at a conversion facility, in order
to achieve this, the Honeywell Yellowcake will be separated from the drum shreds in a sulfuric acid bath and
the resulting solutions will be introduced into the Mill process, where the yellowcake will be concentrated and
precipitated, dried and then packaged as yellowcake product. The resulting tailings, including the drum shreds,
will be disposed of in the Mill's tailings cells as 1 le.(2) byproduct material. The steps and processes involved
in separating the yellowcake from the shreds, putting the yellowcake into solution, and precipitating,, drying and
packaging the yellowcake will he no different from the steps that could, he taken by the Mill to separate any of
its own hardened packaged yellowcake from drums and disposing, of any damaged drums in the Mill's tailings
cells.
As previously discussed, EFRI has determined that the Honeywell Yellowcake consists of the same yellowcake
product as produced hy EFRI at the Mill, and in fact, may include yellowcake produced in the past at the Mill.
Our most recent: information from Honeywell, as summarized in our discussion, with Mr. Hultquist on June 6,
NAWMMVVternate Fecds\Honevwef! CcnvenlyncNDrum Shreds approval processor, to R, Lundberg re Honeywell Yellowcake 7.25.13.doex
Letter to R. Lusidbcr"'
July 26, 2013
Page 2 of?
2013, confirms that the Honeywell Yellowcake has never been combined with, nor contains, any other materials
ur constituents. Detailed information supporting the description presented to Mr Hultquist during the June b.
2013 telephone call is provided below,
Honeywell proposes to ship approximately 4,KU0 overpack-sized drums containing approximately 200.000
pounds of Honeywell Yellowcake attached to $10,000 pounds of shredded drain pieces produced as discussed
below. Based on the information below, KFRl believes that the Honeywell Yellowcake can be separated from
the shreds at the Mill just as any other encrusted yellowcake could be separated from drums at the Mill. The
drum shreds would then be disposed of in the Mill's tailings cells in the same manner as any other discarded
drum. The ovcrpacks would either he returned to Honeywell, or re-used hy the Mill, or if not fit for re-use,
disposed of in ihe Mill's tailing cells like any other non-reusable oscrpack.
Honeywell Yellowcake History
The details provided below confirm iha! the Hone.)well Yellowcake has not been commingled with any other
matenal or constituents.
Tho Metropolis Works has received yellowcake drums from uranium milling operations in the L'S from 1958 to
19o4 and from thc US and abroad since !%8. Yellowcake received at I he Metropolis Woiks is convened to
uranium hexafluoride and shipped to other facilities in the nuclear fuel cycle for enrichment and then
iara i..4iinn into reactor iucL
The Metropolis Works opens and samples each yellowcake drum tor assay and ehanieten/ation to confirm that
the contents comply with Honeywell's contract requirements for yellowcake from each supplier, iiach drum
remains open for no more than a. few minutes at thc tune of initial sampling. Drums which meet the contract
requirements are inventoried and remain closed until they are scheduled to be processed in the Metropolis
Woiks conversion plant.
The Metropolis Works received approximately 15,000 drums over the past 25->ear period, which have not been
processed in the conversion plant. Fach of the 15,000 drums (as well as all other yellowcake feed drums
accepted at the Metropolis Works):
* was opened once for assay and composition analysis;
* had an assay and composition \\ hieh met Honeywell's acceptance contract criteria at the time of
receipt; that is, contained only yellowcake;
* remained closed awaiting processing in the conversion plant; and
* was opened and inspected pi ior to antiuguuM processing.
Honeywell deter:tuned that for each of these 15.000 drums, the drummed yellowcake contents had. over the
period the drum was inventoried awaking processing, absorbed moisture through its drum lid. The moistened
yellowcake hardened within the drums and could no longer be removed by conventional drum emptying
equipment. Each of the drams containing haulened yellowcake was iclaheled as "hard ore." It should be noted
that each drum of "hard ore" remained within Honeywell's inventory of yellowcake because it contained only
yellowcake, and retained its uranium value as potential feed to Honeywell's conversion facility. However,
since tlie drums could not he emptied, the contents could not be processed.
2
Letter to R. Lundberg
July 26. 2013
Page 3 of 7
Prepara: , -< *o- ,., 1 io,
In 2012 and 2013, in an attempt to remove the hardened yellowcake that could not be directly emptied from she
15,000 drums identified as "hard ore", Honeywell installed mechanical equipment at the Metropolis Works to
shred thc drums and recover the majority of the contained uranium value In the hardened yellowcake.
Each "hard ore * drum was opened and put through a mechanical shredder, which shredded tlie drums and the
hardened yellowcake in the drums. No chemicals or reagents of any type were used in the shredding process.
The ponton of the hardened yellowcake which was not freed by the shredding remained attached to the
shredded drum pieces. The shredded yellowcake pieces, together with the ye11owcake-encrusted shredded drum
pieces, were transferred on a conveyor belt to a separation step which mechanically separated the encrusted
drum pieces from the shredded yellowcake pieces. The resulting freed yellowcake pieces were repackaged in
overpack-sized drams, for introduction into the process at the Metropolis Works. The remaining hardened
yellowcake encrusted on the drum shreds comprises the Honeywell Yellowcake. The Honeywell Yellowcake
was repackaged in overpack-sized drums, and is intended for transfer to the Mill under 10 CFR 40,510),
At the current time, all the "hard ore" at the Metropolis Works has been handled in this manner. This produced
approximately 17,000 drums of >hreddai/pulveri/.ed hardened yellowcake (due to expansion during shredding)
and approximately 4.800 dtums of hardened yellowcake adhered to drum shreds (due to expansion during
shredding). The hardened yellowcake attached to the drums was identical to the hardened yellowcake freed and
packaged separately and ultimately introduced, or to he introduced, as yellowcake into die process at the
Metropolis Works.
Honeywell will process at the Metropolis Woiks the 17,000 drams of hardened yellowcake freed from the
shreds along with its other yellowcake inventors. Honeywell plans to ship approximately 4,800 drums of the
remaining Honeywell Yellowcake, along with thc associated shreds to l.FRT at rhe Mill as a lieensee-todieensee
transfer of source material under 10 CFR 40.31 and the Mill License, The Mil! will then separate the
Honeywell Yellowcake from the drum shreds and concentrate and purify the separated \eiiowcake into
commercial yellowcake product. The Honeywell Yellowcake to be transferred to the Mill has been very welt
characterized as discussed with Mr. Hultquist and detailed below.
Drum Characterization Data
Hone y we I i performed sampling and characterization of the yellowcake resulting from the shredding process as
follows. The characterization is representative of both the shredded hardened yellowcake and the Honeywell
Yellowcake attached to the shredded drums.
As the Honeywell Yellowcake was separated from shredded pulverized hardened yellowcake on the conveyor
belt, a sample was collected. Samples were collected from 9,408 (over 55%) of the drums of recovered
hardened yellowcake. Samples from each of the 48 drams were composited into one lot. A total of 1%
samples/lots representing 9,408 drums of hardened yellowcake were analyzed for every constituent in
Honeywell's feed acceptance criteria table. Data from the analyses are summarized in the attached Table I
The data indicate that:
* the Honeywell Yeiloweake consists solely of natural uranium ore concentrates (yellowcake only), and
Letter to R. Lundberg
July 26,2013
Page 4 of 7
• the yellowcake is within the specifications of Honeywell's feed acceptance criteria (other than the
moisture content which contributed to the hardening of the yellowcake, the hardened physical form and
the associated drum shreds).
The drum shreds are the same composition as the drums received and disposed of at the Mill on a regular basis.
Regulatory Considerations
EFRI has considered the following in making its determination and conclusions discussed below,
USDOT regulations and existing procedures already regulate the shipment of Honeywell Yellowcake between
the Mill and the Metropolis Works. The number of trucks associated with transporting the Honeywell
Yellowcake to the Mill will be far fewer (140 times fewer) than the number of trucks required to transport the
quantity of ore needed to produce the same mass of yellowcake. The number of trucks required to transport the
resulting separated, precipitated, dried and packaged yellowcake to and from the Mill would be the same as
required to transport yellowcake produced from processing natural ores or any other feed at the Mill.
The first paragraph and Conditions 6, 7, and 8 of the Mill License allow EFRI to "transfer, receive, possess and
use" "natural uranium" "in any form" with "no maximum quantity limit". Receipt of the Honeywell
Yellowcake, along with the associated drum shreds, would be a licensee-to-licensee transfer of source material
to the Mill under 10 CFR 40.51(5), because the Mill is "authorized to receive such source or byproduct
material" under terms of the Mill License, which is "a specific license or a general license or their equivalents
issued by the Cornraission or an Agreement State," as required by that regulation.
Composition of the Transferred Source Material
As discussed above, the Honeywell Yellowcake consists solely of hardened concentrates of natural uranium
yellowcake attached to shreds of steel product drums. Neither the yellowcake nor the drum shreds contain any
constituent that is not present and handled routinely at the Mill. The Honeywell Yellowcake may, in fact,
include yellowcake previously produced at the Mill, and some of the drum shreds may have originated at or
passed through the Mill.
The detailed analysis of the Honeywell Yellowcake was discussed above. The Mill already receives and
recycles and/or disposes of steel drums from a number of other facilities in the US and abroad which enter the
Mill from various sources, including:
• Alternate feed materials;
• Process chemicals; and
• lle.(2) byproduct material from in-situ recovery facilities.
Transport
Receipt
4
(
Letter to R. Lundberg
July 26. 2U13
Page 5 of 7
Concentration and Purification of the U'eneyweil Yellowcake
The Honeywell Yellowcake does not meet the specifications required for acceptance at a conversion facility,
due to its moisture content, its hardened form, and its adherence to the drum shreds, It therefore requires further
concentration and purification at the Mill in order to produce yellowcake that meets commercial specifications.
Concentration and purification will include separation of the hardened yellowcake from the drum shreds, and
then concentration, precipitation, drying and packaging the yellowcake- Other impurities in the Honeywell
Yellowcake would also be removed during this process. This will result in a purified form of yellowcake that
meets all of the commercial specifications for yellowcake.
Separating the hardened yellowcake from the drum sha eds at the Mill will involve thc same steps HFR1 would
use to separate any oi* its own yellowcake product that were to become hardened and/or attached to its own
product drums. The Mill has previously internally reprocessed off-spec yellowcake product produced at the
Mill. Offspec product is removed from its product drums and reintroduced into the process at the leach,
extraction, or precipitation area as appropriate. If the Mill were to reprocess yellowcake that had become
hardened and/or attached to its drum walls, the Mill would acidify and empty the drum contents in the same
fashion, and reintroduce the dissolved yellowcake into the Mill's leach circuit, just as would be required for the
Honeywell Yellowcake Consistent with License condition 9.4, the Mill's SERP committee would review any
change^ to the facility or process, or to existing procedures, required to dissolve the hardened yellowcake from
the shreds and remove the dissolved yellowcake and shreds from the overpack drums, prior to reprocessing the
yellowcake and disposal of thc remaining shreds, just as it would for similar procedures involving its own
hardened yellowcake,
The United States Nuclear Regulatory Commission ("NRC") has concluded that reprocessing yellowcake in
these circumstances is uranium milling and that the resulting wastes are 11e.<2> byproduct material. In Staff
Requirements - SECY - 02 - 0095 - Applicability of Section lie. (21 of the Atomic &wrt>y Act to Materia! at the
Sequoyah Fuels Corporation Cranium Conversion Facility, a copy of which is included with this letter, NRC
concluded that wastes generated at the front end of the Sequoyah fuels Corporation conversion facility ("SIC")
that resulted from the fun her concentration and purification of yellowcake that it had received from uranium
mills can be classified as 1 !e.{2) byproduct material, hi that decision, the Commission accepted NRC Staffs
position that "The staff has not found it necessary to label the feed for each step of the milling process as "ore"
as the basis for classifying the waste from that step as 1 le.(2) byproduct material. When yellowcake underwent
additional concentration at the front end of SFC it was a continuation of uranium milling, i.e.. another step of
the milling process. Thus, that part of the processing at a conversion facility fulfills rhe "extraction or
concentration" terms of I le.(2) byproduct matenal."1 Unlike SFC, rhe Metropolis Works does not have a front
end concentration and purification stage, and therefore must send the Honeywell Material lo the Mill to perform
this final stage of uranium milling. As indicated by NRC Staff, and adopted by the Commission, "(tlie Office of
the General Counsel 1 has advised the staff that the definitions of uranium milling and I le.(2) byproduct
material are process-related definitions and not restricted to a particular location of activity nor the physical
characteristic of a material "? In fact, NRC Staff noted a number of circumstances where uranium mills in the
past each performed a part only of the uranium mil ling process and then shipped the resulting produced material
or concentrates to another licensed facility tor further milling. NRC Staff noted that "(e]ach of these mills and
1 Policy issue {Notation VOUM Srr'Y-02-OtRS, page 3
2 Policy Issue {Notation Ynuo SFC Y-02-OOUS, footnote 2
5
I
Letter to R. Lundberg
July 26,2013
Page 6 of7
several others accomplished only a portion of the milling process at dispersed locations but were a!! licensed
operations at one time.*'"
Concentrating and purifying the Honeywell Yellowcake at the Mill is therefore another step of the uranium
milling process, and all wastes associated with such milling are classified as 1 le.(2) byproduct materia! and can
be disposed of in the Mill's tailings cells.
Disposal
As determined by NRC in Sequoyah, all wastes associated with further concentration and purification of
yellowcake can be classified as 1 le.i2) byproduct material. Since the concentration and purification of the
Honeywell Yellowcake at the Mill involves the same steps jn the milling process as for other yellowcake, all
wastes associated with the milling will be the same as wastes associated with concentration and purification of
yellowcake at the Mill The same can be said for the drum shreds. The Mill routinely crashes and disposes of
steel drums bom the various sou ices listed abo\e as 1 le.(2) byproduct matenal in its trillings cells. Since Oleic
aie no new or additional constituents in thc Honeywell Yellowcake and associated dniin shreds, there will be no
human health, environ mental, or worker safety impacts due to new or additional constituents above those
already managed at the Mill.
The Honeywell Yellowcake is Source Material and not an Alternate Feed Material
The Honeywell Material is source material that is being transferred to the Mill under 10 CTR 40.51 and the Milt
License and will be further concentrated and purified as a step in the uranium milling process. It is not an "ore''
and hence is not an alternate feed material, In fact, in its recommendation to the Commission in the Sequoyah
decision, NRC Staff noted that lw}hether the incoming source material to SFC meets the definition of "ore'" is
not relevant to the argument of waste classification. Declaring an incoming feed for individual milling-process
stages as "ore," throughout the continuum of milling, is an artificial and unnecessary distinction. When milling
is done at one she, the lied for each stage is not considered when making I lei2) byproduct material
determinations for the classification of wastes for each stage. Similarly, uranium milling has, and docs, occur at
different locations under regulatory oversight without the construct of individual processing feeds meeting the
definition of "ore." Thus, there is no need to consider the feed al SFC as ore, because the iront-end process at
SFC was simply the last step in the milling activity . .
Conclusion
The Honeywell Yellowcake can be received at the Mill as a licensee-to-licensee transfer of source matenal
under 10 CFR 40,51(51 and the Mill License. The Honeywell Yellowcake can be further concentrated and
purified at the Mill as a step in the uranium milling process in order to produce yellowcake that meets
commercial specifications. All wastes from such concentration and purification can be disposed of in the Mill's
tailings cells as 1 le,{2) byproduct material. As the Honeywell Uranium is not an "ore4* it is not an alternate
feed materia], and hence an amendment to the Mill License is not required.
f Policy Issue (Notation Vote) SECY-O2-O095, Attachment 5: Uranium Milling Activities ea Sequoyah Fuels Corporation,.
page;2' e. ,:.er W^JzF* Yw. : Oaf,,
! Policy Issue (Nutation Vote) SEC Y-<O-iXRl Attachment 5: Uranium Mil ling Activities at Sequoyah Fuels Corporation,
page 6.
6
1
Letter to- R. Lundberg
July 20, 2013
Page 7 of 1
Further, there are no additional environmental, health, or safety concents 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 io the M ill'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. No additional or new
chemicals or reagents will he used in the process.
Please advise us as soon as possible whether you concur with EFR IN determination as described in this letter.
If you should have any questions regarding the above information, please contact me or David Prydeniund at
303-389-4132.
Yuurs vers truly.
KNRRKY Ft)ELS RKSOl'RCKS I USA) IN«'.
Jo Ann Ti sch ler
Manager. Mill Compliance
cc: David C. Prydeniund
Dan Hill sten
John Hultquist (DRC)
Harold R. Roberts
David E. Turk
Katharine A. Weinel
Attachments
7
Table 1
Analysts of Honeywell OOC on Drum Shreds
UOC Material %Na %Mg %K %Ca %Ti %V %Cr %Fe
Average <0,0001 0.0003 030 0.0161 0.0574 0.0331 0.13 0.15 0,0037 0.0349 0.0006 0.0071 1.13
Max 0.0001 0.0015 1.53 0.1248 0.2297 0.1708 9.10: 1,28 0.0173 0.1623 0.0043 0,0414 5.25
<0.000I <0.0001 0.03 0.0026 <0.0001 <0.0001 <0.01 0.02 0.0005 0,0010 <0.0001 0.0011 0.10
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 2.50
UOC Material %Co %Ni %As %Zr %Ag %Cd %Sb %Ba %Hg %Pb pprnTh
Average o.oooa 0.0019 0.0105 0.0045 0.0303 0.0606 0.0001 0.0002 0.0004 0.0016 <0.0001 0.0015 3.18
Max 0.0033 0.0955 0.0249 0.2286 0.1535 0.4842 0.0011 0.0005 0.0058 0.0161 0.0003 0.033: 5615
Msn <0.0001 <0.0001 0.0011 0.0000: 0.0015 0.0033 <0.0001 <0.0001 <0.0001 0.0001 O.OOOl 0 0001 02
Honeywell
Acceptance
Specification
(max) NA NA 0.10 0.04 1.00 030 0.04 0.04 NA 0.04 NA 0.04 5000.00
IUOC Mater
Max
Mm
Honeywell
Acceptance
Specification
(max)
ppm U-234
53.29
54.87
51.56
62.00
%235U
0.711
0.714
0.706
NA
%238U
76.77
81.83
67.66
NA
%S04
=
1.52
7.10
0.62
4.00
% cr
0.01
0.24
0,01
NA
%F
0.07
1.26
<0.01
0.15
%H20
8.42
25.4-8
1.20
Note; Analytical data on 196 lots of hard ore with the exclusion of sulfates. Only 96 lots have been analyzed for sulfates as of 6/6/2012.
Samples collected and analyzed in 2013 at Honeywell's Metropolis Works
Shredded Drum Processing
Procedures
No.: PBL-12
Rev. No.: R-0
Date: November 1,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Shredded Drum Acid Leach
Page 1 of 3
Hazard Assessment Worksheet
Reagent Data
Leach Solution
pH < 1
Temperature Ambient
Oxidizer/Reductant Strong oxidizer
Pressure Ambient
Flashpoint Not flammable
Reagent Concentrations H,SO* NaCIO:
Concentration Range 40 - 60 g/L 10 - 20 g/L
Assessment Description: The acid/chlorate solution will be added to each drum and each drum
will be rolled on electric drum rollers in order to dissolve the uranium contained in each drum.
Any splashing or contact with the leach solution, before and after the leaching process should be
avoided as these chemicals can cause chemical burns. Also, avoid contact with organic material
(such as clothing) as sodium chlorate can react strongly with organic materials. Operators and
anyone in the area should wear proper PPE to protect from these chemicals. In case of any
contact, wash the area of contact off with generous amounts of water.
Leach
Solution
Drum
Drum Roller
Operating Instructions
This node deals with the acid leaching of the uranium coated drum shreds.
• Obtain approval from your supervisor to run the leaching process of the drum
shreds.
• Make a safety inspection of all lines and equipment.
o Inspect lines for leaks or seeps.
No.: PBL-12
Rev. No.: R-0
Date: November 1,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Shredded Drum Acid Leach
Page 2 of 3
o Inspect safety showers and eyewash fountains.
o Inspect the drum rollers and associated equipment for defects.
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the MSDS. This means that you must read and understand the
information on the MSDS and if you don't, ASK YOUR
SUPERVISOR.
• Position each drum near a rolling station. Relieve any pressure build up in the
drum by making a vent hole before removing the lid. Remove the lid of each
drum.
• Inspect the drum for any abnormalities or suspicious content.
• Re-seal the drum with a "process" lid. The process lid has additional fittings
to allow for ease in processing. Make sure that the o-ring is not damaged and
that the lid seals completely to avoid leakage from the drum. Also, make sure
the center vent port is free of ice or other obstructions.
• Lower each drum onto the rolling mechanism.
• Connect the venting tubing and the reagent fill line. Fill the drum with the
specified volume of reagent solution. Close the valve and remove the reagent
fill line
• Close all guarding and safety mechanisms and turn the drum rollers on.
Allow the drums to roll for 30 minutes or as instructed by your supervisor.
• When 30 minutes is up shut off the drum rollers. Connect the drain lines and
open the valves to drain the solution into the sump. Transfer the solution from
the sump to the solution holding tank. From the holding tank the solution is
sent to the solvent extraction circuit and will be processed using normal SX,
rjrecipitation and drydngjjractices.
• Repeat the process if necessary as instructed by your supervisor.
• Rinse the contents of the drum with water if necessary as instructed by your
supervisor.
• Stand the drums back up and remove the "process" lids. Replace it with the
original lid and move drum to drum disposal area after which the drums will
be disposed of according to Mill Waste Disposal SOP PBL-7.
No.: PBL-12
Rev. No.: R-0
Date: November 1,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Shredded Drum Acid Leach
Page 3 of 3
Be sure to wear appropriate PPE at all times when working on or around this
process.
Always keep your work area clean and free of obstructions.
No.: PBL-12
Rev. No.: R-0
Date: November 1,
2013
IJN©" RGY FUELS RESOURCES (USA)
STANDARD OPERATING PROCEDURES
Title: Shredded Drum Reagent Make-up
Page 1 of2
Hazard Assessment Worksheet
Reagent Data
Leach Solution
pH < 1
Temperature Ambient
Oxidizer/Reductant Strong oxidizer
Pressure Ambient
Flashpoint Not flammable
Reagent Concentrations H,SO< NaCIO:
Concentration Range 40 - 60 g/L 10 - 20 g/L
Assessment Description: The acid/chlorate solution will be made up from bulk concentrated
solutions of sulfuric acid and sodium chlorate. Batches will be made up by an automated system
with reagents added in this order: water, sulfuric acid then sodium chlorate. Sulfuric acid is a
strong acid and can cause chemical burns. Sodium chlorate is a strong oxidant and can cause
chemical burns. Also, avoid contact with organic material (such as clothing) as sodium chlorate
can react strongly with organic materials. Operators and anyone in the area should wear
proper PPE to protect from these chemicals. In case of any contact, wash the area of
contact off with generous amounts of water.
H2SCX
Water
Na?CIQ3
Reagent
Mix Tank
Operating Instructions
This node deals with the leach solution make-up.
No.: PBL-12
Rev. No.: R-0
Date: November 1.
2013
RGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: Shredded Drum Reagent Make-up
Page 2 of 2
• Obtain approval from your supervisor to make a batch of leach solution.
• Make a safety inspection of all lines and equipment.
o Inspect lines and tank for leaks or seeps.
o Inspect safety showers and eyewash fountains
o Always keep your work area clean and ensure your area is free of
hazardous obstructions. Always read and follow all parameters listed
on the MSDS. This means that you must read and understand the
information on the MSDS and if you don't, ASK YOUR
SUPERVISOR.
• Check the level of the tank and determine if a new batch of leach solution is
needed.
• Ensure that all valves are in appropriate positions
• Initiate the batch make-up
• Be sure to wear appropriate PPE at all times when working on or around this
process.
• Always keep your work area clean and free of obstructions.
Drum Rolling Ops
Photos
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Other Supporting
Documentation
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
Product Preparation and Shipping
have been trained and have had the opportunity to ask questions regarding
the activities associated with preparing, cleaning and shipping of uranium (Yellowcake) and vanadium
(Blackflake) product drums. The training includes but is not limited to the following:
STEP 1. - Pick up the clean product drums and inspect the drums for damage. The vanadium product drums
are scanned by the radiation department prior to pick up. Check with the radiation department to insure
the scan is completed. A full face respirator is required when picking up vanadium product drums in the
vanadium packaging area. If product drums, uranium or vanadium, are dirty they should be cleaned before
transferring the product to the Product Yard. If the product drums are damaged, uranium or vanadium,
leave the drums in the packaging area and notify Operations which drums are to be repackaged.
STEP 2. - Once the product drums are in the Product Yard they are hand washed and inspected individually
for damage. Report any damage to the product drum to your supervisor so that the damaged drums can be
taken to the packaging areas.
STEP 3. - Once the product drums are all washed and inspected they are re-weighed and the weights are
documented on the re-weight sheet. After all the product drums are re-weighed check for over or under
weights compared to the production weights. If the product drums are over or under weight by more than
3 kilograms, they are taken back to packaging to be repackaged. Once the product drums are confirmed
"good," tighten the uranium product drum rings. The vanadium product drums are opened and inspected
for moisture, if there is moisture in the drum, the drum should be documented and taken back to
packaging. Proper PPE is required for checking the vanadium product drums for moisture. When the
vanadium product drums are confirmed free of moisture replace the lids and tighten the rings.
STEP 4. - After the product drum rings are tightened the rings are drilled for the identification tags. Each
product drum lid is painted. Product drums are painted as needed. When the product drums are painted
and tagged the product drums are scanned by the radiation department. The product information, (weights,
lot number, and drum number), is written on the stickers provided; there are three stickers to a product
drum. The hazard sticker and seals on the uranium product drums are placed on by a certified
transportation expert on site. The seals on the vanadium product drums are also placed and secured by a
certified transportation expert on site.
STEP 5. - Once the product drums are inspected, stickered, scanned, and sealed the drums are ready for
shipping. The uranium product drums are ready to be loaded individually onto the trailer. The vanadium
product drums are put on pallets in sequence from 1 through 72. Then the vanadium product drums are
secured down to the pallet with a band. After the vanadium product drums are banded to the pallets they
are wrapped with shrink wrap. After they are wrapped, a poison sticker should be applied on all four sides
of the banded pallet.
The enclosed trailer van's wood floor is pressure washed before it is backed into the Product Yard. The floor
is allowed to dry or dried before a radiation technician is called to scan the surface of the floor for
contamination. Once the van is clean the cribbing and loading can begin. A member of the radiation staff
must be present when loading uranium, (Yellowcake), product in the van. The diagrams attached show the
load placement and cribbing for uranium or vanadium product shipments in the van. After the product is
loaded and secured in the van, photographs are taken to document the loaded van. The van is then sealed
and placarded with the appropriate placarding. The radiation department does a series of scans on the
uranium shipments prior to the shipment leaving the site.
After all these steps are carried out the product is ready to be shipped. Please take pride in preparing these
drums for shipment and always do your best work. Remember work safe and productive.
Loading trailer and trailer preparation
Instructor: Traine Date: 7-- Ifl
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
U308 YELLOW CAKE URANIUM SHIPPING LOAD PLACEMENT AND CRIBBING
4X4 BOARD 2X4 BOARD 2" band 2X4 BOARD 2" band , 2X4 BOARD
7
2X4 BOARD 2X4 BOARD
22 DRUMS LOADED iN THE BACK 21 DRUMS LOADfcE) w FRONT
GAP BETWEEN LOADS 5 foot gap between the toad to time tiooTi.
The diagram above shows where the yellow cak e drums are placed in a 53 foot trailer, it also shows where all the cribbing
is placed and how many drums are loaded in the front and rear of the van.
There will also be synthetic straps that will be placed on both loads after they have been banded and cribbed.
o
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding. UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
v205 VANADIUM BLACKFLAKE LOAD PLACEMENT & CRIBBING
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9 pallets in the front 8 to 10 foot gap 9 pallets in the back
The above diagram shows how the cribbing and load placement that should be done for a 54 foot trailer.
Also the 9 pellets in the back are to be placed over the trailers axles.
The diagram below shows how the cribbing and load placment that should be done for a 48 foot trailer
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9 pallets in the front 4 to 5 foot gap 9 pallets in the back