DRC-2018-003332 - 0901a068807e706d

Department of
Environmental Quality
State of Utah
Alan Matheson Executive Director
GARY R. HERBERT Governor
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
SPENCER J. COX lieutenant Governor
MEMORANDUM
TO: File C-2018-40
THROUGH
FROM:
Phil Goble, Section Manager ff G
Russell J. Topham, P.E. �
DATE:
SUBJECT:
April 5, 2018
Inspection of receipt of Sequoyah Fuels Alternate Feed; Radioactive Materials License Number UTl 9004 79 (RML. Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
License Condition I 0.8 allows Energy Fuels to receive, store and process alternate feed material from the Sequoyah Fuels Corporation facility located near Gore, Oklahoma. That license condition sets forth the following conditions:
1.limits on stockpiled quantities (16,700 tons gross weight or 7,520 tons dry weight for bulk storage, or17,250 SuperSaks),2.Maximum weight of the material in any individual SuperSak (approximately 2,200 pounds),3.If stored on the ore pad, the SuperSaks must receive a cover of a minimum of 6 inches of soil,4.Stockpiled material must be kept moist by sprinkling until covered,5.The material must receive a cover within three days of placement on the ore pad,6.Cover soil must be kept moist by sprinkling to reduce dusting,7.Offloading operations can only occur when wind speeds remain below 20 mph if any SuperSak isdamaged or leaking upon arrival.
On March 26 and 27, 2018, in the company Phil Goble of the DWMRC and David Turk of Energy Fuels Resources (EFR); I conducted an inspection of the receipt and initial processing of the first two shipments of Sequoyah Fuels alternate feed material at the White Mesa Mill. Since the material was staged adjacent to the ore intake grizzly on March 261h and was extracted from the SuperSaks and placed in the grizzly to begin processing on March 2?1\ only items 2, 4 and 7 in the above list pertain to this event.
The mill received two shipments of Sequoyah Fuels alternate feed material on March 25, 2018. Both arrived on flat-bed trailers. Each trailer carried 24 SuperSaks (inner bags) in groups of four, each group of four placed in a flexible, waterproof textile container (large SuperSak) to control any leakage that may occur. The load was covered with a tarp and secured with straps and bungee cords. Photo 1 shows the first shipment outside the mill awaiting radiological survey and visual inspection prior to being received.
DRC-2018-00332 195 North 1950 West• Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
iml!W.deq.utah.gov Printed on I 00% recycled paper
Review Memorandum, Project C-201 8-40
April5,2018
Page2
Photo 1: First load ofSequoyah Fuels alternate feed material upon arrival at the mill. Transportation placard is typical ofthe four placed
one on each side of the trailer. Photo taken March 26.2018.
The load was visually inspected, received a radiological survey, and then was moved to the scale for weighing
and inspection of shipping paperwork.
Photo 2: Visual inspection and radiological survey of incoming load. No leakage was detected.
Radiological surveys were taken at I meter and on contact. Photo taken March 26,2018.
Radiation survey is attached to this report
Review Memorandum" Proiect C-2018-40
April 5,2018
Pase 3
The two loads received on this day carried a net weight of 22 and 19 tons, which works out to I 801 lbs. average
for SuperSaks on the first truck and 1593 lbs. for SuperSaks on the second truck. Both ofthese values fall below
the approximate 2200-lb.limit per SuperSak specified in License Condition 10.8, and repeated in Bullet 2 above.
Photo 3: View ofpart ofunderside ofthe trailer. This is typical ofthe condition ofthe trailer observed for both loads received. i.e.. no
evidence ofleakage. Photo taken March 26.2018
Photo 4: Truck and loaded trailer on the scale. Photo taken March 26. 2018
Review Memorandum. Proiect C-20 I 8-40
April 5,2018
Page 4
The 2200-lb. limit pertains to the contents of the bags, while the per-bag weight calculated and presented above
includes the weight of the bags and the pallets on which the bags were transported.
From the scale, the truck proceeded to a location just east of the grizzly where the tarps were removed, the straps
securing the load were removed and the load was transferred from the trailer. Tarps were surveyed for
radiological contamination. No contamination was detected, so, following removal of the load, the tarps were
placed on the trailer for release. Photo 6 on Page 5 of this report shows a worker checking for contamination on a
tarp.
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Each four-SuperSak container was labeled with the same information that appeared on the trailer placards, along
with the gross weight of the four-SuperSak unit. Thus, had an incident on the highway resulted in loss of a
portion of the load, emergency responders would have a clear idea of the nature of the rnaterial. Each four-
SuperSak unit was placed on a pallet for shipping and handling. Upon unloading, the pallets were stacked and
surveyed for contamination, then placed on a trailer for release. Contamination was not found on the pallets.
During all operations beginning with removal of the tarps, a worker with a breathing zone monitor was stationed
near the activity, in a location most likely to capture any releases. Furthermore, those working most intimately
with the material during unloading and transfer to the grizzly wore protective Tyvek suits, protective gloves and
respirators, and one wore an additional breathing zone monitor. Upon analyzingthe filters in the breathing zone
monitors, no radioactive particulates were detected.
Of the 48 SuperSaks off-loaded from the two trailers, only one showed an appearance suggesting a possible
breach of the SuperSak. Inspection of that SuperSak following off-loading from the truck revealed some material
on the exterior of the bag, but no rips or tears were apparent. lt is probable that the material on the exterior of the
SuperSak did not leak from the interior of that vessel or an adjacent one, but was spilled there during packaging of
the material.
Photo 5: Removing the tarp from the trailer. Photo taken March 26,2018.
Rer.ieu, Memorandum.
April 5.2018
Page 5
Pro.jecl C-2018-40
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I)hoto (r: Perlorrning radiological survcr of orrc ol'1he tarps that cor,crcd the loads.
on corl1ac1. (-'ontatnination \\as ltot detectcd. l)hoto laken l\4arch 26. 20 lti
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Photo 7: 'l hc' hcaviest sct of lour SuperSaks inclucled in thc trvo loacls obscrvccl is picturcd hcre. Notc the nlacarcling anl the $cish1
l)hoto taken March 2(r. 20189.
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Rcvieu' Mcmolandunr. Pnr.iect ('-101 tt-40
April 5.2018
Page 6
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Iter.icrv Mcmorandum.
April 5, 2018
Page 7
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fll'hoto I l: Itctnoving SLrperSalis liotn thc transport spill containrneut \rrap. Photo takcll March 2(r.20 ltl
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I)ltttto ll: Ilcutorirtg SttpcrSaks lionr thc tllulspotl rpilJ contarrrrrcnt \\rap. Photo takcn \,larch l(r. 10 18.
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Review Memorandum, Proiect C-20 I 8-40
April5,20l8
Page 9
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only a handful ofmaterial was observed in the transport wrap. It appears this might have been the result ofa spill during packaging. In
any event, no evidence existed of material finding its way outside the transport wrap. Photo taken March 26,2018.
After remaining in a staging area overnight, the SuperSaks were emptied of their contents on the threshold of the
ore processing intake grizzly. Only trained workers were permitted to work this closely with the material, and a
refresher briefing was held at the commencement of the day.
Observers were held upwind of the operation, even though the air was nearly still. Tyvek-and respirator-clad
crews slit open the SuperSaks as they were suspended from a forklift in pairs. Breathing zone monitors were
employed again to monitor conditions in close proximity to the material removal operation. While the
employment of breathingzone monitors in addition to respirators may seem redundant, the information gathered
from the breathing zone monitors will be useful in quantifoing risks and demonstrating adequacy of the measures
taken. Most of the SuperSaks contained material with sufficient moisture content to prevent dusting.
Only minor dusting was observed, and that only from the contents of about a half-dozen SuperSaks.
Following the removal of material from the SuperSaks, the workers used a loader to transfer the material into the
process intake hopper. From there, a conveyor would take over handling of the material, introducing it to the
conventional mill process.
The crew gathered the empty SuperSaks and transported them in the bucket of the loader to the area of Cell 3
designated for disposal of plant-generated debris. Once placed, the debris was covered with interim fill material
to secure it in place and to reduce any residual radiation from contamination remaining on the bags.
Rcview Memorandum. Proiect C-201 8-40
April 5. 2018
Pase 10
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I'hoto I 7: nlatcilat ptaccO at the threshold o1'thc grizzlv for introduction inro thc plant proccss
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I)hoto I 8: Transfcr o1'rnalerial into 1hc planl process intakc using a loader
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Review Memorandum.
April 5. 2018
Page 12
l)roject C-2018-40
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Photo laken March 27.2018.I vsi s.irtg {eorrrpositc s:rrnple ) t]rc rnatcri
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I)hoto 20: 'l ransporting emply SupelSaks to disposal area. l'hoto lakcn March 27.2018
Review Memorandum, Project C-20 1 8-40
April5,20l8
Page 13
Photo 21: Covering empty SuperSaks with interim fill soil to prevent them blowing away in the wind. Photo taken March 27, 2018.
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Review Memorandum,
April 5, 2018
Page 14
Proiect C-2018-40
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Photo 23: Survevins. truck for radiological contarnination lbllowine dccontarrrination. prior to rclcase from mill. When the sccond truck
exited the sitc. it carried the pallets and spill containrrent rvraps for reuse. Thcse rverc also survey'ed for contamination prior to releasc to
prevcnt contamination Iiom leaving the site. Photo taken March 26. 2018.
DWMRC Findings: During inspection we detected no items requiring attention or adjustment.
l. The nominal2,200-lb.limit for the contents of any individual SuperSak was not exceeded.
2. No Sequoyah Fuels alternate feed rnaterial remains on the ore pad.
3. The moisture content of the material was sufficient that additional wetting was not required; however, the
crew was prepared to wet the rnaterial had it been necessary.
4. Offloading operations were carried out in a safe rnanner with respect to physical and radiological
protection of workers.
5. Observers were kept at a safe distance and upwind of the work.
6. All material handling took place while wind speeds remained below 20 rnph.
1. Disposal of debris generated during the operation was conducted in a legal and safe Inanner.
8. Transporlation of the material to the site and release of the trucks, pallets, tarps and containntent vessels
appears to have met all applicable health and safety requirements.
Attachments: Shipping paper, radiological survey and weigh ticket fbr each load.
Equipment release survey for the pallets used to ship the rnaterial.
Trainins attendance roster and training outline for those involved in the work.
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Shipping Paper
From: Sequoyah Fuels Corporation
# 1 Sequoyah Lane
[I-40 & Hwy 10]
Gore, OK 74435
918.489.5511
To: Energy Fuels Resources (USA), Inc.
6425 S Highway 191
Blanding, UT 84511
435.678.2221
EMERGENCY CONTACT: Chemtrec -800.424.9300
__________ Description _________ _
Exclusive Use Shipment Trailer: NRF4071
Q packages RQ, UN3321, radioactive material, low specific activity (LSA-II), 7, 17954 kg,
Th-230, U(nat), Th(nat), solid, hydrated nitrate, RADIOACTIVE YELLOW-II,
Activity Transport Index
0.008 TBq, l.2
0.007 TBq, l.2
0.005 TBq, 1.4
0.007 TBq, l.2
0.005 TBq, 1.4
0.008 TBq, 1.2
Isl SA}r>A'N"r
This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper
condition for transportation according to the applicable regulations of the Department of Transportation.
,az;Jf.;# , 23Ma,ch2018 ~ ;J
Robert Miller Date ~
Feed Material Receipt
Inspection
Date: _ _1-::_2'4_:._~--------
lnspector: -r;_:ery S la.J,e.,..
Is the shipment leaking? Yes or@
If Yes, complete the other side of this document.
Number of containers/drums in shipment: __ _,{_tJ..__ ___ _
Radiation Activity Levels: ~u-@_z.-,\J:~
Location of Storage: _.....,.~Nu.~o..__ .... p:-.a.~c\"" _____ _
Corrective Action Taken for Damaged Drums:
'
Observations (note dented or damaged drums)
Se~ ~YA\
Inspector: --re-d)f <5lac\e....
(Print Name)
,C,,._~ -~
(Signature)
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
Vehicle ID: 99
Trailer ID:
Account ID: SEQUOYAH F SEQUOYAH
Order ID:
Owner ID:
Material ID: SEQUOYAH ALTERNATE
Destin. ID: BLANDING
FUELS
FEED
Comments: 6 BAGS
Operator: 4 Charge by Weight
Signature:
In:
Out:
Transaction No.
53359
Date Time Scale
03/26/2018 08:23 1
03/26/2018 09:28 1
Gross: 37.02 tn (M)
Tare: 30820 lb (K)
Net: 21. 61 tn
Shipping Paper
From: Sequoyah Fuels Corporation
# 1 Sequoyah Lane
[1-40 & Hwy 10]
Gore, OK 74435
918.489.5511
To: Energy Fuels Resources (USA), Inc.
6425 S Highway 191
Blanding, UT 84511
435.678.2221
EMERGENCY CONTACT: Chemtrec -800.424.9300
__________ Description _________ _
Exclusive Use Shipment Trailer: Q565~6
"Zt"'C/ S);pAeN I
.Qpackages RQ, UN3321, radioactive material, low specific activity (LSA-II), 7, 17284 kg,
Th-230, U(nat), Th(nat), solid, hydrated nitrate, RADIOACTIVE YELLOW-II,
Activity Transport Index
0.007TBq, 0.2
0.007TBq, 0.2
0.007TBq, 0.2
0.005 TBq, 0.4
0.006 TBq, 0.4
0.006 TBq, 0.4 4p~
2 ":tlo-0
This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper
condition for transportation ace ding to the applicable regulations of the Department of Transportation.
23 March 2018
Robert Miller Date
for Sequoyah Fuels Corporation
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Feed Material Receipt
Inspection
Date:. -~_-:.__?::.k_:_1_2{ ______ _
Inspector: fee 7 '.5laJ. e.... ·
Is the shipment leaking? Yes or Q
If Yes, complete the other side of this document.
Number of containers/drums in shipment: _______ _
Radiation Activity Levels: 0,,'3 M:£/hr sas; . ·t t. 2 ,~~f'."S
Location of Storage: __,(?KC. ....... t7.C:____,~p;,-,~.,._.._. _____ _
Corrective AJ/gaken for Damaged Drums:
Observations (note dented or damaged drums)
s,\M)~
Inspector: Le<o/ skk-.
(Print Name)
~.~
{Signature)
Energy Fuels Resources (USA) Corp .
White Mesa Mill
6425 S . Highway 191
Blanding UT 84511
** Reprinted by 4 at 03/26/18 10 :05 :02 **
Vehicle ID: 1001
Trailer ID:
Account ID : SEQUOYAH F SEQUOYAH FUELS
Order ID :
Owner ID :
Material ID : SEQUOYAH ALTERNATE FEED
Destin . ID : BLANDING
Cormnents : 6 BAGS TRL# Q56596
Operator : 4 Charge by Weight
Signature :
In:
Out :
Transaction No .
53360
Date Time Scale
03/26/2018 09 :21 1
03/26/2018 10:04 1
Gross : 36 .32 tn (M)
Tare: 34420 lb
Net : 19.11 tn
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radiation Survey of Equipment Released for Unrestricted Use
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with the following procedure.
I. .\lonitor for liross alpha contamination with the appropriate survey meter.
2. If calculated assay exceeds 1,000 dpm/100cm2, then perform swipe analysis at applicable points.
3. Decontaminate ifa removable alpha exceeds 1,000 dpm/100cm2 or fixed alpha exceeds 5,000 dpm/100cm2•
4. Release equipment or material if alpha contamination and Beta-Gamma levels are below the following
limit:
Removable alpha -1,000 dpm/100crn2
Fixed alpha-5,000 dpm/100cm2 average
15,000 dpm/100cm2 maximum
Beta-Gamma-0.2 mr/hr @1 cm average
1.0 mr/hr @ 1 cm maximum
Released from White Mesa Mill to: t,ru.Y\Le\aA ~<!;b(..S.
Released by (print name): J:~ "t°', \I\ Ptf'V'1h .S.
Date: ,l-l..~-1~
List of Equipment Total Alpha dpm/100cm2
I l L •• •--C I °'"" ""' \LJ.. ~&1~~ .
2
3.
4
S.
Instrument Function checks
Removable Al~ha
dpm/lOOcm-
r.1/A
Beta/Gamma mr/hr
'=.o .ll
Alpha Meter: Beta-Gamma Meter: Removable Alpha:
Inst. Model :l · SN µ~;).3 i
Th-230 Source SN 'b,90,q .... Of:\
dpm\C\lH> cpm'.U~ eff \~it:%
Efficiek:y Factor ~-\ '
Cal. Date: )..] 8\.""C \:J
Bkg ~()
MDA \\\\
Inst. Model 3 SN }..U II()
Cs-137 Source SN C ~~Jb
Inst. Response \. t, Mi:\ 'rlr--
Cal. Date: l-J QfiI \2
Was a copy of this document offered to the recipient:©or No Signature of recipient
SN -----
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Inst.Mod~! Th-230 S .·
dpm_-----',.:... -~-eff.~---
Efficiency
Cal. Date: ----
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0..\.\ ,:tn }.\"v\lS Utl':"t, S..~
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Training Attendance Record
Date 1-\ f-{ C> I '6 Instructor j)Otv1~ T <4-t-k J IA/ /Jj,n..,
Time started 6 JO() Time ended d 14'c.J Total Time
Full Name Social Security No. Job Classification
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Sequoyah Material Handling
• Only those with documented training is to operate equipment.
• Do your pre-shift inspection.
• Housekeeping
• Site work place exams/ lifting devices
• High visibility vests
• One person to give hand signals to equipment operator.
• Communicate clearly at all times with each other.
• Opening at the top of the grizzly/ fall protection required beyond cable.
• As the temperatures go up drink more water.