DRC-2020-020944 - 0901a06880dca557

ve• • , ,
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
L. Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
DR C-2)020 -020944-
MEMORANDUM
TO: Project File C-2020-41
THROUGH: Phil Goble, Uranium Mill Section Manager
FROM: Russell J. Topham, PE
DATE: November 17, 2020
pft 6 11/0/zeZa
SUBJECT: 2020 Engineering Module 73, Inspection of disposal of 1le.(2) decommissioning debris
from in situ recovery facilities — In-Plant File Review
Authority
Radioactive Materials License #UT1900479, Condition 10.5: "In accordance with the Licensee's
submittal to the NRC dated May 20, 1993, the Licensee is hereby authorized to dispose of byproduct
material generated at licensed in situ leach (ISL) [aka in situ recovery (ISR) facilities, subject to [...]
conditions." (Conditions are cited below as Requirements.)
R313-12-3 (quoting 10 CFR 40.4): "Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes. 9,1
10 CFR Part 40 Appendix A, Criterion 2: "To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal
1 This defmition amends the language given in Section 1le.(2) of the Atomic Energy Act as amended in 1954 to include in
situ recovery (or in situ leach) facilities on the same footing as conventional uranium mills. This is done by referencing
"solution extraction" in the definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980,
Volume 1, No. 10.
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
2020 ISR Decommissioning Debris Disposal File Inspection Report
November 17, 2020
Page 2
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations."
Requirements
1. Radioactive Materials License #UT1900479, Condition 10.5A: "Disposal of ISL waste is limited to
5,000 cubic yards from a single source." The Division considers a source to be a discrete facility
defined by its geographic boundaries.2
2. Radioactive Materials License #UT1900479, Condition 10.5B: "All ISL contaminated equipment
shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other
than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels
containing soil or sludges shall be verified by the Licensee to be full prior to disposal. Barrels not
completely full shall be filled with tailings or soil prior to disposal."
3. Radioactive Materials License #UT1900479, Condition 10.5C.. "All ISL waste shall be buried in
Cell No. 3 unless prior written approval is obtained from the Director for alternate burial locations."
4. Radioactive Materials License #UT1900479, Condition 10.5D: "All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include descriptions of
the ISL waste and the disposal locations, as well as all actions required by this License condition."
5. Radioactive Materials License #UT1900479, Condition 10.5E: "The Licensee shall also submit for
Director approval a revised written Standard Operating Procedure (SOP) for ISL disposal on or
before December 1, 2010. The revised SOP shall describe the documentation required for ISL
disposal, which shall include but is not limited to the following:"
(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an
area of the cell that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material will be segregated from any mill material and equipment disposed
of in the cells pursuant to License Condition 10.4, and the ISL byproduct material from each in
situ leach source will be segregated from the byproduct material from all other in situ leach
sources;
(4) Absence of void space inside barrels disposed, including physical verification before disposal;
and
(5) Detailed engineering drawings which demonstrate:
2 A "source" in this context is a geographically discrete facility. See Letter from Rusty Lundberg to Jo Ann Tischler dated
November 7, 2013 (DRC-2013-005682)
2020 ISR Decommissioning Debris Disposal File Inspection Report
November 17, 2020
Page 3
a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the
tailings cell.
6. Radioactive Materials License #UT1900479, Condition 10.5F: The Licensee shall notify the
Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any
byproduct material generated at ISL facilities in the tailings cells.
An annual summary of the amounts of waste disposed of from off-site ISL generators shall be sent to
the Director on or before November 1 of each calendar year.
Observations
Russell J. Topham, PE of the Utah Division of Waste Management and Radiation Control (the
Division), inspected the files for all loads of 1le.(2) byproduct material received during 2020 on
November 10, 2020 at the White Mesa Uranium Mill (the Mill) owned and operated by Energy Fuels
Resources (the Licensee). In addition to the above requirements, the files were compared against the
mill's governing Standard Operating Procedure, SOP PBL-10, and against the Annual 2020 Summary of
Disposal of 11 e.(2) Byproduct Material dated October 29, 2020 (the Summary). The inspection
examined records of all 20 loads received and buried prior to the inspection date during 2020, from six
generators.
This inspection focused on the Licensee's implementation of Standard Operating Procedure SOP PBL-
10, which governs disposal of 1le.(2) byproduct material from in situ recovery facilities. Incoming
shipments for all materials are subject to another procedure, SOP PBL-19, which was not the subject of
this inspection.
Copies of paperwork reviewed show that the Licensee used revision R-3.4 of SOP PBL-10, dated
February 1, 2018 for all 2020 disposal events. Revision R-3.4 is the most recent version of the
procedure.
The Licensee maintains a map of Tailings Impoundment 3 in the Mill office that shows the dedicated
disposal location assigned for each 1le.(2) debris generator. Examination of that map reveals that if
disposal operations are limited to the lateral extents of the dedicated disposal plots and if the vertical
location of placement of material is limited to within two feet below the upper surface of the tailings,
neither the excavation nor the debris will endanger the integrity of the impoundment liner.
Lateral disposal pit locations are determined and located in the field by survey prior to excavation. The
bottom of the excavations is extended into the tailings sand, and the depth is surveyed prior to placement
of material into the excavation. Once the debris is placed in the excavation and compressed, the top of
debris is surveyed, after which cover soil is placed and compacted. Lateral locations were checked by
the inspector onsite. The examined disposal data packets included survey data that shows that the
vertical placement is below the peripheral top of liner and well above the liner beneath the excavation.
SOP PBL-10 requires that material must be accepted for disposal prior to departure of the transport
vehicle from the generator. This allows the Licensee to ascertain that the material characteristics meet
2020 ISR Decommissioning Debris Disposal File Inspection Report
November 17, 2020
Page 4
the requirements for classification as 1le.(2) byproduct material, and to verify that the quantity to be
shipped will not exceed the 5,000 cubic yard per source limit established in License Condition 10.5A.
Checks of running receipt totals confirmed that the volume limits had not been exceeded. The material
is checked upon receipt to verify that what was shipped is what was expected.
Once the material is accepted for shipment, the receipt and burial are scheduled and the Licensee sends a
seven-day advance notice to the Division of the date scheduled for the burial event and number of loads
anticipated for disposal. The Division received the written notices for all loads disposed.
Observations
Items reviewed during the inspection included:
1. Initiation date for each packet
2. Generator identification
3. Pre-shipment radiological report
4. Certification of absence of RCRA-listed products (RCRA Certification)
5. Shipper's manifest
6. Bill of Lading
7. Scalehouse weigh ticket
8. 7-Day notice to the Division
9. Photos
10. Equipment release form (used to document decontamination)
11. Disposal event-related surveys
12. Disposal date
The above list is more extensive than one generated from the Requirements section of this report, but
reflects the items required in SOP PBL-10.
The data from the individual load data packets were compared to the volumes reported in the Summary,
at which time one load was identified that was not included in the Summary. The omitted load was a
one-time shipment from Weston Solutions of two barrels of soil. The Summary was corrected and a
revised copy has been submitted to the Division.
Except as detailed below, all items reviewed were present and did not indicate violation of the Rules laid
out in the Requirements cited above or deviation from SOP PBL-10.
The data packet for two loads, a truck-and-pup pair simultaneously transported to the mill, lacked the
RCRA Certification. A copy of this document was identified and added to the file. The Rules do not
require retaining this document with the load documentation. However, as a best practice, since the mill
requires the driver transporting the load to carry this document and present it upon delivery of the
material, it seemed prudent to retain the RCRA Certification with the remainder of the load
documentation. 1le.(2) byproduct material cannot contain RCRA-listed material, so taking the
additional step of obtaining and retaining this certificate can become useful should a future need to
document the mill's efforts at restricting disposal activities to qualifying 11e.(2) material emerge.
Conclusions and Recommendations
2020 ISR Decommissioning Debris Disposal File Inspection Report
November 17, 2020
Page 5
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 11e.(2) byproduct material generated as decommissioning debris
from in situ uranium recovery facilities.
At closeout for the inspection, I forwarded a recommendation to retain the RCRA Certification in the
individual load data packets as an additional protection for the mill.