DRC-2022-022690 - 0901a0688111cb01

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
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director
M E M O R A N D U M

TO: Project File C-2022-34 THROUGH: Phil Goble, Uranium Mill Section Manager
FROM: Heather Mickelson, PE, PG
DATE: November 14, 2022 SUBJECT: November 2, 2022 Inspection of the Disposal of 11e.(2) Decommissioning Debris from In Situ Leach Facilities at the White Mesa Uranium Mill. Radioactive Material License
No. UT 1900479, Amendment 10.
Authority Radioactive Materials License #UT1900479 Amendment 10, 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 11e.(2) byproduct material generated at licensed in-situ recovery (ISR) [previously known as in-situ leach (ISL)] facilities as per 10 CFR 40 Appendix A, Criterion 2 and from other uranium recovery facilities, subject to the
following conditions:” (Conditions are included below in the Requirements and Compliance Determination section.)
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.”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

1 This definition amends the language given in Section 11e.(2) of the Atomic Energy Act as amended in 1954 to include ISL 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.
11/14/22
11/14/2022
Fourth Quarter 2022 ISL Decommissioning Debris Disposal Inspection Report November 14, 2022
Page 2
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual surveillance obligations.”
Observations Heather Mickelson, PE, PG of the Utah Division of Waste Management and Radiation Control (Division), with Phil Goble, Uranium Mill Section Manager, observed the disposal of two (2) loads of
11e.(2) byproduct material on November 2, 2022 at the White Mesa Uranium Mill. The mill is owned
and operated by Energy Fuels Resources (Licensee). Notification of the disposal was received by the Division on October 19, 2022. Operating Procedures and Records
The Standard Operating Procedure (SOP) PBL-10, dated August 4, 2021, governs the disposal of
11e.(2) byproduct material from ISL facilities. The Licensee maintains hard copies of the buried 11e.(2) material records onsite. Records are moved from the White Mesa Mill’s office building to an onsite storage container within the restricted area when
file space inside the office building becomes limited. These storage locations were verified and
observed during this inspection. Copies of the data packets for each load disposed during this inspection are attached to this report.
11e.(2) Byproduct Material Disposal Activities and Description
Prior to November 2, 2022, the disposal pit locations were determined, located by survey, and excavated. The bottom of the excavations extended into the tailings sand. The 11e.(2) byproduct material was placed near the burial pit for burial (Photos 1 and 2).
During the November 2, 2022 inspection, the Division observed the final disposal activities. Prior to
placement, the excavation depth was surveyed. Once the 11e.(2) byproduct material was in the excavation, the top of the material was surveyed. Clean cover was then placed over the 11e.(2) byproduct material and then compacted to further minimize void spaces (Photos 3, 4, and 5). The vertical extent of the burial was below the top of the tailings and above the bottom liner.

The two (2) loads of 11e.(2) byproduct material was from Strata Energy Inc. Ross Project in Oshoto, Wyoming. The material consisted of supersacks, soil, and fiberglass (Photos 1 and 2). Close Out Meeting
A close out meeting to discuss observations during the inspection included Heather Mickelson, Phil
Goble, Terry Slade, Dean Lyman, and Tanner Holiday. Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition 10.5B: “All ISR 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. ”
Fourth Quarter 2022 ISL Decommissioning Debris Disposal Inspection Report November 14, 2022
Page 3
The activities observed and information gathered during this inspection support the conclusion that the Licensee is complying with this license condition. Pipe was chipped or cut lengthwise prior to placement in the Cell 3. Cut pipe was made of fiberglass that easily crushed when compacted.

Radioactive Materials License #UT1900479, Condition 10.5C: “All ISR byproduct material shall be buried in Impoundment No. 3 unless prior written approval is obtained from the Director for alternate burial
locations.”
The activities observed and information gathered during this inspection supports a conclusion that the Licensee is complying with this license condition. All 11e.(2) byproduct material was buried in Tailings Cell No. 3.
Radioactive Materials License #UT1900479, Condition 10.5D: “All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include all items required by this License.”
The activities observed and information gathered during this inspection support the conclusion that the Licensee is complying with this license condition. The Licensee maintains records of the 11e.(2) byproduct material disposed of onsite. These records document the nature of each load of material
received, where it is buried, and how it was handled, including all measures taken to comply with all of
License Condition 10.5. Radioactive Materials License #UT1900479, Condition 10.5E: “Disposal Requirements for 11e.(2) byproduct material: the licensee shall perform byproduct material disposal activities in accordance with the current Standard Operating Procedure (SOP) for 11e.(2) byproduct material disposal. Said plan includes the
following minimum provisions:
(1) The material disposal area must be located on a tailings beach area of the conventional impoundment or on an area of the impoundment 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 conventional impoundment; (3) (Reserved) (4) Absence of void space inside barrels disposed, including physical verification before disposal; and
(5) Detailed engineering drawings which demonstrate: 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
impoundment.”
The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Licensee met the requirement to submit the procedure with the initial version of SOP PBL-10, and now uses Revision R-3.5, dated August 4, 2021. Revision R-3.5 addresses all of the items specified in License Condition 10.5. The original version and every subsequent revision of this procedure were submitted to the Division for review and approval
prior to implementation.

Fourth Quarter 2022 ISL Decommissioning Debris Disposal Inspection Report November 14, 2022
Page 4
Further, the Licensee is complying with the SOP, such as, minimizing void space, and placing the waste in the tailing sands with at least four feet of sands below it and at least 12 feet from the side or dike of the cell.

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 11e.(2) byproduct
material in the conventional impoundments. An annual summary of the amounts of 11e.(2) byproduct material disposed of from off-site generators shall be included in the Annual Technical Evaluation Report required in License Condition 12.2.”
The activities observed and information gathered during this inspection supports the conclusion that the Licensee is complying with this license condition. The Division received notice of the disposal on October 19, 2022, which complies with the 7 days advance notice requirement.
The annual summary submittal will be evaluated by DWMRC separately from this inspection. Conclusions and Recommendations 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 ISL uranium recovery facilities.

Attachments: 11e.(2) Byproduct Receipt Notification dated October 14, 2022, and received on October 19, 2022 Document packet for Strata Energy, Inc. 11e.(2) byproduct material bearing Bill of Lading # 22-043 #1 and
#2

Photo 1. 11e.(2) byproduct material to be buried. Photo taken on November
2, 2022.
Photo 2. Excavated pit and 11e.(2) byproduct material to be buried. Photo
taken on November 2, 2022.
Photo 3. EFR placing cover over the 11e.(2) byproduct material. Photo taken
on November 2, 2022.
Photo 4. EFR compacting the fill over the 11e.(2) byproduct material. Photo
taken on November 2, 2022.
Photo 5. Final compacted area of the the 11e.(2) byproduct material burial
location. Photo taken on November 2, 2022.
October 14, 2022
VIA Electronic Mail (PDF) and UPS
Mr. Doug Hansen State of Utah Department of Environmental Quality 195 North 1950 West PO Box 144880 Salt Lake City, UT 84114-4880
Dear Mr. Hansen
Re: 1 le.(2) Byproduct Receipt Notification
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809 Blanding, UT. US, 84511 435 678 2221, fax [phone]
www.energyfuels.com
Div of Waste Management and Radiation Control
OCT 1 9 2022
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources (USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White Mesa Uranium Mill will be receiving and disposing of 1 additional load by November 1st, 2022.
If there are any questions regarding these shipments or the scheduling of the disposal activities, feel free to contact me at the White Mesa Mill at 435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files
DRC-2022-021937