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Home My WebLink AboutDRC-2022-023728 - 0901a0688113452f\\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-SERP 2021.docx Page 1 of 5 UTAH DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-SERP-01 SAFETY AND ENVIRONMENTAL REVIEW PANEL ANNUAL REPORT REVIEW ENERGY FUELS RESOURCES- WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT1900479 References: Utah Administrative Code RML UT 1900479 License Condition 9.4 Year Reported Date of Report Date of Review 2021 March 31, 2022 April 8, 2022 1) Describe what subject(s) were reviewed by the Mill’s SERP. Subject 1: EFRI plans to add equipment within the existing footprint of the Mill buildings and reuse existing circuit equipment for the recovery of rare earth carbonates, prior to uranium recovery, from REU ores. Using primarily existing Mill facilities and equipment, with no significant changes at this time, the Mill will recover the uranium from the REU and will produce a commercial rare earth ("RE") carbonate concentrate that can be sold to an RE separation facility for the production of RE oxides. The SOPs will not require any types of process operations not currently performed at the Mill. Processes such as digestion, and precipitation and dewatering of products from aqueous solutions, have been regularly performed at the Mill. The SOPs will not require any new types of equipment not currently used in Mill processes. The centrifuges to be added are equipment historically used at the Mill and will be added within the current footprint of the Mill buildings. The Change will not require use of electricity, fuel, or water resources beyond levels anticipated in the license for full Mill production. The purified and concentrated yellowcake that will be produced will not cause the Mill to exceed the yellowcake production limit under the License. The SERP also assessed that there would be no change in the safety or environmental commitments in the license application or reclamation plan. Processing according to the SOPs will: • Not produce any increased levels of radionuclides in processes or wastes beyond those anticipated in the EAs or previously managed under approved SOPs, • Not introduce any new constituents to the tailings system, • Not produce any new emissions or pathways for exposure to workers or the public, • Not require any changes to spill control or storm water drainage designs or the associated plans, • Not require additional tailings capacity or changes to tailings management plans, and • Not introduce any new pathways of contamination to the environment. Processing according to the SOPs is within the envelope of conditions evaluated in the Mill's Processing according to the SOPs will have no effect on commitments or the quantities addressed in the Reclamation Plan. The original 1980 Environmental Assessment, subsequent environmental reports, and the DWMRC Technical and Environmental Report for the Mill contemplated that the Mill would recover \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-SERP 2021.docx Page 2 of 5 secondary metals, in addition to uranium. The Mill has also previously been approved to recover, and has modified the process to recover, tantalum and niobium. The process will not generate any new tailings constituents not already monitored or addressed by other indicator parameters in the groundwater discharge permit ("GWDP"). The process will produce no new or increased air emissions. The tailings to be generated will be comparable to, and contain comparable non-radiological constituents, as the tailings previously generated and managed in the tailings management system. Processing according to the SOPs is not expected to produce any environmental impacts beyond those assessed in any EA, and is consistent with the conclusions regarding actions analyzed in the EAs. As a result, this criterion is also satisfied. Subject 2: Review and approve proposed revisions to the White Mesa Mill (the "Mill") Radiation Protection Manual ("RPM"). The Mill Radiation Safety Officer ("RSO") reviews all Mill Standard Operating Procedures ("SOPs") annually as required by Nuclear Regulatory Commission ("NRC") Regulatory Guide 8.31 Section 2.2. During the 2021 annual review the RSO proposed two changes to the RPM SOP-PBLRP- 1, Sections 1.1.2.8 and 1.4.5. The specific changes are as follows: 1. Section 1.1.2.8 states that duplicate samples will be submitted for breathing zone ("BZ") samples. The requested change is to remove the specification of samples being "submitted". The text as written is inconsistent with current procedures and analysis methods for BZ samples. The language refers to and was used for an analysis method for BZ samples no longer employed at the Mill. Change number 1 to the RPM does not conflict with any requirement specifically stated in the license or applicable NRC Regulatory Guides. There are no regulations or guidance that require use of the previous method for analysis of BZ samples involving the digestion of the filters followed by analysis with Mill laboratory instrumentation, or that would preclude the use of the current procedure of counting area airborne samples twice after the waiting period, using 2 different alpha counters, which provides a quality control check equivalent to a duplicate analysis performed by the Mill laboratory. 2. Section 1.4.5 states that "Urinalysis results should be completed and reported to the Radiation Safety Department within 7 days of sample collection." This turn- around-time ("TAT") is unreasonably restrictive and does not agree with the NRC Regulatory Guide 8.22 for Bioassays at Uranium Mills. Further, the 7-day TAT noted in the RPM does not take into account staggered/offset work schedules which preclude the collection and analysis in 7 days. The RSO suggested changing the bioassay TAT to agree with the TAT as specified in Regulatory Guide 8.22. Change number 2 to the RPM does not conflict with any requirement specifically stated in the license or applicable NRC Regulatory Guides. There are no regulations or guidance that would prevent changing the TAT for receipt of bioassay data from 7 days from collection to 20 days from collection, which is appropriate in light of the staggered/offset work schedules employed at the Mill. In fact, changing the TAT to 20 days is the TAT specified in NRC Regulatory Guide 8.22. \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-SERP 2021.docx Page 3 of 5 Based on the above, the SERP determined that both Change number 1 and Change number 2 do not conflict with any requirement specifically stated in the license or impair EFRI's ability to meet all applicable regulations. This criterion is therefore met. 2) Did the subject(s) meet the criteria found in License Condition 9.4.A? Yes _X__ No_____ Explain: Subject 1:. The SERP reviewed the facility, process and procedures described above and determined that: • Making changes in the procedures is within the authority of the SERP Committee. Subject 2: The SERP reviewed the Procedure described above and determined that: • Making changes in the procedure is within the authority of the SERP committee. DWMRC Staff Review: Subject 1 was a review of existing facility, processes and procedures. Therefore, the subject reviewed by the SERP met the criteria in License Condition 9.4.A. Subject 2 was a change in an existing procedure. Therefore, the subject reviewed by the SERP met the criteria in License Condition 9.4.A. 3) Did the subject(s) meet the criteria found in License Condition 9.4.B? Yes __X__ No_____ Explain: Subject 1: • The SERP determined that the change does not conflict with any requirement stated in the license or any license requirement contained in any license tie-down letters. Therefore, this criterion is met. • The SERP determined that there are no changes required to the operational documents or Reclamation Plan required as the result of this SERP and as such, no change pages are required. • The SERP determined that processing the rare-earth/uranium ore according to the SOPs is not expected to produce any environmental impacts beyond those assessed in any EA, and is consistent with the conclusions regarding actions analyzed in the EAs. As a result, this criterion is also satisfied. Subject 2: The SERP determined that the changes to the SOPs does not conflict with any requirement stated in the license or any license requirement contained in any license tie-down letters. Therefore, this criterion DWMRC Staff Review: Subject 1: The requirements for 9.4.B were met and the Licensee does not need to amend their license. Subject 2: The requirements for 9.4.B were met and the Licensee does not need to amend their license. 4) Did the SERP members meet the expertise criteria found in License Condition 9.4.C? Yes X , No_____ \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-SERP 2021.docx Page 4 of 5 Subject 1: Rare Earth, Uranium ore recovery Person and/or Job Title Managerial and Financial David Frydenlund, Chief Financial Officer, General Counsel and Corporate Secretary Operations and/or Construction Logan Shumway, Mill Manager Radiation Safety Terry Slade, Radiation Safety Officer Other: Corporate responsibility for regulatory compliance Scott Bakken, Vice President Regulatory Affairs Other: Responsible for regulatory compliance at the White Mesa Mill Kathy Weinel, Director Regulatory Compliance Other: Implementation of Environmental and Radiation Safety Practices Garrin Palmer, Assistant Radiation Safety Officer Other: Regulatory and Legal Support to General Counsel Julia Hoffmeier, Corporate Counsel and Assistant Corporate Secretary Other: Independent Safety/Environmental Evaluation Jo Ann Tischler, Independent Chemical Engineering Consultant Explain: DWMRC Staff Review: Documented members of the SERP Committee meet the requirement. Subject 2: Revision to the Radiation Protection Manual Person and/or Job Title Managerial and Financial David Frydenlund, Chief Financial Officer, General Counsel and Corporate Secretary Operations and/or Construction Logan Shumway, Mill Manager Radiation Safety Garrin Palmer, Radiation Safety Officer Other: Corporate responsibility for regulatory compliance Scott Bakken, Vice President Regulatory Affairs Other: Responsible for regulatory compliance at the White Mesa Mill Kathy Weinel, Director, Regulatory Compliance Other: Implementation of Environmental and Radiation Safety Practices Terry Slade, Assistant Radiation Safety Officer Explain: DWMRC Staff Review: Documented members of the SERP Committee meet the requirement. 5) Did the SERP Annual Report meet the criteria found in License Condition 9.4.D? Yes X No____ Explain: DWMRC Staff Review: The SERP report was submitted prior to March 31of the following year. Changes to the existing procedure was included with the 2021 SOP transmittal. The SERP followed the Mills operating procedure for SERP reviews. Therefore, the SERP report did meet all of the criteria in License Condition 9.4.D. Staff will verify that records are being maintained in a future site inspection. \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-SERP 2021.docx Page 5 of 5 Identified Deficiencies: None Report Reviewed By: Ryan Johnson 4/8/2022 (Print Name) (Signature) (Date) Supervisory Review By: Phil Goble 4/11/2022 (Print Name) (Signature) (Date)