DRC-2023-002850 - 0901a068811cadb7

March 30, 2023
Dv o "
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APR n 3 2::3
Sent VIA EXPRESS DELIVERY AND E-MAIL
Mr. Doug Hansen
Director, Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4820
Re: White Mesa Uranium Mill-RML UT1900479
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www .energyfuels.com
Safety and Environmental Review Panel ("SERP") Annual Report
Dear Mr. Hansen:
Condition 9.4 D of the White Mesa Mill, State of Utah Radioactive Materials License No. UT 1900479
("RML"), requires that Energy Fuels Resources (USA) Inc. ("EFRI") submit an annual Safety and
Environmental Review Panel ("SERP") Report. Attached is the annual 2022 SERP Report required by
RML Condition 9.4D.
Copies of the Standard Operating Procedures ("SOP") that were revised as a result of these SERPs were
included in the annual transmittal of SOPs which was transmitted to the Division of Waste Management
and Radiation Control ("DWMRC") on December 19, 2022.
If you should have any questions regarding this report please contact me at 303-389-4134.
Yours very truly,
-I{_ m.r ~~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Director, Regulatory Compliance
CC: Scott Bakken
David Frydenlund
Garrin Palmer
Logan Shumway
Terry Slade
DRC-2023-002850
ATTACHMENT A
2021 Annual SERP Report
SAFETY AND ENVIRONMENTAL REVIEW PANEL ("SERP")
2022 ANNUAL REPORT
Submitted to the Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
Submitted by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 30, 2023
1.0 INTRODUCTION
This report is being submitted by Energy Fuels Resources (USA) Inc. ("EFRI"), licensee of the
White Mesa Uranium Mill (the "Mill") to the Utah Division of Waste Management and Radiation
Control ("DWMRC") in compliance with condition 9.4D of State of Utah Radioactive Materials
License No. UT 1900479 ("RML" or the "License").
There were two Safety and Environmental Review Panel ("SERP") evaluations conducted for the
period of January 1, 2022 through December 31, 2022. These SERP evaluations and reviews were
conducted in accordance with SERP procedures set forth in the Mill's Standard Operating Procedure
PBL-1, Rev. No. R-6 (the "SERP SOP"). The evaluations are summarized below in Section 2.0.
2.0 SUMMARY OF EVALUATIONS
This section describes the change, test, or experiment evaluated by the SERP pursuant to License
condition 9.4, and summarizes the evaluations performed and actions taken by the SERP relative to
each.
In each case, the SERP consisted of those individuals specified in License condition 9.4 C, with
additional members included as appropriate, to address specific technical issues.
The SERP followed the SERP SOP as it performed its evaluations, to ensure that the actions taken
satisfy the following three conditions specified in License condition 9.4 B (the SERP Approval
Criteria"):
1) The change, test or experiment does not conflict with any requirement specifically stated
in the License, or impair the licensee's ability to meet all applicable regulations.
2) There is no degradation in the essential safety or environmental commitments in the License
application or provided by the approved reclamation plan.
3) The change, test or experiment is consistent with the conclusions of actions analyzed in the
most recent Environmental Assessment conducted by the Division from the last license
renewal and/or major license amendment.
2.1. SERP Report No. 2022-01 January 27, 2022
Lanthanum Removal During Processing of Rare Earth Bearing Uranium Ore
2.1.1. Proposed Action
The Mill produces rare earth ("RE") carbonates by processing rare earth bearing uranium ("REU")
ores for the recovery of uranium and REs. EFRI plans to reuse existing circuit equipment to remove
lanthanum from the recovered rare earth carbonate products (the "Lanthanum change").
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2.1.2. Descriptions of Change, Tests or Experiments
The proposed process involves the use of an extractant from one or more of the classes of di-alkyl
substituted organo-phosphorus oxide compounds, referred to as phosphinic or phosphonic acids,
which are in the same class as extractants used regularly at the Mill. The proposed process will also
use an additional quantity of 22-degree Baume hydrochloric acid ("HCl''), which is used in the
current RE recovery process. 5N HCl will be prepared at ambient temperature in one of the rubber-
lined steel leach tanks by dilution of the 22° Baume acid as purchased from the supplier. The 5N
HCl will be transferred to one of the fiberglass tanks in the vanadium SX area, which has been
converted for use in lanthanum removal.
2.1.3. Safety and Environmental Evaluation of this SERP Action
In order for a change in the facility or process, as presented in the license application, to be eligible
for approval by the SERP, the three SERP Approval Criteria, detailed in the SERP SOP, must be
satisfied. The three SERP Approval Criteria were reviewed and discussed, as follows:
Does the change conflict with any requirement specifically stated in the license or impair EFRl's
ability to meet all applicable regulations?
The standard operating procedures for the Lanthanum change (the "Lanthanum SOPs")will not
require any types of process operations not currently performed at the Mill. Processes such as
solvent extraction and product stripping, have been regularly performed at the Mill. The Lanthanum
SOPs will not require any new equipment. Existing equipment in the vanadium circuit will be
converted (re-used) periodically for the lanthanum removal step in RE carbonate recovery as needed,
and returned to other service when needed. The chemicals and proposed process as described in the
Lanthanum SOPs will not generate any new air emissions or require revision to the Air Approval
Order ("AO"). HCl will be stored and supplied from the HCl storage tank and air pollution control
systems approved by AO DAQE-ANl 12050024-21 on December 23, 2021.
The SERP identified that there are no Resource Conservation Recovery Act ("RCRA"),
Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), or Toxic
Substances Control Act ("TSCA") requirements applicable to the ore or proposed process chemicals.
Use of the HCl and extractants will noi require any worker protections beyond those currently in use
in other Mill operations.
The Lanthanum 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 determined that the Lanthanum change does not conflict with any requirement stated in
the license or any license requirement contained in any license tie-down letters. Further, the change
does not impair EFRI's ability to meet all applicable regulations. Therefore, this criterion is met.
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Does the change create any degradation in the essential safety or environmental commitments in
the license application, or provided by the approved reclamation plan?
The SERP assessed that there would be no change in the safety or environmental commitments in
the license application or reclamation plan.
Processing according to the Lanthanum 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.
Processing according to the Lanthanum 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 constituents to the tailings system that are detrimental to the tailings
solutions or tailings liner,
• Not produce any new emissions or pathways for exposure to workers or the public,
• Not require any changes to spill control or storm water management plans or drainage
designs,
• 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 Lanthanum SOPs is within the envelope of conditions evaluated in the
Mill's MIL DOS model for dose to off-site receptors.
Processing according to the Lanthanum SOPs will have no effect on the commitments or quantities
addressed in the Reclamation Plan.
Is the change consistent with the conclusions of actions analyzed in the most recent EA conducted
by the Division from the last license renewal and/or major license amendment?
The original 1980 Environmental Assessment ("EA"), subsequent environmental reports, and the
DWMRC Technical and Environmental Report for the Mill contemplated that the Mill would
recover 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 Lanthanum 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.
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2.1.4. SERP Documentation
Condition 9.4D of the RML requires the submission of change pages to the operations plans and
Reclamation Plan of the approved license application to reflect changes made during the SERP
process. 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.
2.1.5. SERP Action
The SERP concluded that the proposed Lanthanum change and Lanthanum SOPs meet the criteria
set forth in the SERP SOP for approval, and approved the Lanthanum SOPs and extractants.
The SERP authorized immediate implementation of the Lanthanum SOPs.
2.1.6. SERP Membership and Qualifications
This SERP consisted of the following members:
Resoonsibilitv Name/Position
Corporate Radiation Safety Officer or Garrin Palmer
equivalent; Mill Radiation Safety Officer (Member)
Assuring Tests conform to radiation safety
and environmental requirements
Management Expertise; David Frydenlund
Responsibility for managerial and financial Chief Financial Officer, General Counsel
approvals and Corporate Secretarv (Member)
Operations and/or Construction Logan Shumway
Management; Mill Manager (Member)
Responsibility for implementing
operational procedures
Responsibility for regulatory compliance at Kathy Weinel
WMM Director, Regulatory Compliance
Corporate responsibility for regulatory Scott Bakken
compliance Vice President, Regulatory Affairs
Independent Safety /Environmental Jo Ann Tischler
Evaluation Independent Chemical Engineering
Consultant
In addition, the following Mill or Corporate Personnel attended the SERP:
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Reason for Attendance N rune/Position
Regulatory and Legal Support to General Julia Hoffmeier
Counsel Corporate Counsel and Assistant
Corporate Secretary
2.2. SERP Report No. 2022-02 December 14, 2022
SOPs for Neodymium/Praseodymium Separation during Uranium Rare Earth Ore
recovery
2.2.1. Proposed Action
Review and approve proposed process and SOP for separation of neodymium ("Nd") and
praseodymium ("Pr") from the currently-produced mixed rare earth intermediate stream.
2.2.2. Descriptions of Change, Tests or Experiments
The Mill intends to modify its existing solvent extraction ("SX") facility by removing an existing
rare earth ("RE") SX circuit and some redundant vanadium SX tanks and replacing them with an
expanded RE SX circuit to be used to purify the currently-produced mixed rare earth chloride
intermediate stream (the "Separation change"). The mixed rare earth chloride solution will be
separated into three streams: a lanthanum/cerium ("La/Ce") chloride waste stream, a
neodymium/praseodymium ("NdPr") product stream, and a mixed mids/heavies product stream
containing REs with atomic masses of samarium and higher and yttrium ("Sm+"). The NdPr
chloride stream will be precipitated using oxalic acid, commercially available in its dihydrate form,
to produce NdPr oxalate. The Sm+ chloride stream will be precipitated using sodium carbonate to
produce a carbonate product, similar to what is currently produced from the existing RE circuit
that will be removed and replaced by the expanded RE SX circuit.
The Mill is evaluating and this SERP assumes packaging and selling an interim NdPr oxalate
product while requirements and equipment related to oxidation to produce Nd2O3 and Pr6Oll are
finalized. The calcining/oxidation step and associated equipment will be evaluated in a separate
SERP process and AO revision process. The SERP evaluated the remainder of the proposed
process described above.
In addition to the proposed process and chemicals, the SERP evaluated the standard operating
procedures (the "Separation SOPs"), which addressed the operation described above.
2.2.3. Safety and Environmental Evaluation of this SERP Action
In order for a change in the facility or process, as presented in the license application, to be eligible
for approval by the SERP, the three SERP Approval Criteria, detailed in the SERP SOP, must be
satisfied. The three SERP Approval Criteria were reviewed and discussed, as follows:
Does the change coriflict with any requirement specifically stated in the license, or impair EFRl's
ability to meet all applicable regulations?
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The Separation SOPs will not require any types of process operations not currently performed at the
Mill. Processes such as solvent extraction and product stripping, have been regularly performed at
the Mill. The Separation change will involve an additional stage of RE product separation using the
same types of solvent extraction equipment as currently and historically used. The Separation
change will require the relocation of some existing mixer-settlers and installation of additional SX
equipment of the same type as currently used, which will be installed within existing buildings.
The SERP identified that there are no RCRA CERCLA, or TSCA requirements applicable to the ore
or proposed process chemicals, HCl or oxalic acid. The chemicals and proposed change and SOPs
will not generate any new air emissions or require revision to the AO. HCl will be stored and
supplied from the existing HCl storage tank and air pollution control system approved by AO
DAQE-ANl 12050024-21 on December 23, 2021
Storage of chemicals will not require construction of new tanks or storage areas. The Separation
change will not require use of electricity, fuel, or water resources beyond levels anticipated in the
license for full Mill production.
There are no reported incompatibilities for NdPr oxide and it can be stored near other products or
reagents.
Use of the HCl and oxalic acid will not require any worker protections beyond those currently in use
in other Mill operations.
The purified and concentrated yellowcake that will be produced from the oreprior to the RE recovery
step will not cause the Mill to exceed the yellowcake production limit under the License.
Based on the above, the SERP determined that the Separation change does not conflict with any
requirement stated in the license or any license requirement contained in any license tie-down letters.
Further, this change does not impair EFRI's ability to meet all applicable regulations. Therefore,
this criterion is met.
Does the change create any degradation in the essential safety or environmental commitments in
the license application, or provided by the approved reclamation plan?
The proposed process 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 constituents to the TMS that are detrimental to the tailings solutions or
tailings liner,
• Not produce any new emissions or pathways for exposure to workers or the public,
• Not introduce any new pathways of contamination to the environment,
• Not increase the disturbed area footprint,
• Require no changes to the Radiation Protection Manual ("RPM"),
• Require no changes to the Environmental Protection Manual ("EPM"),
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• Require no changes to the Emergency Response Plan ("ERP"),
• Require no changes to the ALARA SOP,
• Require no change to the GWDP,
• Require no changes to the training program, and
• Not require additional tailings capacity or changes to tailings management plans,
The SERP assessed that there would be no change in the safety or environmental commitments in
the license application or reclamation plan. Processing according to the Separation 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.
Is the change consistent with the conclusions of actions analyzed in the most recent EA conducted
by the Division from the last license renewal and/or major license amendment?
The original 1980 EA, subsequent environmental reports, and the DWMRC Technical and
Environmental Report for the Mill contemplated that the Mill would recover secondary metals, in
addition to uranium. The original EA contemplated recovery of copper and/or vanadium. 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 measurable 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.
The Separation change will not introduce any new feed materials or new radionuclides. The process
will involve no change to the uranium recovery circuit or radionuclide levels in the uranium recovery
process.
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.
2.2.4. SERP Documentation
The Separation change will Require an update of the Spill Prevention, Control and Countermeasures
Plan ("SPCC") and Stormwater Best Management Practices Plan ("SWBMPP") to incorporate
oxalic acid.
The tailings capacity evaluation 2023 update will confirm that suitable tailings capacity exists for
equipment associated with the proposed Separation change.
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2.2.5. SERP Action
The SERP concluded that the proposed Separation change and Separation SOPs meet the criteria set
forth in the SERP SOP for approval, and approved the proposed process and Separation SOPs.
2.2.6. SERP Membership and Qualifications
This SERP consisted of the following members:
Resoonsibilitv Name/Position
Corporate Radiation Safety Officer or equivalent; Garrin Palmer
Assuring Tests conform to radiation safety and Mill Radiation Safety Officer
environmental requirements (Member)
Management Expertise; David Frydenlund
Responsibility for managerial and financial Executive Vice President, Chief Legal
approvals Officer and Corporate Secretary
(Member)
Operations and/or Construction Management; Logan Shumway
Responsibility for implementing operational Mill Manager (Member)
procedures
Responsibility for regulatory compliance at Kathy Weinel
WMM Director, Regulatory Compliance
Corporate responsibility for regulatory Scott Bakken
compliance Vice President, Regulatory Affairs
Independent Safety /Environmental Jo Ann Tischler
Evaluation Independent Chemical Engineering
Consultant
In addition, the following Mill Personnel attended the SERP:
Reason for Attendance Name/Position
Technical Expertise on Proposed Process Timo Groves
Chief Metallurgist, PE
Worker Safety Expertise Dax Jacobsen
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