DRC-2023-003306 - 0901a068811d8d2f

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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
2022 March 30, 2023 April 8, 2022
1) Describe what subject(s) were reviewed by the Mill’s SERP.
Subject 1: 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 ("HCI''), 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.
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 not 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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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 MILDOS 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. The original 1980 Environmental Assessment, 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 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 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 sainarium 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 Nd203 and Pr6011 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.

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In addition to the proposed process and chemicals, the SERP evaluated the standard operating 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 ore prior 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. 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"), • 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
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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.

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) 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 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. Subject 2:
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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.
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_____ 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 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: 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: Independent Safety/Environmental
Evaluation
Jo Ann Tischler, Independent Chemical
Engineering Consultant
Other: Technical Expert on Proposed Process Timo Groves, Chief Metallurgist, PE
Other: Worker Safety Expertise on Proposed Process Dax Jacobsen
Explain:

DWMRC Staff Review: Documented members of the SERP Committee meet the requirement.

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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. 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.

Identified Deficiencies: None

Report Reviewed By: Ryan Johnson 4/17/2023
(Print Name) (Signature) (Date)
Supervisory
Review By: Phil Goble 4/17/2023
(Print Name) (Signature) (Date)