DRC-2024-005492

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. 711
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: 2023 HP White Mesa Mill Inspection Folder
THROUGH: Phil Goble (U-Mill/RAM Section Manager) 8/24/2023
Heather Mickelson (U-Mill Engineer) 8/24/2023
FROM: Ryan Johnson (U-Mill HP Inspector) 8/24/2023
DATE: 8/23/2023
SUBJECT: ALARA Issue with 11e.(2) Disposal at the White Mesa Mill
Background
On August 14, 2023, an inspection was conducted at White Mesa Uranium Mill (Mill) by Ryan Johnson
and Heather Mickelson, representatives of the Division of Waste Management and Radiation Control
(Division) of the Utah Department of Environmental Quality. Brandi O’Brian from the State of
Wyoming accompanied the inspection as part of the Nuclear Regulatory Commission’s (NRC) IMPEP
team for the 2023 review of State of Utah’s Agreement State program. As part of this inspection the
Division Inspectors observed 11e.(2) disposal activities on tailing impoundment #3. During this
observation it was noticed that some material from a previous 11e.(2) disposal activity was not
completely buried. Ms. O’Brian pointed it out to Ms. Mickelson and Ms. Mickelson asked the Mill
employee accompanying the Inspectors to put the material into the disposal trench. Upon request the
Mill employee did what was requested and picked up the material by hand and threw it into the disposal
trench. It was noted by Ms. O’Brian that the White Mesa employee was not wearing gloves when he
picked up material and threw it into the trench. After the 11e.(2) disposal activities the Inspectors and
the Mill employee went back the Administration Building and scanned out of the restricted area using a
hand held Alpha scintillator (The Mill uses Ludlum Model 177 meters with an Alpha probe). The
radiation scans of the Inspectors and the employees did not detect any contamination.
During the preliminary closeout meeting with Mill management, the inspectors explained what they had
observed regarding the interaction with the 11e.(2) material by Mill personnel sans gloves.
Page 2

Note: 11e.(2) Disposal is when 11e.(2) material from other uranium recovery facilities such as ISRs
comes to the White Mesa Mill to be buried in tailings impoundment #3. These disposal activities are
authorized under 10 CFR 40 Appendix A Criterion #2 and referenced in State of Utah rules in R313-24.
The total amount of 11e.(2) material that the White Mesa Mill can receive and where it can be buried is
in Utah Radioactive Material License UT1900479 License Condition 10.5.

Issue

On August 23, 2023, in a conference call between the NRC and Division Management, the NRC
brought up the observation that the Mill employee picked the 11e.(2) material and threw it into the
disposal trench with no gloves on. The NRC indicated that they saw this as an ALARA issue and
expected the Division to take the appropriate action to address it. The NRC indicated that they would
follow-up with the Division on this issue when they come to Utah in September of 2023.

Mill’s Corrective Response

After the NRC shared their concerns with Division Management, that same day, Phil Goble contacted
the Inspectors and asked them to follow-up with the Mill. Ryan Johnson contacted Kathy Weinel,
EFRI’s Director Regulatory Compliance, and Garrin Palmer, Mill’s Radiation Safety Officer, and
discussed the NRC’s ALARA issue. It was determined that the Mill would document this issue in their
annual ALARA Report and that the SOP for 11e.(2) disposal would be revised to include gloves as
required PPE and how loose 11e.(2) material will be handled in the future. The Mill also committed to
additional training on 11e.(2) disposal for their personnel.

Division Follow-up

The Division will follow-up on this issue on September 13th and 14th, when the next HP inspection will
occur. The Division will also follow-up during the next 11e.(2) disposal engineering inspection and
during the ALARA HP inspection performed by Division Staff in November of 2023.

Note: Via email on August 24, 2023, EFRI submitted a redline/strikeout version of their revised 11e.(2)
Disposal SOP for Division review addressing the concern identified during the August 14, 2023
inspection.