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U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RPP 2-13-2025.docx
INSPECTION REPORT
Inspection Module: RADMOD-RPP: Respiratory Protection Program (RPP) Inspection Location: Energy Fuels - White Mesa Uranium Mill (Mill), Blanding Utah.
Inspection Items: Respiratory Protection
Inspection Dates: February 12 & 13, 2025 Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
DWMRC Project #: 479-2025-005 Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RSO)
Terry Slade, Radiation Safety Technician (RST) Justin Perkins, RST Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
• NRC Regulatory Guide 8.15 Opening Meeting Energy Fuels Resources: Garrin Palmer, RSO
Tanner Holliday, Environmental Technician Utah DWMRC: Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documents to be reviewed during the inspection. The Mill was not processing ore at the time of the inspection but has been processing ore since the last inspection. The Mill staff reminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date Dose Rate Bicron B789W 5/21/2025
Inspection Summary The inspection consisted of a RSO interview, reviewing applicable documentation and a mill tour. The following discussion provides more detail of the specific items reviewed.
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U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RPP 2-13-2025.docx
Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC Inspector reviewed the following documents:
• The current Respiratory Protection Manual and confirmed all required respirator protection procedures from R313-15-703 and NRC Reg. Guide 8.15 are covered in the manual;
• The respirator issuance log;
• Respirator Damage Sheet;
• Fit testing and respirator training documentation;
• Respirator survey forms; and
• The Medical Clearance form. Deficiencies: None
Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The
tour included ore pad, the mill, the solvent extraction building, the tailing impoundments, and the respirator room. Observations: The DWMRC inspectors also observed:
• OSL badges were appropriately being used by all observed employees at the Mill;
• Native ore and Alternate feeds are being stored on the ore pad;
• Yellowcake drums are being stored in the storage area;
• Silmet alternate feed material has been processed;
• Most of the Japan ore has been processed;
• Dawn Mining and Calcine alternate feed materials are being processed;
• Respirator room was clean and well organized;
• Respirators were clean and in good repair;
• Meters used to survey respirators were calibrated and in good repair; and
• “Radiation Areas” have been properly posted. The Inspectors spoke with the Safety Technician that performs the fit testing at the Mill. The Mill is using the same equipment and procedures as they have in previous years.
Radiological readings observed during Mill tour
Location Dose Rate (µrem/hr)
Yellowcake Storage area 200 Mill 50
Drum Packaging 80
Solvent Extraction Building 15
Ore Pad 100-200
Chemours 5,000
Japan Ore 100-200
Deficiencies: None
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U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RPP 2-13-2025.docx
Closeout Meeting Energy Fuels:
Garrin Palmer, RSO
Utah DWMRC: Ryan Johnson (Health Physics Inspector)
Findings
None
Recommendations
None
Recommendation for Next Inspection
None
Prepared By: Ryan Johnson 2/24/2025
(Print Name) (Signature) (Date)
Reviewed By: Heather Mickelson 2/24/2025
(Print Name) (Signature) (Date)
Reviewed By: Adam Wingate 3/6/2025
(Print Name) (Signature) (Date)
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UTAH DIVISION OF RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-RPP RESPIRATORY PROTECTION PROGAM
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT1900479 Inspector(s):
Inspection Dates: Start: End: Requirements, Procedures, Policies, Standards:
o Radioactive Materials License UT1900479
o NRC Regulatory Guide 8.15: Acceptable Programs for Respiratory Protection
o Respiratory Protection Program, Book 14, 12/12 Revision EFR-6 (On U: Drive) o Utah Administrative Code R313-15 o NRC IP 89030
OPENING MEETING MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
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DISCUSION
SITE STAFF COMMENTS
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Mill Tour
1) During the Mill tour observe general dose rate/contamination measurements and record.
Area of the Mill Dose Rate (µR/hr)/ Contamination (dpm/100cm2)
DRC Meters Used Model Serial Number Calibration Due Date
Contamination Ludlum 3002
Dose Rate Bicron
Personnel Contacted for this Inspection
Name Job Position/ Title
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Respiratory Protection Program
R313-15-703. Use of Individual Respiratory Protection Equipment
If the licensee or registrant uses respiratory protection equipment to limit the intake of radioactive material: (1) Except as provided in Subsection R313-15-703(2), the licensee or registrant shall use only respiratory protection equipment that is tested and certified by the National Institute for Occupational
Safety and Health.
(2) The licensee or registrant may use equipment that has not been tested or certified by the National Institute for Occupational Safety and Health or for which there is no schedule for testing or certification, provided the licensee or registrant has submitted to the Director and the Director has approved an application for authorized use of that equipment. The application must include a demonstration by
testing, or a demonstration on the basis of reliable test information, that the material and performance
characteristics of the equipment are capable of providing the proposed degree of protection under anticipated conditions of use. (3) The licensee or registrant shall implement and maintain a respiratory protection program that includes:
(a) Air sampling sufficient to identify the potential hazard, permit proper equipment selection, and
estimate doses; and (b) Surveys and bioassays, as necessary, to evaluate actual intakes; and (c) Testing of respirators for operability, user seal check for face sealing devices and functional check for others, immediately prior to each use; and
(d) Written procedures regarding
(i) Monitoring, including air sampling and bioassays; (ii) Supervision and training of respirator users; (iii) Fit testing; (iv) Respirator selection;
(v) Breathing air quality;
(vi) Inventory and control; (vii) Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection equipment; (viii) Recordkeeping; and
(ix) Limitations on periods of respirator use and relief from respirator use; and
(e) Determination by a physician prior to initial fitting of respirators, before the first field use of non-face sealing respirators, and either every 12 months thereafter or periodically at a frequency determined by a physician, that the individual user is medically fit to use the respiratory protection equipment; and (f) Fit testing, with fit factor greater than or equal to ten times the APF for negative pressure devices,
and a fit factor greater than or equal to 500 for positive pressure, continuous flow, and pressure-demand
devices, before the first field use of tight fitting, face-sealing respirators and periodically thereafter at a frequency not to exceed one year. Fit testing must be performed with the facepiece operating in the negative pressure mode. (4) The licensee or registrant shall advise each respirator user that the user may leave the area at any
time for relief from respirator use in the event of equipment malfunction, physical or psychological
distress, procedural or communication failure, significant deterioration of operating conditions, or any other conditions that might require such relief.
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(5) The licensee or registrant shall also consider limitations appropriate to the type and mode of use. When selecting respiratory devices the licensee shall provide for vision correction, adequate
communication, low temperature work environments, and the concurrent use of other safety or
radiological protection equipment. The licensee or registrant shall use equipment in such a way as not to interfere with the proper operation of the respirator. (8) The licensee shall ensure that no objects, materials or substances, such as facial hair, or any conditions that interfere with the face and facepiece seal or valve function, and that are under the control
of the respirator wearer, are present between the skin of the wearer's face and the sealing surface of a
tight-fitting respirator facepiece. (9) In estimating the dose to individuals from intake of airborne radioactive materials, the concentration of radioactive material in the air that is inhaled when respirators are worn is initially assumed to be the ambient concentration in air without respiratory protection, divided by the assigned protection factor. If
the dose is later found to be greater than the estimated dose, the corrected value must be used. If the dose
is later found to be less than the estimated dose, the corrected value may be used. **Note: If they are using MSA or North brand respirators than the answer is yes.
2) Have the respirators that the licensee uses for respiratory protection been tested and certified by the
National Institute for Occupational Safety and Health? (R313-15-703) Yes No N/A Comments:
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3) Upon review of the Respirator Protection Program and Mill procedures, are written procedures in the
following areas implemented and maintained? (R313-15-703(3)(d))(NRC Reg. Guide 8.15 as per L.C. 9.)
Written procedures Yes No
Monitoring, including air sampling and bioassays;
Supervision and training of respirator users;
Training and minimum qualifications of respirator program supervisors and implementing personnel
Training of respirator users, including the requirement for each user to inspect and perform a user seal check (for face-sealing devices) or an operational check (non-face-sealing devices) on a
respirator each time it is donned
Fit testing;
Respirator selection;
Breathing air quality;
Inventory and control;
Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection equipment;
Recordkeeping;
Limitations on periods of respirator use and relief from respirator use;
Performing and documenting the required medical evaluation,
Maintaining TEDE ALARA and performing ALARA evaluations with regard to respiratory protection
Comments:
**Note: You find these records, accept the medical clearance, in the training files. Medical clearance records are now a form that a medical provider signs.
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Respirator Issuance
4) Have the licensee provide a list of 5 respirator users. Do the following users meet the requirements of
R313-15-703 for respirator training?
Name Exams Initial/ Refresher Training Records Medical Clearance Fit Tests
1.
Yes No Yes No Yes No
2.
Yes No Yes No Yes No
3.
Yes No Yes No Yes No
4. Yes No Yes No Yes No
5. Yes No Yes No Yes No
Comments:
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Respirator Maintenance
** Note should be part of the Radiation Safety and Safety Technicians qualification training. They are the
people who maintain and issue the respirators. 5) Has the licensee provided documentation for training of personnel responsible for respirator maintenance and repair? Yes No N/A
Comments:
***Note: The Mill has a special survey form for this.
6) Are used respirators being surveyed after each use? Yes No N/A
Comments:
***Note: The Mill uses disc smears and counts them on Ludlum 3030 or 2929s 7) Are respirators surveyed for removable contamination? Yes No N/A
Comments:
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8) Do respirator surveys properly document the survey performed? Yes No N/A
Comments:
9) Are respirators decontaminated as per Manufacturer’s Instructions? Yes No N/A
Comments:
10) Are respirators inspected in accordance with the licensee’s Respiratory Protection Program?
Yes No N/A Comments:
**Note: Mills Safety department does inhouse respirator fit testing.
11) Observe respirator fit testing Comments:
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*** Note: They are supposed to use disc smears and count the disc smears 12) Check the meters used to survey respirators
Comments:
Meter Type Model Serial Number Meter Condition Calibration Due Date
Comments:
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***Note: I usually take the respirators apart to verify every part of the respirators are being cleaned and maintained.
13) Visually inspect 6 respirators.
Yes No
Visibly clean Cracks in the face mask
Tears in the seal area or face piece
Excessive scratching of the facemask Tears in straps
Comments:
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Other
14)
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CLOSEOUT MEETING DATE______________________
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
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DISCUSSION of FINDINGS
SITE STAFF COMMENTS