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Home My WebLink AboutDRC-2025-001650 1 of Page 5 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RWP 3-5-2025.docx INSPECTION REPORT Inspection Module: RADMOD-RWP: Radiation Work Permits Inspection Location: Energy Fuels - White Mesa Uranium Mill (Mill), Blanding Utah. Inspection Items: Radiation Work Permits and Supporting Documentation Inspection Dates: March 3 & 4, 2025 Project Number: 479-2025-015 Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control (DWMRC) Adam Wingate, Utah Division Waste Management and Radiation Control (DWMRC) Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RSO) Terry Slade, Radiation Safety Technician (RST) Mike McNamara (TETCO Inc,) Governing Documents: • UAC R313-15 • Radioactive Materials License (RML) UT1900479 • Applicable Mill procedures and manuals o Radiation Protection Manual, Section 5 • NRC Inspection Procedure 89030 Opening Meeting Energy Fuels Resources: Garrin Palmer (RSO) Utah DWMRC: Ryan Johnson (Health Physics Inspector) Adam Wingate (Uranium Recovery Section Manager) During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed during the inspection. The Mill is processing ore at the time of the inspection. The Mill staff reminded the inspector 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 reviewing documentation, a mill tour and interviewing Mill staff. The following discussion provides more detail of the specific items reviewed. 2 of Page 5 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RWP 3-5-2025.docx Item 1. Documentation Review: The inspector reviewed radiation work permits (RWPs) from 2024. The use of RWPs is not a directly specified in the Utah Admin. Code. However, License Condition 9.6 requires the Mill to establish and follow standard operating procedures (SOPs) for all operational and non-operational activities involving radioactive material. The Mill follows the procedures for RWPs found in the Mill’s SOP PBL-RP-5, Book 9: Radiation Protection Manual, Section 5. The purpose of RWPs is to document and evaluate the potential for exposure to radioactive material exists while doing nonroutine jobs for which no standard operating procedures exist. these jobs. (See NRC Regulatory Guide 8.31 Section 2.2) Observations: The DWMRC inspector observed: • The Mill’s RWPs were appropriately filled out and contained the following information: o A unique identification number; o The date the RWP was issued; o A description of the work to be done; o The location where the work is to be done; o Identified the personnel working on the job being done and how much time they were working on the specific job assignment; o The estimated time that it would take to do the job; o The personal protective equipment (PPE) requirements for the job; o The radiological and other occupational monitoring requirements for the job; o The radiation technician observations and surveillance of the job (when applicable); and o The RSO’s signature indicated that he reviewed everything associated with the work that was done under the RWP. • Other documents attached to the RWPs included: o The Mill’s Safe Work permits (SWPs), which document occupational safety concerns (when applicable); o The Mill’s Confined Space Work permits (when applicable); o Lock out/tag out information (when applicable); o Breathing Zone air sample results (when applicable); and o Bioassay results of personnel working on the RWP (when applicable). • The Mill’s dosimetry documentation for the calendar year of 2024 included: Note: The Mill uses Landauer’ Optically Stimulated Luminescence (OSL) badges. o The dosimetry logbook that is used to document what happened to the missing OSL badges (i.e. the employee took the OSL badge home, left the OSL badge in their office or locker, or lost their OSL badge).  Lost OSL badges were replaced with temporary badges; or  The employee was given the same dose as another person that they work with; o The "Employee Exposure to Airborne Radionuclides" tracking form, used by Mill employees to record their work locations and durations. This form, in conjunction with air monitoring data, helps determine the appropriate Derived Air Concentration (DAC) values for calculating each employee's Total Effective Dose Equivalent (TEDE).; and 3 of Page 5 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RWP 3-5-2025.docx o The computer spreadsheet that is used to calculate the annual TEDE for each employee. 2024 Occupational Dose High Low Average TEDE 610 mrem 0 mrem 210 mrem Note: The annual occupational dose limit for a trained radiation worker is 5,000 mrem/year. (R313-15-201(1)(a)(i)) • All forms that were observed were legible and complete. Deficiencies: None Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour included the ore pad, the mill, the tailing impoundments, the cover test pads, and the solvent extraction building. Observations: The DWMRC inspector also observed: • The product yard containing full yellowcake (uranium) and black-flake (vanadium) drums; • Tailings impoundment 4B contains process liquid and tailing sands; • Alternate feed and ore being stockpiled on the ore pad; • All of the Japanese ore has been processed; • OSL badges were appropriately worn by all observed employees at the Mill; • OSL badges are properly being stored; and • Mill personnel were wearing appropriate PPE. Radiological readings observed during Mill tour Location Dose Rate (µrem/hr) Ore Pad 100-300 Mill 50 Chemours 5,000 Product Yard (at fence line) 20 Solvent Extraction Building 40 Packaging Room 70 Deficiencies: None Item 3. Stack Sampling; South Yellowcake Dryer Stack and Grizzly Stack: As part of the RADMOD-ENVIRO inspection module that will be done in August 2025, the DRC Inspectors observed stack sampling as part of this inspection. Observations: The DWMRC inspector observed: • Stack Sampling is contracted out to TETCO Inc.(TETCO); • TETCO performed the stack sampling activities at the White Mesa Mill; • TETCO had a 3-man crews performing the sampling; • TETCO personnel informed the inspector that they were using EPA Method 5 as per the Mill’s Standard Operating Procedure (SOP); 4 of Page 5 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RWP 3-5-2025.docx • At the time of the inspection TETCO were sampling the south yellowcake dryer stack; • Inspectors did not observe TETCO completing EPA methods 1 or 2, but verified the results of these methods; • Inspectors observed TETCO perform successful leak checks before beginning both run on the morning of March 4. No other leak checks were verified.; • The south stack was sampled for a total of 8-hours; • The south stack has an inner diameter of 12.75 inches. As confirmed by EPA method 1, TETCO ran the test using two perpendicular traverses, with each traverse consisting of four sampling points (See Figure 1); • Each point, was sampled three times for twenty minutes each. This resulted in one hour per point, four hours per traverse, and an 8 hour total run time; • Sampling equipment is typically decontaminated prior to use. However, inspectors did not observe set up; • TETCO used equivalent equipment as listed in the Mill’s Environmental Protection Manual, Section 1.4 Stack Sampling, Subsection, 2.1 Sampling equipment; and • Air filters had unique numbers printed on them. Filters are typically placed in a sealed container to be sent to the laboratory, but inspectors did not observe post-sampling work up. Deficiencies: None Closeout Meeting Energy Fuels: Logan Shumway (Mill Manager) Garrin Palmer (RSO) Utah DWMRC: Ryan Johnson (Health Physics Inspector) Adam Wingate (Uranium Recovery Section Manager) Findings None Figure 1 – Illustration of Traverses and Sampling Locations 5 of Page 5 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-RWP 3-5-2025.docx Recommendations None Recommendation for Next Inspection None Prepared By: Ryan Johnson 3/10/2025 (Print Name) (Signature) (Date) Reviewed By: Adam Wingate 3/10/2025 (Print Name) (Signature) (Date)