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Home My WebLink AboutDRC-2025-002076 1 of Page 6 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-PEM w Emergency 6-10-25.docx INSPECTION REPORT Inspection Module: RADMOD-PEM: Surveys/Posting/Exit Monitoring Project Number 479-2025-026 Inspection Location: Energy Fuels - White Mesa Uranium Mill (Mill), Blanding Utah. Inspection Items: Radiological Postings, Weekly Alpha Surveys and Employee Exit Monitoring Inspection Date: June 10 & 11, 2025 Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control (DWMRC) Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RSO) Tanner Holliday, Environmental Technician Deen Lyman, Environmental Technician Abel Mendoza Jr., Safety Technician Dax Jacobsen, Safety Manager Governing Documents: • UAC R313-15 • Radioactive Materials License (RML) UT1900479 • Applicable Mill procedures and manuals Opening Meeting Energy Fuels Resources: Garrin Palmer (RSO) Utah DWMRC: Ryan Johnson (Health Physics Inspector) During the opening meeting: • The Inspector discussed the inspection items for the inspection; • The Mill staff reminded the inspector of the safety requirements for the Mill; DWMRC Meters Used Model Serial Number Calibration Due Date Dose Rate Bicron B288K 5/1/2026 Contamination L2360 237303 4/1/2026 2 of Page 6 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-PEM w Emergency 6-10-25.docx Inspection Summary The inspection consisted of: • Observing radiological postings around the Mill; • Observing Mill personnel perform exit surveys: • Reviewing documentation of: Exit Monitoring; and • Taking dose rate measurements and contamination swipes around the Mill. The following discussion provides more detail of each inspection item. Item 1. Radiological Postings: Observations: During the Mill Tour the inspector observed the following posted areas: Posting Locations Observed Postings Observed Dose Rates (µrem/hr) Yellowcake Storage Area Caution Radiation Area 40 (Fence Line) 1,000-3,000 (YC Drums) Laboratory Metallurgic Caution Radioactive Materials NA Laboratory Chem Caution Radioactive Materials NA Doors leading to the restricted area from the Administration building Any Area within this Mill May Contain Radioactive Material Background Bucking Room Caution Airborne Area 300 Yellowcake Packaging Room Caution Radiation Area Caution Airborne Area 90 South Dryer Caution Radiation Area Caution Airborne Area 200 North Dryer Caution Radiation Area Caution Airborne Area 150 Pinon Plain ore Caution Radiation Area 4,000-5,000 Fixed Gauges Caution Radioactive Materials 1,100 Perimeter fence Caution Radiation Area Background Perimeter gates Any Area within this Mill May Contain Radioactive Material Background Ore Pad No Postings 50-200 Solvent Extraction Building No Postings 15 Mill Building No Postings 70 Note: Due to no uranium production at the time of the inspection there are fewer posted areas in the Mill. The Inspector determined that all of the postings observed were legible and appropriate. 3 of Page 6 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-PEM w Emergency 6-10-25.docx The Inspector also collected large area swipe samples in 13 areas within the restricted area. Location Alpha (dpm/100cm2) Beta (dpm/100cm2) Scale House 13 <Background Lunch Room 2 <Background Lunch Room #2 <Background <Background Locker Room <Background <Background Control Room 22 75 Laboratory Metallurgic 10 <Background Laboratory Chem 5 <Background Bucking Room 475 1533 Maintenance Office 10 <Background Warehouse 3 <Background Admin Offices 13 <Background Admin Breakroom <Background <Background Yellowcake Drum 7 <Background Deficiencies: None Item 2. Radiological Surveys and Monitoring: The Inspector reviewed the weekly surveys done around the Mill. Observations: The Inspector reviewed the radiological monitoring documentation performed at the Mill site. The documentation indicated that: • All areas of the Mill are being surveyed for radiological conditions; • Surveys indicate that the Mill is being maintained within regulatory radiological parameters • Documentation is legible, complete and using appropriate units; and • “Clean” areas are being maintained. Meter Type Model Meter Serial # Probe Serial # Cal. Due Meter Condition Alpha Scintillator Ludlum 3 337536 PR378523 3/31/2026 Good Alpha Scintillator Ludlum 3 236288 PR281511 12/18/2025 Good Alpha Scintillator Ludlum 3030 37956 PR503283 11/9/2025 Good Alpha Scintillator Ludlum 3030 247394 PR263686 10/30/2025 Good Deficiencies: None Item 3. Exit Surveys: The Inspector observed employees survey themselves out of the restricted area and checked the alpha meter used. Observations: The Mill uses Alpha scintillators for exit surveys. The Inspector checked the settings of the survey instruments and found that they were set properly. Meters are calibrated annually. The Mill personnel that were observed performing exit surveys, did the surveys appropriately. The Mill’s RSTs also perform random checks on exit surveys. 4 of Page 6 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-PEM w Emergency 6-10-25.docx Meter Location Model Meter Serial # Probe Serial # Cal. Due Alarm Setting West Admin. Door Ludlum 177 322900 PR19024 8/12/2025 60 East Admin. Door Ludlum 177 189581 PR19024 2/3/2026 60 Lab Admin. Door Ludlum 177 264740 PR191566 2/3/2026 60 Lunch Room Ludlum 177 159120 PR192467 8/5/2025 60 Lunch Room #2 Ludlum 177 264743 RN16489 12/4/2025 60 East Decon Gate Ludlum 177 322883 PR392603 12/4/2025 60 Deficiencies: None Item 4. Vegetation Sampling: As a part of the RADMOD-SEM-ENVIRO inspection to be done in August 2025, the Inspector observed the Mill’s Environmental Technicians collect vegetation samples. Note: Vegetation samples are collected three times a year; once in the Spring, once in early summer and once in the Fall. Observations: The DWMRC inspector observed: • Collect vegetation from 3 different areas vegetation sampling is collected on the Mill property; • Collected more than 3,000 grams of vegetation material from each area; • The sampled material was placed in large plastic bag; and • Each bag was marked with location, date and time of sampling. Deficiencies: None Item 5. Emergency Preparedness Plan: Note: This part of the inspection was originally going to be done in April with the DOT inspection but due to time constraints this portion of the inspection was not done and April. Observations: The Inspector toured the Mill facility and observed: • The seven fire stations; • The four fire hoses in the Mill; • The four evacuation points. The signs marking the evacuation points are legible; and • The 440,000 gallon water tank that supports the water suppressing system. In discussions with the Safety Technician during the tour there are fire sprinkler systems in the SX, warehouse/maintenance building and the Administration building. The Inspector reviewed the following documents: • Emergency Response Plan; 5 of Page 6 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-PEM w Emergency 6-10-25.docx • Fire and Evacuation Drill forms; • Fire Station Equipment lists; • Quarterly Equipment Checklist; and • Quarterly Fire Hydrant Checklist The Mill’s Emergency Response Plan meets all of the requirements for an Emergency Response Plan found in R313-22-32. The Inspector also interviewed the Safety Technician. During the interview, the Safety Technician discussed with the Inspector how the Mill conducts 1/4ly drills. The 1/4ly drills alternate between fire drills and evacuation drills so that there are two of each within the calendar year. The evacuation drills consisted of turning on the emergency siren and timing how long it would take for Mill personnel to meet at the designated assembly areas. The fire drills the Mill’s fire brigade train with firefighting equipment. The drills were evaluated by the Safety Manager and technicians and brief reports are written. The Inspector, Safety Technician and the Safety technician discussed that during these drills the Mill should try to use scenarios that could happen at the Mill (i.e. fire or confined space) to give their emergency response team realistic training. The Mill participates in the San Juan Local Emergency Planning Committee (LEPC) which meets quarterly. According to the San Juan County Emergency Management webpage the LEPC Deficiencies: The fire and evacuation forms are incomplete and lack detailed information. Also the 1st quarter drill indicated that the alarm could not be heard in the respirator room but there was no follow up recorded to document how that issue was resolved. The 1/4ly equipment check forms indicated that some equipment was missing but there was no documentation stating how the issue was being resolved. During the closeout meeting Mill staff indicated that these issues were also identified by the ALARA audit in April. Therefore the Inspector will follow up on these findings. Closeout Meeting Energy Fuels: Garrin Palmer (RSO) Abel Mendoza Jr. (Safety Technician) Utah DWMRC: Ryan Johnson (Health Physics Inspector) Recommendations Follow up on Emergency Response corrective actions in June of 2026. Recommendation for Next Inspection None 6 of Page 6 U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2025\Inspection Reports\Inspection Report RADMOD-PEM w Emergency 6-10-25.docx Prepared By: Ryan Johnson 6/26/2025 (Print Name) (Signature) (Date) Reviewed By: Adam Wingate 6/26/2025 (Print Name) (Signature) (Date) Page 1 of 25 UTAH DIVISION OF WASTE MANAGEMENT & RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-PEM ROUTINE RADIOLOGICAL SURVEYS/POSTINGS/EXIT MONITORING ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT1900479 References: • Radioactive Material License UT1900479 • License Renewal Application dated February 28, 2007 • Radiation Protection Manual, Book #9, Sections 1 and 2 • ALARA Program Manual, Book #12, Section 2 • 10CFR20 • Utah Administrative Code R313-15 • NRC IP 89030 Date of Inspection: Inspector(s) DATE______________________ OPENING MEETING MEETING MEMBERS NAME DRC/COMPANY CONTACT INFORMATION 6/10&11/25 Ryan Johnson Garrin Ryan Page 2 of 25 DISCUSSION SITE STAFF COMMENTS Page 3 of 25 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 Dose Rate Personnel Contacted for this Inspection Name Job Position/ Title YC Drum 7Alpha <Bkg Beta Ore Pad 50-200 urem Mill 70 urem SX 15 urem Locker Room <Bkg Alpha < Bkg Beta Lunch Room #2 Dpm Warehouse Dpm Garrin Tanner Deen Jr Dax Jacobsen Page 4 of 25 RADIOLOGICAL POSTINGS 2) On Mill Tour note the type of postings observed Location Type of Posting(s) Legible Y/N Dose Rate Product Yard Caution Radiation Area Yes 40 urem/hr perimeter 1,000-3,000 next to YC drums Caution Radiation Area Yes 4,000-5,000 Caution Radiation Area Yes 3,000-5,000 Caution Radiation Area Yes 90 urem perimeter Airbourne Yes Caution Radioactive Materials Yes 1,100 Caution Radiation Area Yes 200 urem Airbourne Yes Caution Radiation Area Yes 150 urem Airbourne Yes Pinion Plains Ore Chemours Packaging Room Fixed Gauge South Dryer North Dryer Page 5 of 25 Location Type of Posting(s) Legible Y/N Dose Rate Bucking Room Airbourne Yes 300 475 Alpha 1,533 Beta Radioactive Material Yes Dpm Radioactive Material Yes Dpm Caution Radioactive Material Yes No Trespassing Any Area within this mill May Contain Radioactive Material Yes Maintenance Shop Dpm Scale House Dpm Control Room Dpm Admin Ofﬁce Dpm Admin Break Areas Dpm Locker Room Dpm Metal Lab Chem Lab Perimeter Fence (West Side) Restricted Area Doors and Gates Page 6 of 25 License Condition 9.9 states: The licensee is hereby exempted from the requirements of R313-15-902(5) for areas within the mill, provided that all entrances to the mill are conspicuously posted in accordance with R313-15-902(5) and with the words, “Any area within this mill may contain radioactive material”. 3)Has the licensee conspicuously posted all entrances to the mill in accordance with R313-15-902(5)and with the words, “Any area within this mill may contain radioactive material”? Yes____ No____ Comments: Utah Administrative Code R313-15-902(1) requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIATION AREA." 10CFR20.1003 defines a Radiation Areas as an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem (0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates. 4)Were all radiation areas posted in accordance with R313-15-902(1)? Yes____ No _____ Comments: 5)Were all posted Radiation Area boundaries found to be ≤ 5mrem/hr? Yes____ No _____ Comments: X X X Page 7 of 25 As required by Utah Administrative Code R313-15-902(4), the licensee or registrant shall post each airborne radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, AIRBORNE RADIOACTIVITY AREA" or "DANGER, AIRBORNE RADIOACTIVITY AREA." 6) Has the licensee employed the proper postings for Airborne Radioactivity Areas in accordance withR313-15-902(4)? Yes____ No _____ Comments: 7) Were all radiological postings observed found to be legible, conspicuously posted and unobstructed? Yes____ No _____ Comments: X X Page 8 of 25 EXIT SURVEYS Radiation Protection Manual Section 1.2.1, Restricted Area, states “All personnel who enter the Restricted Area will monitor themselves each time they leave the Restricted Area and at the end of their shift. The Radiation Safety Department will review the monitoring information. All personnel exiting the Restricted Area must initial a record of their monitoring activity.” 8) Did all employees observed monitor themselves in accordance with the Radiation Protection Manual Section 1.2.1 upon exit from the Restricted Area? Yes____ No _____ Comments: Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to perform proper personnel monitoring. 9)Were all exit monitor (count rate meter) alarms adjusted within the range of 500 to 750 dpm/100cm2? (Note: Because the Ludlum Model 177 reads out in counts per minute, ensure proper calculations were used to achieve a 500 to 750 dpm/100cm2 range). Yes____ No _____ Meter Location Model Meter Serial # Probe Serial # Cal Due Alarm Setting East Door West Door Lab Door Decon Gate Lunchroom #1 Lunchroom #2 Alarm rate meter setting < 1,000 dpm/100 cm2 Comments: dpm = cpm - BKG efficiency X The Mill also does Employee Spot Alpha Surveys and they document those spot surveys with the weekly alpha surveys X Ludlum-177 189581 PR19024 2/3/2026 60 Ludlum-177 322900 PR359816 8/12/2025 60 Ludlum-177 264740 PR191566 2/3/2026 60 Ludlum-177 322883 PR392603 12/4/2025 60 Ludlum-177 159120 PR192467 8/5/2025 60 Ludlum-177 264743 RN16489 12/4/2025 60 All meters appeared in good condition Page 9 of 25 10)Did all observed personnel exiting the Restricted Area slowly survey their hands, clothing and shoes, including the shoe bottoms, at a distance from the surface of approximately ¼ inch? Yes____ No _____ Comments: 11)Has the licensee provided documentation of individual (exit) surveys being logged and initialed? Yes____ No _____ Comments: ROUTINE SURVEYS The Mill’s Radiation Protection Manual, Appendix E, Section 2.3 requires the licensee to perform alpha surveys, both fixed and removable, at regular intervals in particular areas of the Mill. Table 2.3.2-1 lists the areas to be surveyed. Section 2.3.2 requires the listed areas to be surveyed on a weekly basis during production periods. During non-production periods, only those areas designated by the RSO as authorized lunchroom/break areas are monitored. 12)What dates within the last year was the Mill considered in “production periods” and in “non-production periods”?Comments: X All observed employees scanned themselves out correctly X Yes, they have separate sign out sheets for contractors/truck drivers, west guardhouse, east guardhouse, lunch rooms and each admin door. The weekly alpha surveys are all the same during production and non-production periods Page 10 of 25 Table 2.3.2-1 White Mesa Mill Alpha Area Survey Locations Location Area Surveyed Y/N Surveys Documented on Daily/Weekly Inspection Reports Y/N Contamination Survey Results (dpm/100cm2) Scale House Table Warehouse Office Desks Maintenance Office Desks Change Room Lunch Tables Maintenance Lunchroom Tables CCR Tables Metallurgical Laboratory Desks Chemical Laboratory Desks Administrative Break Room Counter Administrative Office Desks 13)Check the meters used Comments: Meter Type Model Meter Serial Number Probe Serial Number Meter Condition Calibration Due Date Comments: Y Documented on Weekly Alpha Survey Sheets Y Same Y Same Y Same Y Same Y Same Y Same Y Same Y Same Y Same Ludlum 3030E 371956 PR503283 Good 11/6/2025 Ludlum 3030E 247394 PR263686 Good 10/30/2025 Ludlum 3 337536 PR378523 Good 3/31/2026 Ludlum 3 236288 PR281511 Good 12/18/2025 13 Alpha <Bkg Beta 3 Alpha <Bkg Beta 10 Alpha <Bkg Beta <Bkg Alpha <Bkg Beta <Bkg Alpha <Bkg Beta 2 Alpha <Bkg Beta 22 Alpha 75 Beta 10 Alpha < Bkg Beta 5 Alpha <Bkg Beta 13 Alpha < Bkg Beta Page 11 of 25 14) During production periods, were all areas listed in Table 2.3.2-1 surveyed for removable alpha as per Section 2.3.2? Yes____ No _____ Comments: 15) During production periods, were all areas listed in Table 2.3.2-1 surveyed for fixed alpha as per Section 2.3.2? Yes____ No _____ Comments: 16) During non-production periods, were all areas designated by the RSO as authorized lunchroom/break areas surveyed for removable alpha as per Section 2.3.2? Yes____ No _____ Comments: X X X Page 12 of 25 17) During non-production periods, were all areas designated by the RSO as authorized lunchroom/break areas surveyed for fixed alpha as per Section 2.3.2? Yes____ No _____ Comments: X Page 13 of 25 R313-22-32. Filing Application for Specific Licenses. (8)(a) Applications to possess radioactive materials in unsealed form, on foils or plated sources, or sealed in glass in excess of the quantities in Section R313-22-90, "Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency Plan for Responding to a Release", shall contain either: (c) An emergency plan for responding to a release of radioactive material submitted under Subsection R313-22-32(8)(a)(ii) shall include the following information: (i) Facility description. A brief description of the licensee's facility and area near the site. (ii) Types of accidents. An identification of each type of radioactive materials accident for which protective actions may be needed. (iii) Classification of accidents. A classification system for classifying accidents as alerts or site area emergencies. (iv) Detection of accidents. Identification of the means of detecting each type of accident in a timely manner. (v) Mitigation of consequences. A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers on-site, and a description of the program for maintaining equipment. (vi) Assessment of releases. A brief description of the methods and equipment to assess releases of radioactive materials. (vii) Responsibilities. A brief description of the responsibilities of licensee personnel should an accident occur, including identification of personnel responsible for promptly notifying off-site response organizations and the Executive Secretary; also responsibilities for developing, maintaining, and updating the plan. (viii) Notification and coordination. A commitment to and a brief description of the means to promptly notify off-site response organizations and request off-site assistance, including medical assistance for the treatment of contaminated injured on-site workers when appropriate. A control point shall be established. The notification and coordination shall be planned so that unavailability of some personnel, parts of the facility, and some equipment will not prevent the notification and coordination. The licensee shall also commit to notify the Executive Secretary immediately after notification of the appropriate off-site response organizations and not later than one hour after the licensee declares an emergency. NOTE: These reporting requirements do not supersede or release licensees of complying with the requirements under the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Public Law 99-499 or other state or federal reporting requirements, including 40 CFR 302, 2005 ed. (ix) Information to be communicated. A brief description of the types of information on facility status, radioactive releases, and recommended protective actions, if necessary, to be given to off-site response organizations and to the Executive Secretary. (x) Training. A brief description of the frequency, performance objectives and plans for the training that the licensee will provide workers on how to respond to an emergency including special instructions and orientation tours the licensee would offer to fire, police, medical and other emergency personnel. The training shall familiarize personnel with site-specific emergency procedures. Also, the training shall thoroughly prepare site personnel for their responsibilities in the event of accident scenarios postulated as most probable for the specific site including the use of team training for the scenarios. (xi) Safe shutdown. A brief description of the means of restoring the facility to a safe condition after an accident. (xii) Exercises. Provisions for conducting quarterly communications checks with off-site response organizations and biennial on-site exercises to test response to simulated emergencies. Quarterly communications checks with off-site response organizations shall include the check and update of all necessary telephone numbers. The licensee shall invite off-site response organizations to participate in Page 14 of 25 the biennial exercises. Participation of off-site response organizations in biennial exercises although recommended is not required. Exercises shall use accident scenarios postulated as most probable for the specific site and the scenarios shall not be known to most exercise participants. The licensee shall critique each exercise using individuals not having direct implementation responsibility for the plan. Critiques of exercises shall evaluate the appropriateness of the plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the response. Deficiencies found by the critiques shall be corrected. (xiii) Hazardous chemicals. A certification that the applicant has met its responsibilities under the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Public Law 99-499, if applicable to the applicant's activities at the proposed place of use of the radioactive material. (d) The licensee shall allow the off-site response organizations expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to the Executive Secretary. The licensee shall provide any comments received within the 60 days to the Executive Secretary with the emergency plan. 18) Does the Licensee have an emergency plan for responding to a release of radioactive material? Yes_____ No_____ Comments: 19) Does the emergency plan contain a facility description? (A brief description of the licensee's facility and area near the site.) Yes_____ No_____ Comments: X Reviewed revision 9/1/2023. X Page 15 of 25 20) Type of Accidents—Does the emergency plan identify each type of radioactive materials accident for which protective actions may be needed? Yes_____ No_____ Comments: 21) Classification of accidents. Does the emergency plan have a classification system for classifying accidents as alerts or site area emergencies? Yes_____ No_____ Comments: 22) Detection of accidents. Does the emergency plan identify the means of detecting each type of accident in a timely manner? Yes_____ No_____ Comments: 23) Mitigation of consequences. Does the emergency plan provide a brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers on-site, and a description of the program for maintaining equipment? Comments: Yes_____ No_____ X X X X Page 16 of 25 24) Assessment of releases. Does the emergency plan provide a brief description of the methods and equipment to assess releases of radioactive materials? Comments: Yes_____ No_____ 25) Responsibilities. Does the emergency plan provide a brief description of the responsibilities of licensee personnel should an accident occur, including identification of personnel responsible for promptly notifying off-site response organizations and the Executive Secretary; also responsibilities for developing, maintaining, and updating the plan? Yes_____ No_____ Comments: 26) Notification and coordination. Does the emergency plan provide a commitment to and a brief description of the means to promptly notify off-site response organizations and request off-site assistance, including medical assistance for the treatment of contaminated injured on-site workers when appropriate. A control point shall be established. The notification and coordination shall be planned so that unavailability of some personnel, parts of the facility, and some equipment will not prevent the notification and coordination. The licensee shall also commit to notify the Director of Radiation Control immediately after notification of the appropriate off-site response organizations and not later than one hour after the licensee declares an emergency. Yes_____ No_____ Comments: X X X Page 17 of 25 27) Information to be communicated. Does the emergency plan contain a brief description of the types of information on facility status, radioactive releases, and recommended protective actions, if necessary, to be given to off-site response organizations and to the Director of Radiation Control? Yes_____ No_____ Comments: 28) Training. Does the emergency plan contain a brief description of the frequency, performance objectives and plans for the training that the licensee will provide workers on how to respond to an emergency including special instructions and orientation tours the licensee would offer to fire, police, medical and other emergency personnel? Does the training familiarize personnel with site-specific emergency procedures? Does the training thoroughly prepare site personnel for their responsibilities in the event of accident scenarios postulated as most probable for the specific site including the use of team training for the scenarios? Yes_____ No_____ Comments: 29) Safe shutdown. Does the emergency plan contain a brief description of the means of restoring the facility to a safe condition after an accident? Yes_____ No_____ Comments: X X X Page 18 of 25 Emergency Response Plan Rev. 2 Section 1.2.3 Assembly and Relocation Areas When the evacuation alarm sounds or when personnel are verbally notified by radio or other means all personnel will assemble at: • The parking lot south of the office; • The Scale house; • North side of Tailings Cell; or • North of the Mill. 30) Are these areas marked as assembly areas? Yes_____ No_____ Comments: 31) Are there any postings in the Mill/work areas that identify assembly areas? Yes_____ No_____ Comments: 32) During the Mill tour ask several Mill employees if they know where the emergency assembly areas are. Do Mill workers know where the Emergency assembly points are? Yes_____ No_____ Comments: X X There are four assembly locations. All postings are ledgible Page 19 of 25 Section 7.3 Drills and Exercises The drill and evacuation activities are documented by the Mills Safety Coordinator and maintained within plant files Management reviews all drills at quarterly ALARA Committee Meetings 33) Review the documentation of the drills from the past year. Did the Mill perform quarterly Emergency/Fire drills? Yes_____ No_____ Comments: 34) If possible, observe an Emergency/Fire drill. Yes_____ No_____ Comments: 35) According to the NRC Inspection Manual: Inspection Procedure 88050 Emergency Preparedness: an effective drill requires three (3) critical elements: • A credible, technically correct, and challenging scenario to test key elements of the Emergency Plan, procedures, equipment, and the onsite and offsite response organizations; • Adequate facilities and resources; and • Critical and candid assessment of the response using trained controllers and evaluators. Yes_____ No_____ Comments: X Quarterly drills are alternated between Fire Drills and Evacuation Drills NA X Page 20 of 25 36) Who does the assessment of the emergency/fire drills? Yes_____ No_____ Comments: 37) Check the different fire stations during the Mill tour. Have they been recently checked to see if they are in working order. Yes_____ No_____ Comments: General Comments and Observations: Able Mendoza Jr. (Safety Technician) and Dax Jacobsen (Safety Manager) X There are 7 stations. They are check monthly. In addition to the 7 ﬁre stations, there are 4 ﬁre hoses in the main Mill. There are also sprinkler systems in the SX, warehouse and Admin buildings. The ﬁre hydrants are fed by a large 440,000 gal water tank. Water for the water tank comes from recapture resivour. According to the 1/4ly equipment checks in 2024 there is some equipment missing (e.g. helmets and gloves) but no indication on how that missing equipment is missing or needs to be replaced. Do ﬁre hydrants ever get turned on to test the water supply system? What happened with the to the work order (WR004742) to ﬁx the alarm? Are ﬁre hoses ever attached and used as part of the ﬁre drills? Fire and Evacuation Drill forms are incomplete and lacking in information. Page 21 of 25 Observe a fire drill. According to the NRC inspection manual Inspection procedure 88055 Fire Protection Annual Inspection. During the annual observation of a fire brigade drill in a plant area important to safety, evaluate the readiness of the licensee or certificate holder’s personnel to prevent and fight fires, including the following aspects: While observing a fire drill Yes No Does the Mills fire brigade have Protective clothing/turnout gear and know how to properly don the gear? Does the Mill have Self-contained breathing apparatus (SCBA) equipment and is the Mills fire brigade know how to properly wear and use? Are Fire hose lines are capable of reaching all necessary fire hazard locations, the lines are laid out without flow constrictions, the hose is simulated being charged with water, and the nozzle is pattern (flow stream) tested prior to entering the fire area of concern? Was the fire area of concern entered in a controlled manner (e.g., fire brigade members stay low to the floor and feel the door for heat prior to entry into the fire area of concern). Is there sufficient fire fighting equipment brought to the scene by the fire brigade to properly perform their firefighting duties? Was the fire brigade leader's fire fighting directions are thorough, clear, and effective? Was radio communications with the Mill operators and between fire brigade members efficient and effective? Did members of the fire brigade check for fire victims and propagation into other plant areas? Was effective smoke removal operations simulated? Was the fire fighting pre-plan strategies were used? Was the licensee’s pre-planned drill scenario followed, and the drill objectives acceptance criteria met? Comments: ✔ ✔ ✔ ✔ Page 22 of 25 38) Documentation Are the following documentation being kept at the Mill Yes No Quarterly Communication Checks with off-site emergency responders. Letters of agreement with off-site emergency responders Incident reports Emergency Response drills documentation Records of Emergency equipment checks Comments: Environmental Monitoring: The Environmental Monitoring module will be done in August. However, some environmental monitoring is done at different times of the year. Therefore vegetation sampling was added to this module because its being done in June. 39) Observe Vegetation Sampling (If being done during visit) **Note: Vegetation sampling is done in the spring and the fall. X X X X X X Emergency equipment checks are documented in the Fire Station Box Inspections which are done 1/4ly. Emergency Response Drills are documented with the Fire and Evacuation Drills form, the Fire Brigade Training documentation Observed the June vegetation sampling, they collected approximately 3,000 grams of vegetation from three different areas around the Mill. Just west of the tailings impoundments, near BH-1 and Northwest area of the property. Each bag was marked with date, time, and sample location. Page 23 of 25 33) Other Page 24 of 25 DATE______________________ CLOSEOUT MEETING MEETING MEMBERS NAME DRC/COMPANY CONTACT INFORMATION 6/11/2025 Garrin Able Mendoza Jr Page 25 of 25 DISCUSION: SITE STAFF COMMENTS: