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Home My WebLink AboutDRC-2013-004662 - 0901a06880428827Department of Environmental Quality Amanda Smith Executive Director State of Utah GARY R. HERBERT Governor DIVISION OF RADIATION CONTROL Rusty Lundberg Director GREG BELL Lieutenant Governor October 2, 2013 DRC-2013-004662 Jo Ann Tischler Director, Compliance Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, Colorado 80228 RE: DRC Inspection Module RADMOD-PEM-01, September 26, 2013; RML UT1900479 Dear Ms. Tischler: Inspection Module RADMOD-PEM-01 was conducted on September 26, 2013, by the Division of Radiation Control (DRC) at the White Mesa Mill. The inspection focused on the Mill's routine surveys, radiological postings and personnel exit monitoring. No discrepancies were noted as all items inspected met applicable regulatory requirements and site procedures. Please continue to remember that radiation safety is the responsibility of the licensee. Thank you for your cooperation in this matter. If you have any questions or concerns regarding this letter, please contact Kevin Carney at (801)536-4250. Sincerely, Rusty Lundberg, Director RL/KJC:kc cc: Ron Nieves, Site RSO 195 North 1950 West • Salt Lake City, UT. Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801-533-4097 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper INSPECTION REPORT Inspection Module: RADMOD PEM-01 Inspection Location: White Mesa Mill, Blanding Utah RM License: UT1900479 Inspection Items: Inspection Date: Inspectors: Surveys, Postings and Exit Monitoring September 26, 2013 Kevin Carney, Utah Division of Radiation Control (DRC) Personnel Contacted: David Turk, Ron Nieves and Dan Hillsten. Governing Documents: • Radioactive Material License UT 1900479 • License Renewal Application dated February 28, 2007 • Radiation Protection Manual, Appendix E, Sections 1 and 2 • ALARA Program Manual, Appendix I, Section 2 • 10CFR20 • Utah Administrative Code R313 -15 Inspection Summary The inspection was a verification of compliance with Utah Rules, 10CFR20 and White Mesa Mill (the Mill) procedures as they pertain to radiological surveys, postings and exit monitoring at the Mill. The inspection consisted of a review of records, site observations and interviews with the Radiation Protection Staff as well as other personnel on site. Discrepancies Several discrepancies were noted during the inspection that were minor in nature and immediately corrected by Mill staff. Inspection Items The inspection was divided into three main sections: • Exit Surveys • Routine Surveys • Radiological Postings The inspection outlines are noted below according to section: 1 of Page 3 C:\Documents and Settings\kcarney.UTAH\My DocumentsU le2 RMLs\Energy Fuels Resources - White Mesa\Inspections\20T 3 Inspections\PEM- 01\PEM-01 Inspection Report 10-l-2013.doc Exit Surveys This section of the inspection consisted of direct observation of personnel exiting the Mill's Restricted Area (RA) and inspection of Exit Monitor alarm set points. Personnel were observed self-monitoring at RA exit points at the Guard Shack, West Door and Laboratory. All observed personnel had adequately surveyed themselves upon exit from the RA. Survey meters at the above listed exits as well as the Maintenance Building Lunchroom were inspected to assure correct alarm set points. All observed meters were Ludlum Model 177s with 50 cm" probes. The Mill's Radiation Protection Manual Section 1.2.3 requires exit monitors' alarms to be adjusted within the range of 500 to 750 dpm/100cm2. Since these meters read out in counts per minute and the probes are 50 cm2 in surface area, the set points are determined by calculation. All exit monitors were found to have the correct alarm settings. During the alarm check of the exit monitoring instrumentation, it wras noted by the inspector that the monitor designated as 'Lunchroom #2' bore a calibration label with a due date of April 10,2014. A subsequent inspection of instrument records showed that the meter's calibration certificate indicated a calibration due date of October 16,2013. The calibration certificate showed a six month calibration period while the instrument's label showed a twelve month calibration period. This error was brought to the attention ofthe Mill staff. They indicated that the meter will be removed from service and sent for re-calibration during the next week. Routine Surveys - . This section of the inspection consisted of a review of documents associated with weekly alpha surveys, daily R.SO inspections and weekly Mill inspections. The inspector reviewed documentation forthe last three months; July, August and September, 2013. It was communicated by Mill staff that the Mill was in production during the months of July and August and has been in a non-production mode since the beginning of September for maintenance and modifications. All weekly alpha surveys have been documented for the three month period covered by the inspection and were adequately performed. Documentation showed that the daily and weekly inspections were being performed as well. It was noted by the inspector that two of the daily RSO inspection forms bore the same date, September 6, while no form was dated for September 7. The inspector agreed that the latter form was misdated and was indeed performed on the 7th. This was brought to the attention of the Mill staff and was corrected during the inspection. Although the Mill's procedures allow for certain areas to not be surveyed, it was noted by the inspector that the surveys were performed identically whether the Mill was in production or non- production modes. 2 of Page 3 C:\Documents and Setlings\kcarney.UTAH\My DocumentsM le2 RMLs\Ehergy Fuels Resources - White Mesa\Inspections\2013' Inspections\PEM- 01\PEM-01 Inspection Report 10-1 -2QJ^ioc .; Radiological Postings The inspection examined the Mill's radiological postings through direct observance. The inspector observed postings at the Mill's entrances, Radiation Areas and Airborne Radioactivity Areas. Radiation Area boundaries were surveyed by the inspector using Bicron Microrem s/n B288K. No boundaries were found to exceed the 5 mrem/hr limit nor were any areas found to be > 5 mrem/hr outside of posted Radiation Areas. All Mill entrances and Airborne Radioactivity Areas were also found to be adequately posted. No posting discrepancies were noted during the inspection. Findings No findings were identified during the inspection. Conclusion and Recommendations No violations are recommended for this inspection. The items noted were of a minor nature and the RSO's outlook on addressing the findings was reasonable to the inspector. The RSO was notified that these issues would be revisited during subsequent inspections. Recommendation for Next Inspection 1. Assure routine survey records are adequately filled out and correctly dated. 2. Ensure proper exit monitoring by Mill personnel. 3. Assure proper calibration certifications and meter labels. Prepared By: Reviewed By: Kevin Carney Phillip Goble 3 October 1, 2013 October 1.2013 3 of Page 3 C:\Documents and Settings\kcarney.UTAH\My DocumentsU le2 RMLs\Energy Fuels Resources - White Mesa\Inspections\2013 lnspections\PEM- 01\PEM-01 Inspection Report 10-l-2013.doc UTAH DIVISION OF RADIATION CONTROL Inspection Module PEM-01 Rev. 1 Energy Fuels Resources White Mesa Mill Radioactive Materials License UT 1900479 OPENING MEETING Inspector(s) Kevin Carney Date(s): September 76, 2013 MEETING MEMBERS NAME COMPANY CONTACT INFORMATION Kevin Carney DRC 801-536-4250 Boyd Imai DRC 801-536-4250 David Turk Energy Fuels 435-678-2221 Ron Nieves Energy Fuels 435-678-2221 UTAH DIVISION OF RADIATION CONTROL Inspection Module PEM-01 Rev. 1 Energy Fuels Resources White Mesa Mill Radioactive Materials License UT1900479 OPENING MEETING DISCUSSION The inspector informed the Mill Staff of the scope of the inspection. The inspector requested access into the Restricted Area of the site and requested documentation for review for the purposes of completing the inspection. SITE STAFF COMMENTS The Mill Staff communicated that the inspector would have access to any records requested and offered a tour inside the Mill's Restricted Area, UTAH DIVISION OF RADIATION CONTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-PEM-01 Revl SURVEYS/POSTINGS/EXIT MONITORING ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UT1900479 References: Radioactive Material License UT 1900479 License Renewal Application dated February 28, 2007 Radiation Protection Manual, Appendix E, Sections 1 and 2 ALARA Program Manual, Appendix I, Section 2 10CFR20 Utah Administrative Code R313-15 Date(s) of Inspection: September 25 - 27. 2013 Inspector^: Kevin Carney 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." 1) Did all employees observed monitor themselves in accordance with the Radiation Protection Manual Section 1.2.1 upon exit from the Restricted Area? Yes |EI No • Comments: Personnel were observed at the Guard Shack. West Door and Lab exits. Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to perform proper personnel monitoring. 2) Section 1.2.3 step 1. 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 g| No • Comments: Exit monitors were observed at the Guard Shack, West Door. Lab exit and Lunch Room. All alarms were appropriately set. See below for additional comments. 3) Section 1.2.3 step 2. 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 lA inch? Yes Kl No [ Comments: All observed personnel appropriately surveyed. 4) Section 1.2.3 step 6. Has the licensee provided documentation of individual (exit) surveys being logged and initialed? Yes IS No • Comments: Monitoring logs were present at all monitoring stations. 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. Table 2.3.2-1 White Mesa Mill Alpha Area Survey Locations Scale House Table Warehouse Office Desks Maintenance Office Desks Change Room Lunch Tables Maintenance Lunchroom Tables Central Control Room (CCR) Tables* Metallurgical Laboratory Desks Chemical Laboratory Desks Administrative Break Room Counter Administrative Office Desks * (Changes to Table 2.3.2-1: "Mill Office Lunchroom Tables" has been replaced with "CCR Tables".) 5) For the period including the last three (3) months, on what dates was the Mill considered in "production periods" and in "non-production periods"? 1st Month 2nd Month 3rd Month Production Periods July August Non-Production Periods September Comments: Mill has been in maintenance mode since the beginning of September 6) During production periods, were all areas listed in Table 2.3.2-1 surveyed for removable alpha as per Section 2.3.2? Yes g| No • Comments: All surveys were found to be completed in a timely manner and included removable alpha surveys. 7) During production periods, were all areas listed in Table 2.3.2-1 surveyed for fixed alpha as per Section 2.3.2? Yes _3 No • Comments: All surveys were found to be completed in a timely manner and included fixed alpha surveys, 8) 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: During the non-production period in September, all weekly routine surveys were performed the same as during production periods. 9) 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 |3 No • Comments: See #8 above. The Mill's ALARA Program, Section 2.3.1, requires the RSO or designee to perform daily inspections throughout the Mill and document the results on the Daily Mill Inspection form. Section 2.3.2 requires the RSO and Shift Foreman or designees to perform weekly inspections throughout the Mill and document the results on the Weekly Mill Inspection form. Inspector shall review inspection documents for the period including the last three (3) months. 10) Has the licensee performed the daily Mill Inspections in accordance with Section 2.3.1? Yes __ No • Comments: All daily inspections were completed for the inspected period (July through September). Two inspection forms were found to be dated for September 6 and no form found for September 7. Mill staff has corrected the error and re-dated the later form for September 7. 11) Were the forms completed to satisfy the requirements of Section 2.3.1? Yes __ No • Comments: All forms were found to be complete. 12) Has the licensee performed the weekly Mill Inspections in accordance with Section 2.3.2? Yes No • Comments: All weekly inspections were completed for the inspected period (July through September) 13) Were the forms completed to satisfy the requirements of Section 2.3.2? Yes Comments: All forms were found to be complete. _3 No • RADIOLOGICAL POSTINGS 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". 14) 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 [X] No • Comments: All Mill entrances were found to be appropriately posted. 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. 15) Were all radiation areas posted in accordance with R313-15-902(1)? Yes g_ No • Comments: All identified Radiation Areas were found to be properly posted. 16) Were all posted Radiation Area boundaries found to be < 5mrem/hr? Yes __ No • Comments: No Radiation Area boundaries were found to be > 5mrem/hr. No unposted Radiation Areas were identified during the inspection. 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." 17) Has the licensee employed the proper postings for Airborne Radioactivity Areas in accordance with R313-15-902(4)? Yes _3 No • Comments: All identified Airborne Radioactivity Areas were found to be properly posted. 18) Were all radiological postings observed found to be legible, conspicuously posted and unobstructed? Yes No • Comments: All radiological areas were found to be adequately posted with signage in good repair. Additional Observations and Findings: Comments: Inspection Item #2: During the alarm check of the exit monitoring instrumentation, it was noted by the inspector that the monitor designated as 'Lunchroom #2' bore a calibration label with a due date of April 10. 2014. A subsequent inspection of instrument records showed that the meter's calibration certificate indicated a calibration due date of October 16. 2013. The calibration certificate showed a six month calibration period while the instrument's label showed a twelve month calibration period. This error was brought to the attention of the Mill staff They indicated that the meter will be removed from service and sent for re-calibration during the next week. UTAH DIVISION OF RADIATION CONTROL Inspection Module PEM-01 Rev 1 Energy Fuels Resources White Mesa Mill Radioactive Materials License UT 1900479 CLOSEOUT MEETING Inspector(s) Kevin Carney Date(s): September 7.7 7.0Q MEETING MEMBERS NAME COMPANY CONTACT INFORMATION Kevin Carney DRC 801-536-4250 Boyd Imai DRC 801-536-4250 David Turk Energy Fuels 435-678-2221 Ron Nieves Energy Fuels 435-678-2221 Dan Hillsten Energy Fuels 435-678-2221 UTAH DIVISION OF RADIATION CONTROL Inspection Module PEM-01 Rev 1 Energy Fuels Resources White Mesa Mill Radioactive Materials License UT 1900479 CLOSEOUT MEETING DISCUSSION of FINDINGS The inspector informed the Mill staff that no violations were noted during the inspection. The inspector noted to the Mill staff that there was a discrepancy noted in the daily RSO inspection lot and that the Lunchroom Monitor #2 calibration sticker had the wrong calibration due date. SITE STAFF COMMENTS The Mill staff agreed to fix the RSO log and that they would send the Lunchroom #2 meter out for re- calibration during the next week. J ^<j °> _____-> ^ /—^ ,->;yi fiffn^l ^ 7 ^7 'TL___L___ cV^li^ £A • A/77 z&isnUteb. &° yjpft to****- L'lTX / # (i<sAsck /l-m /A^ 4-/ttf4S Ccru^A @Al i> Me^fh $ , A^MC /__y2. ^SA't)