DRC-2015-001943 - 0901a06880516529

Department of
Environmental Quality
Amanda Smith
Executive Direclor
State of Utah DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
March 30, 2015 DRC-2015-001943
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Radioactive Material License No. UT 1900479
1st Quarter 2015 Radiation Protection Inspection, Module RADMOD-Emergency-2015
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on March 12, 2015 by a representative of the Division of Radiation Control (DRC), Utah Department of
Environmental Quality.
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Materials License Number UT 1900479. The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector.
The activities and practices reviewed during the inspection with respect to the Emergency Response Plan
were found to be in compliance with relevant requirements.
A copy of the Inspection Report is enclosed.
If you have any question, please contact Boyd Imai at [phone].
Sincerely,
Rusty Lundberg, Director
RL/BMI:bi
Enclosure
cc/enc: David Turk, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City. UT
Mailing Address: P.O Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D (801) 536^414
www.deq utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-Emergency-2015
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 12,2015
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: David Turk, Energy Fuels Resources (EFR)
Inspection Summary
The inspection was opened on March 12, 2015 with a meeting with D. Turk.
Areas/Topics inspected included:
• Follow-up to Prior Inspection
• Review of Emergency Response Plan
• Site Evacuation Drill
• Conversion from Material Safety Data Sheet (MSDS) to Safety Data Sheets (SDS)
The inspector held a closeout meeting on March 12, 2015 with D. Turk of EFR to review the
inspection activities, observations, and conclusions.
No infractions or violations were detected or encountered during the course of the inspection.
Inspection Items
Follow-up to Prior Inspection
• During the December 4, 2013 inspection the emergency fire/evacuation alarm system failed
to function when initiated for a routine evacuation drill. It was determined at the time that
the alarm system had been bypassed while maintenance was performed on other systems and
that when the maintenance work was completed the workers failed to reactivate the alarm
system. In order to prevent recurrence the control of the access to the alarm system has been
delegated solely to the Radiation Safety Officer (RSO). If the alarm system has to be shut
down for any reason the RSO, or designee, must be the one to provide access to the system.
The access is secured with a lock with the RSO in sole possession of the key. In this
manner, the RSO will always be aware of when the system is in a shutdown status.
• The critique for the biennial emergency response exercise conducted in November 2013 had
not yet been published at the time of the previous inspection. Once issued, the Licensee was
Page 1 of 4
U:\MON_WASTABimai\wp\Inspections\Energy Fuel, Blanding, UTA2015\RADMOD Emergency
2015\InspectionReportRev0.doc
Findings
requested to review the report and address any relevant issues that were identified in the
critique. The Licensee obtained a copy of the "Blue Mountain Hospital Operation Walking
Dead" After-Action Report/Improvement Plan which was a summary and critique of the
November 15, 2013 Full-Scale Exercise. The main focus of the exercise was the hospital's
handling of an emergency associated with a surge of patients from a transportation accident
involving hazardous materials. The Licensee participated in an ancillary capacity.
There were no criticisms or recommendations directed towards the Licensee's involvement
that needed to be addressed.
The Licensee will conduct its biennial exercise in 2015. Planning for this event was in its
infancy at the time of the inspection.
• Corrections and edits to the Emergency Response Plan were suggested in the course of last
inspection. The items were addressed in the revision of the plan.
Review of Emergency Response Plan
The plan (White Mesa Mill Emergency Response Plan, Book #16, Rev. No. R-3.0, December 2014)
had been revised since the last inspection and was reviewed to ensure that all the required elements
were retained in the revision.
Each element for an emergency response plan specified in Radiation Control Rules R313-22-32(c)
was identified in the Licensee's current plan.
The plan was significantly improved when revised. Emergency Response Guide excerpts were
updated as recommended during the last inspection. Duplicated Appendix designations were also
corrected. Other minor corrections had been made as suggested. The plan is a much "cleaner"
document than what was in place at the last inspection. It is better organized and easier to read and
follow, all around, a better document.
Minor corrections that should be addressed in the revised plan include changing the references to
Section 3.1.6 which should read Section 3.1.7. This reference occurs in two places: Section 6.4.1.3
and Appendix E of the plan. Also in Appendix E 14 a reference is made to exposure to "high
radiation" with respect to contamination when the intent is "high radiological contamination."
Site Evacuation Drill
The RSO was very accommodating for conducting the quarterly site evacuation drill during the
inspection where it could be directly observed. The alarm sounded without delay, the employees
evacuated in an orderly and timely manner, and there was an accounting for all personnel on sight.
It was noted that the majority of the personnel assembled outside the gate to the restricted area in the
parking lot of the administration building which raised the question of controlling potential
personnel contamination situations. It was apparent that the employees would return to the
restricted area and would be scanned out under routine area exit procedures. In the event the
workers could not be allowed back into the restricted area, the RSO indicated that radiation
technicians would be present to frisk the workers prior to allowing them to leave the site. The
Page 2 of 4
U:\MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\20l5\RADIv1OD Emergency
2015\InspectionReportRev0.doc
emergency response plan indicates in general terms that employees will be surveyed following an
evacuation but does not describe in detail how this would be accomplished under differing
circumstances, i.e. workers returning to the restricted area vs workers leaving the site from the
parking lot.
The drill demonstrated that an evacuation from the site can be quick, efficient, and thorough. It was
obvious that all were familiar with the exercise and executed it with no hesitation or question.
Conversion from MSDS to SDS
The deadlines for converting to the new SDS format are set by the Occupational Safety and Health
Administration. Employees were to be trained on the new SDS format by December 1,2013 and
compliance with all the new requirements will be effective June 1, 2015.
The Licensee conducted the training on the Globally Harmonized System (GHS) of classification
and labeling of chemicals during the May and June (2013) quarterly safely meetings covering
Hazcom and radiation safety. All employees were required to attend and the attendance is
documented on the Training Attendance Record.
The Licensee is in the process of updating all of the data sheets associated with the chemicals on
site. Binders for the new SDSs have been established which will mirror the binders for the MSDSs.
As the SDSs are received from the manufacturers of the products they are filed in the SDS binders.
Licensee compliance is dependent upon the manufacturers providing the updated data sheets. Since
the Licensee has an extensive library of MSDSs, ensuring that corresponding SDSs are on file in the
binders as well is challenging and cumbersome. It was suggested that a spreadsheet be devised
which would indicate the status of the each chemical with respect to the data sheet on hand. This
would facilitate looking up specific products without having to thumb through the binders.
The Licensee appears to be "on top" of this matter and is committed to comply with prescribed
changes. The Licensee has been proactive in striving for compliance in this regard. The Licensee
has generated the SDS for the Uranium Oxide product produced at the mill for distribution as
mandated. The Licensee still has to rely on the manufacturers to provide the SDSs of the materials
at the mill in order to achieve full compliance.
Exit Meeting
The inspector held an exit meeting with D. Turk of Energy Fuels Resources (USA) on March 12,
2015. The observations made during the inspection were summarized and discussed during the
meeting.
Conclusion
Based on the items inspected, it is concluded that the Licensee is in compliance with the
requirements of an Emergency Response Plan.
Page 3 of 4
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UTA2015\RADMOD Emergency
2015\InspectionReportRev0.doc
Recommendations for the Licensee
In subsequent site evacuation drills, it should be emphasized to the workforce that if they are not
allowed to return to work in the restricted area or choose not to return that they must be screened for
radioactive contamination by a radiation safety technician prior to departing the site. This should be
stressed and discussed prior to terminating the drill. The Licensee may choose to expand in greater
detail in the plan the manner in which contamination is controlled during an evacuation of the site.
With regards to third party emergency responders the plan (Section 8.2) indicates that thereris no
need-to rrrovide perrodic^errtation tour^foroffsite emergercy Temporise persoruTer since"upon"
arrival during an emergency they will be met by mill staff who will escort them wherever they are
needed. The RSO indicated that the offsite emergency response community is relatively small and
that all have had opportunities to visit the site and have become familiar with the facility. There is
documentation that these visits have taken place. It is suggested that the plan describes how offsite
responders are or become familiar with the mill site rather than dismiss the need for them to be
given orientation tours prior to an event that requires their services.
In order to track the status of the safety data sheets for the various materials on site it is suggested
that a tool like a spreadsheet be created to readily identify the materials and to confirm the site has
the corresponding SDSs. If the capability exists, the Licensee may consider scanning the SDSs and
storing them in an electronic database to facilitate tracking and retrieval.
The minor changes to the Emergency Response Plan as noted by the RSO should be effected.
Recommendation for the DRC Director
It is recommended that no enforcement action in this regard be taken at this time.
Prepared By: Boyd M. Imai
(Name)
March 27, 2015
(Date)
Page 4 of 4
U:\lV10N_vVAST\Bimai\vvp\Inspections\Energy Fuel, Blanding, UT\2015\RADMOD Emergency
2015\lnspectionReportRev0.doc