DRC-2013-004682 - 0901a0688042a099

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
GARY R. HERBERT
Governor
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
June 19, 2013 DRC-2013-004682
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
RE: DRC Inspection Module RADMOD-TPEM-02, March 7, 2013; RML UT1900479
Dear Mr. Frydenlund:
Inspection Module RADMOD-TPEM-02 was conducted on March 7, 2013, by the Division of
Radiation Control (DRC) at the White Mesa Mill. The inspection focused on the Mill's radiation
worker training, radiological postings and personnel radiological 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
RUKJC: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 [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module:
Inspection Location: White Mesa Mill, Blanding Utah
RADMOD TPEM-02
RM License: UT1900479
Inspection Items:
Inspection Date:
Inspectors:
Training, Postings and External Monitoring
March 8, 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
• NRC Regulatory Guide 8.30
• License Renewal Application Dated February 28, 2007
• White Mesa Mill Radiation Protection Manual, Section 1
• White Mesa Mill Security Program, Section 1.4
• White Mesa Mill Training Manual, Sections 2 and 3
• Utah Administrative Code R313-15
• 10CFR20
Inspection Summary
The inspection was a verification of compliance with Utah Rules, 10CFR20, NRC Regulatory Guide
8.30 and White Mesa Mill (the Mill) procedures as they pertain to training, postings and external
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
No discrepancies were noted during the inspection.
Inspection Items
The inspection was divided into four main sections:
• Training
• Postings
• External Monitoring
• Security*
*This section was added as a follow-up to a previous issue with Delivery Driver Training but is
addressed by the Mill in their Security Manual.
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Inspections\TPEM-02\TPEM-02 Inspection Report6-18-2013.doc
The inspection outlines are noted below according to section:
Training
The inspection consisted of a review of records of trained personnel as well as the curriculum
associated with that training. It was focused on the radiation worker training and re-training of Mill
employees and contract personnel. The Mill's rad-worker training was found to be properly managed
and no discrepancies were found regarding the program.
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. One
posting at the Main Gate was recently replaced. The new sign read, "Any Area or ContainerWithin
This Facility May Contain Radioactive Material." It was communicated to the Mill Staff that this
posting may not be appropriate because it was not of the exact wording of NRC Regulatory Guide
8.30. The inspector did not feel that the sign was in any violation since it only added the words, "cr
Container", but thought it was worth mentioning. The RSO agreed to replace the sign and it was
changed out prior to the end of the inspection.
Radiation Area boundaries were surveyed by the inspector. 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. No
posting discrepancies were found during the inspection.
External Monitoring
The inspection examined the Mill's use of exit monitoring for external personnel contamination.
Workers were observed at the Laboratory and West Door exits from the Restricted Area. Workers
were found to be properly self-monitoring and appropriately logging their activity.
Security
During the inspection, there was one ore truck driver and one reagent driver on site. Each of these
drivers was interviewed and had their names taken by the inspector. Their training records were then
reviewed. Both drivers were found to have been properly trained before being allowed access to the
Restricted Area of the Mill.
Findings
No findings were identified during the inspection.
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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 inspectors. The RSO was notified
that these issues would be revisited during subsequent inspections.
Recommendation for Next Inspection
1. Follow up on training for truck drivers.
2. Ensure proper exit monitoring by Mill personnel.
Reviewed By:
Prepared By:
Phillip Goble
Kevin Carney June 18, 2013
June 18. 2013
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UTAH DIVISION OF RADIATION CONTROL
Inspection Module TPEM-02 Rev. 1
Energy Fuels Resources
White Mesa Mill
Radioactive Materials License UT 1900479
OPENING MEETING
Inspector(s) Kevin Carney
Date(s): March 7. 20 H
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Carney DRC 801-536-4250
Russell Topham DRC 801-536-4250
Boyd Imai DRC 801-536-4250
David Turk Energy Fuels 435-678-2221
Ron Nieves Energy Fuels 435-678-2221
Garrin Palmer Energy Fuels 435-678-2221
Tanner Holiday Energy Fuels 435-678-2221
UTAH DIVISION OF RADIATION CONTROL
Inspection Module TPEM-02 Rev. 1
Energy Fuels Resources
White Mesa Mill
Radioactive Materials License UT 1900479
OPENING MEETING
DISCUSSION
t
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-TPEM-02
TRAINING/POSTINGS/EXIT MONITORING Rev 1
DENIS ON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Inspection Dates: Start March 7.2013 End March 8.2013
Inspector(s): Kevin Carney
References:
Radioactive Material License UT 1900479
License Renewal Application dated February 28, 2007
Training Manual, Sections 2 and 3,
Security Program, Section 1.4
Radiation Protection Manual, Section 1
10CFR20
NRC Regulatory Guide 8.30
Utah Administrative Code R313-15
TRAINING
Training Manual Section 2.0 On-Site Contractors.
"New hire training, as outlined in Section 1.2, is included in the training program, as applicable to the
site work specifications, for on-site contractors."
1) Has the licensee documented initial training of on-site contractors?
XlYes • No
Comments: 16 Contractors reviewed. All had received initial training for 2013
Training Manual Section 3.1 Pre-employment Instruction
"Classroom instruction of all new employees is conducted under the supervision of the Radiation Safety
Officer and Safety Coordinator, covering plant and personal safety, including radiation protection."
2) Has the licensee documented initial training of new employees?
X|Yes • No
Comments: Reviewed records of 12 new hires for 2013.
U:\rad\COMMON\Uranium mills\ 1 le(2)UT 1900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02 .doc
D.. „a i „f ;
Training Manual Section 3.1 Pre-Employment Instruction - Items I and J.
3) Did the licensee provide training to female employees on 'Prenatal Radiation Review'?
ElYes • No
Comments: One female new hire in 2013. Training documentation in file.
4) Did the licensee provide training on 'Radiation Protection Review'?
ElYes
Comments: All 12 new hires received Radiation Protection Review training.
• No
5) Did the licensee provide training on the 'Respirator Protection Program'?
ElYes
Comments: All 12 new hires received Respirator Protection Program training.
• No
SECURITY
The Mill's Security Program, Section 1.4, Reagent and Ore Carriers, states:
Truck drivers hauling reagent and ore into the restricted area of the facility are to receive documented
site safety and radiation protection training prior to access to the site. Access is limited by controlling
and documenting gate access. Safety and radiation training consists of appropriate training for the
activity involved.
6) Have all reviewed drivers hauling reagent and/or uranium ore received site safety and radiation
protection training prior to entry into the Restricted Area?
XlYes • No
Comments: One reagent driver and one ore truck driver were interviewed during the inspection. Both
drivers' training documentation was on file.
U:\rad\COMMON\Uranium mills\ 1 le(2)I^Bk)479 Denison Mines - White Mesa UMill\ HP Inspecti^^dules\ RADMOD-TPEM-02.doc
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."
7) Did all employees observed monitor themselves in accordance with the Radiation Protection Manual
upon exit from the Restricted Area?
ElYes • No
Comments: Observed personnel surveys at the west door and at the laboratory exit. All personnel had
properly monitored upon exit.
Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to
perform proper personnel monitoring.
8) Section 1.2.3 step 1.
Were all exit monitor (rate meter) alarms adjusted within the range of 500 to 750 dpm/lOOcm2?
(Note: Because the Ludlum Model 177 reads out in counts per minute and because the Ludlum Model
43-5 probe has an effective surface area of 50 cm2, ensure proper calculations were used to achieve a
500 to 750 dpm/lOOcm2 range).
Alarm Set Point (in cpm) - BKG (in cpm) -f eff. x 2 = Alarm Set Point (in dpm/100 cm2)
ElYes • No
Comments:
9) 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 !4 inch?
^Yes ] No
Comments: See #7 above.
U:\rad\COMMON\UraniurnmiIIs\ 1 le(2)UTl900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
10) Section 1.2.3 step 6.
Has the licensee provided documentation of individual (exit) surveys being logged and initialed?
BY es • No
Comments: Logs at all exits were present and properly maintained.
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".
11) 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"?
ElYes • No
Comments: All Mill entrances were properly posted. The sign at the main gate read. "Any area or
container..." Since the sign did not contain the exact wording of LC 9.9. it was discussed with the Mill
RSO. Although the inspector was uncertain as to whether or not the posting was appropriate, the RSO
agreed to replace it with a sign containing the exact wording of LC 9.9.
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.
12) Were all radiation areas posted in accordance with R313-15-902(1)?
^Yes • No
Comments: No unposted areas in excess of 5 mrem/hr were identified during the inspection.
U:\rad\COMMON\Uranium mills\ 1 le(2)(^Mk)479 Dcnison Mines - White Mesa UMill\ HI' lnspecti^^dulcs\ RADMOD-TPEM-02.doc
13) Were all Radiation Area boundaries found to be < 5mrem/hr?
^Yes • No
Comments: All radiation area boundaries were found to be less than 5 mrem/hr.
Regulatory Guide 8.30.C.6 sets the requirements for establishing Airborne Radioactivity Areas.
14) Has the licensee established Airborne Radioactivity Areas in accordance with Regulatory Guide
8.30.C.6?
ElYes • No
Comments: All ARAs were found to be properly posted.
15) Has the licensee established the yellowcake drying and packaging areas as Airborne Radioactivity
Areas?
g]Yes • No
Comments: ARA Postings were present at all drying/packaging areas.
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."
16) Has the licensee employed the proper postings for Airborne Radioactivity Areas in accordance with
R313-15-902(4)?
ElYes • No
Comments: A previous inspection identified an improperly posted area below the SAG Mill area. The
area was found to be properly posted as an ARA during the inspection.
U:\rad\COMMON\Uranium mills\ 1 le(2)UT 1900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
UTAH DIVISION OF RADIATION CONTROL
Inspection Module TPEM-02 Rev 1
Energy Fuels Resources
White Mesa Mill
Radioactive Materials License UT 1900479
CLOSEOUT MEETING
Inspector(s) Kevin Carney
Date(s): March 8r 2013
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Carney DRC 801-536-4250
Russell Topham DRC 801-536-4250
Boyd Imai DRC 801-536-4250
David Turk Energy Fuels 435-678-2221
Ron Nieves Energy Fuels 435-678-2221
Garrin Palmer Energy Fuels 435-678-2221
Tanner Holiday Energy Fuels 435-678-2221
Dan Hillsten Energy Fuels 435-678-2221
UTAH DIVISION OF RADIATION CONTROL
Inspection Module TPEM-02 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 notice was taken of the new ARA posting at the SAG Mill
aim
The inspector noted to the Mill staff that there may he a issue with the wording on the main gate sign.
The inspector discussed the exit monitor calculations with the Mill staff. ,
SITE STAFF COMMENTS
The Mill staff agreed to replace the main gate sign with one of proper wording.
The Mill staff reviewed the calculation method for determining the restricted area exit monitor alarm
set points.
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UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-TPEM-02
TRAINING/POSTINGS/EXIT MONITORING Rev 1
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Inspection Dates: Start 3 frfa End
Inspector(s):
References:
Radioactive Material License UT1900479
License Renewal Application dated February 28, 2007
Training Manual, Sections 2 and 3,
Security Program, Section 1.4
Radiation Protection Manual, Section 1
10CFR20
NRC Regulatory Guide 8.30
Utah Administrative Code R313-15
TRAINING
Training Manual Section 2.0 On-Site Contractors.
"New hire training, as outlined in Section 1.2, is included in the training program, as applicable to the
site work specifications, for on-site contractors."
1) Has the licensee documented initial training of on-site contractors?
J^TJYes • No
Comments: [(? Cgrf^A^< i '^W^ ZQ\^
Training Manual Section 3.1 Pre-employment Instruction
"Classroom instruction of all new employees is conducted under the supervision of the Radiation Safety
Officer and Safety Coordinator, covering plant and personal safety, including radiation protection."
2) Has the licensee documented initial training of new employees?
J><jYes • No
Comments: ['2" JUrZQQ A?A l<?(\<
U:Vad\COMMON\Uranium mills\ 1 le(2)UTl900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
Training Manual Section 3.1 Pre-Employment Instruction - Items I and J.
3) Did the licensee provide training to female employees on 'Prenatal Radiation Review'?
r - . 0Yes DNo
Comments:< qgjfefe AJscO tttrU? /As 'Z&l~h. "7n**v//<^ d^x^r^f^t/*/^*
4) Did the licensee provide training on 'Radiation Protection Review'?
J3Yes • No
Comments: Ail 12^ K^u^> ht£&> RA& T&rlA4Zb
5) Did the licensee provide training on the 'Respirator Protection Program' ?
Comments: At( ll >\szoC> fiiP^ r1WriA%>3>
^Yes • No
SECURITY
The Mill's Security Program, Section 1.4, Reagent and Ore Carriers, states:
Truck drivers hauling reagent and ore into the restricted area of the facility are to receive documented
site safety and radiation protection training prior to access to the site. Access is limited by controlling
and documenting gate access. Safety and radiation training consists of appropriate training for the
activity involved.
6) Have all reviewed drivers hauling reagent and/or uranium ore received site safety and radiation
protection training prior to entry into the Restricted Area?
0Yes • No
Comments: PA>£ C^A^t^i /W^ cyj?^ D/UUT^L i/^V^\Jia<^^J>,
U:\rad\COMMON\Uranium mills\ 1 le(2)UT1900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
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."
7) Did all employees observed monitor themselves in accordance with the Radiation Protection Manual
upon exit from the Restricted Area?
0YQS • No
Comments: o^^r^^L /J& %^( f
Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to
perform proper personnel monitoring.
8) Section 1.2.3 step 1.
Were all exit monitor (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 and because the Ludlum Model
43-5 probe has an effective surface area of 50 cm2, ensure proper calculations were used to achieve a
50010 750 dpm/100cm2range)-
Alarm Set Point (in cpm) ± eff. x 2 = Alarm Set Point (in dpm/100 cm2) Qjl
•Yes MNo
Comments: /^Sp-S ftu&U-fA\ /A) <^WT'*U><?sT Ur^J ptAf) &cJcU\ ^ar P^TS
,%P I fkfbk jig X/lZ~
9) 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 V* inch?
E^Yes • No
Comments;
U:\rad\COMMON\Uranium mills\ 1 le(2)UTl 900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
10) Section 1.2.3 step 6.
Has the licensee provided documentation of individual (exit) surveys being logged and initialed?
JVes • No
Comments: C&£& h& 4*dAf (sfr} iKoAuJ^ Al /H^ ?> g^tTS ^%7^n^mS> .
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".
11) 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"?
0Yes • No
Comments: % A%/Q 6&T£ 5 fc^O 5AVCS " OkCDtVCAitfO&L - - ~
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.
12) Were all radiation areas posted in accordance with R313-15-902(l)?
^Yes • No
Comments: fJa Q^f^>W> f^vrJb
U:\rad\COMMON\Uranium mills\ 1 le(2)UTl 900479 Denison Mines - White Mesa UMilft HP Inspection modules\ RADMOD-TPEM-02.doc
13) Were all Radiation Area boundaries found to be < 5mrem/hr?
0Yes • No
Comments:_
Regulatory Guide 8.30.C.6 sets the requirements for establishing Airborne Radioactivity Areas.
14) Has the licensee established Airborne Radioactivity Areas in accordance with Regulatory Guide
8.30.C.6?
jgYes • No
Comments:
15) Has the licensee established the yellowcake drying and packaging areas as Airborne Radioactivity
Areas?
KVcs • No
Comments;
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."
16) Has the licensee employed the proper postings for Airborne Radioactivity Areas in accordance with
R313-15-902(4)?
g|Yes • No
Comments:
U:\rad\COMMON\Uranium mills\ 1 le(2)UT1900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc