DRC-2015-003074 - 0901a0688053fd40

Department of
Environmental Quality
Alan Matheson
Acting Executive Director
GARYR HERBERT
Governor
DIVISION Ol RADIATION CONTROL
Rusty Lundberg
Director
SPENCERJ COX
Lieutenant Governor
June 1,2015 DRC-2015-002729
Kathy Weinel DRC-2015-003074
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard. Suite 600
Lakewood,CO 80228
Subject: Compliance—Radioactive Material License No. UT1900479
2nd Quarter 2015 Radiation Protection Inspection, Module RADMOD-IEM-01 2015
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on May 20, 2015 by representatives 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 inspectors.
The activities and practices reviewed during the inspection with respect to the Internal/External Monitoring
practices 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 l ake City, U I
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T D O [phone]
www.tienf.ulah.f{ov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-IEM-01 2015
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): May 20, 2015
Inspector(s): Phil Goble, Utah Division of Radiation Control (DRC)
Boyd Imai. DRC
Personnel Contacted: Dan Hillsten, David Lacy, Abel Mendoza. Garren Palmer, Justin Perkins.
Terry Slade, David Turk of Energy Fuels Resources (EFR)
Inspection Summary
The inspection was opened on May 20. 2015 with a meeting among the Licensee's D. Hillsten and
D. Turk and DRC's P. Goble and B. Imai.
Areas/Topics inspected included-
• Follow-up to Prior Inspection
• Work Area Air Sampling
• Personnel Breathing Zone (BZ) Monitoring
• Equipment Calibration
• Airborne Radioactivity Area Posting
• External Monitoring
• Bioassay
P. Goble and B. Imai held an exit meeting on May 20. 2015 with D. Hillsten. J. Perkins, and D.
Turk of EFR to review the inspection activities, observations, and conclusions.
Findings
No infractions or violations were delected or encountered during the course ofthe inspection.
Inspection Items
Follow-up to Prior Inspection
The DryCal instrument indicated that a calibration had been performed within the last year.
Air Sampling data are reviewed by the Radiation Safety Officer (RSO) routinely.
The Licensee has two DryCal instruments so one is always available when the other one is out for
calibration.
Page 1 of 5
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The Breathing Zone Sampling Field Sheet is reviewed and verified by the RSO each time a batch of
air sample data is entered into the spreadsheet.
Work Area Air Sampling
No uranium ore was being processed, only ore stockpiling is taking place with processing planned
for 2016; therefore, minimum operations were taking place during the inspection. Processing of
Alternate Feed material is in progress but no activity was taking place at the time ofthe inspection.
No work area sampling was being conducted.
All 8 hour annual samples were collected and analyzed for the designated locations in April 2015.
Several of the locations prescribed for monthly sampling are not currently being used and/or locked,
e.g. women's locker room. Instrument Storage (formerly the Operator's Lunch Room); therefore,
the monthly air samples are not being collected in these areas All other areas are being sampled as
required.
Based on a recommendation from a previous inspection, the Licensee is bringing the air samplers
off from the floor when sampling by placing them on stands at the selected locations.
Personnel Breathing Zone Monitoring
No personnel breathing zone monitoring was being performed on the day ofthe inspection. The
radiation safety technician described the process of issuing BZ monitoring equipment.
A worker is issued a BZ sampling pump and filter as directed by the RSO. The radiation safety
technician completes the Breathing Zone Pump Calibration Form each time a BZ unit is issued.
This form documents that the pump is calibrated and ready for use. The air flow is adjusted to -4
liters per minute using a mass flow meter (Mesa Labs DryCal Defender 510 Primary Gas Flow
Calibrator). Three readings, and an average, are taken and recorded on the form. The technician fits
the BZ sampler on the worker and turns the pump on at the work site and retrieves the sampler when
the work for the period is done. The pump stores the air volume and the run-time.
The technician counts the air sample filter on a scaler and enters all pertinent information in the
Breathing Zone Sampling Field Sheet spread sheet.
Consistently high levels of air sampling measurements in the yellow cake packaging area prompted
the Licensee to redesign and rebuild this area in an attempt to reduce exposures to the workers.
Construction was in progress during the inspection with completion anticipated within the next
month.
Equipment Calibration
The area air sampling units (4) were checked and were not "due" for calibration until July 2015.
There was some discussion with the Licensee whether or not regular calibration of these pumps was
necessary or required. The Licensee indicated that a "functional check" was performed each time a
pump was used. This function check entailed ensuring the pump was drawing the desired air flow
as indicated on the flow rate meter attached to the pump The concern is the accuracy ofthe flow
rate meter. Confidence in this regard is dependent on the airflow measuring device having been
adequately calibrated. Guidance (Regulatory Guide 8.25. Air Sampling in the Workplace. 5.2) only
suggests that "The licensee should calibrate airflow meters at least annually." The Licensee agreed
Page 2 of 5
\\EQVMlvlFS03SP\shared\RAD\lvlON_WAST\Pgoble\Staff\Boyd lmai\EFR\lnspectionReportRevO-pg.doc
adequately calibrated. Guidance (Regulatory Guide 8.25, Air Sampling in the Workplace, 5.2) only
suggests that "The licensee should calibrate airflow meters at least annually." The Licensee agreed
to follow the manufacturer's recommended calibration frequency (annual) and make it a procedural
commitment.
Calibration of a BZ air sampler is performed just prior to issuance for use in the field. The pump
calibration is performed as described above. The gas flow calibrator (DryCal) is sent to the
manufacturer for calibration. The DryCal unit in use indicated it had a current calibration.
It was difficult to trace a particular Breathing Zone Pump Calibration Form to the data reported in
the Breathing Zone Sampling Field Sheet. After this was brought to the Licensee's attention, the
calibration form was immediately revised to include the Filter ID number which identifies which
line item on the field sheet corresponds to the pump used to collect the BZ air sample.
Airborne Radioactivity Area Posting
The North Dryer and South Dryer doors were posted as required (verified via real time video).
External Monitoring
The Licensee utilizes Optically Stimulated Luminescence (OSL) dosimetry for external monitoring.
The Licensee requires that dosimeters remain at the mill, worn or stored on a badge board.
OSLs when not being worn are kept on badge boards located near the men's locker room and in the
administration building. The corresponding OSL is clipped next to the worker's name. An
inventory of the badges is performed periodically to ensure badges are not removed from the mill.
Because the number of staff is relatively low a visual review of the board can indicate if a dosimeter
is missing. A reviewer knows when a dosimeter is not on the board either the employee has it and is
working or the dosimeter is missing. The radiation safety technician performs this inventory and
records any discrepancies on a log sheet. It was noted that if there were no discrepancies identified
either an entry to the log was made indicating no discrepancies or no log was filled out.
The radiation safety technician indicated that after the end of the shift is the best time to check the
boards because most employees have departed for the day and the dosimeters should have been
returned to the board and there are fewer absent from the board that have to be accounted for.
Workers (8) encountered during the inspection were asked to show their dosimeter to verify that
each individual had one and was wearing it properly.
It was brought to the Licensee's attention that an employee when asked to display his OSL
dosimeter he discovered that he inadvertently had retrieved the wrong dosimeter from the badge
board and had been wearing it for a short period (the error was discovered at approximately 1330 hr,
5/20/15). The RSO indicated that the information would be noted in case any concerns or problems
arise for this reporting period (second quarter 2015) because of this oversight. At the time the
miscue was discovered the employee indicated that he had not been in any area where he could have
received a dose.
Bioassay
Page 3 of 5
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Bioassay samples are being collected at the frequency prescribed, i.e. bi-weekly in specified areas
during production periods and monthly for workers in other areas. Since no production activities
are taking place at the time of the inspection, only bi-weekly samples are collected for workers at
the Sample Plant, Scale House, and the Sample Prep Room.
The sample preparation area is surveyed for alpha radiation contamination. The area must be
decontaminated to less than 25 dpm/100cm2 (removable alpha). 12.2 dpm/100cm2 was recorded on
a survey done on May 19, 2015. Prior to that, the last positive survey reading was 10.6 dpm/lOOcm2
on September 12, 2014. Removable disposable countertop sheeting is utilized to minimize surface
contamination.
Declared Pregnant Workers
There are currently no declared pregnant workers nor have there been since the last inspection.
Exit Meeting
P. Goble and B. Imai held an exit meeting with D. Hillsten, J. Perkins, and D. Turk of Energy Fuels
Resources (USA) on May 20, 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 relevant
requirements.
Recommendations for the Licensee
• Area air sampler equipment should be calibrated periodically. (Note: This was discussed
during the inspection and it is recognized that the procedure has since been revised to
address this recommendation.)
• For Quality Control purposes a backup scaler should be available to recount samples that
exceed action levels as per Section 1.1.2.8 of the Radiation Protection Manual. (Note: the
RSO indicated that another scaler, not currently in use, from another facility will be brought
to the mill and put in service)
• Section 1.1.2.6 of the Radiation Protection Manual indicates that start and stop times on BZ
pumps be recorded; however, the pumps indicate the amount of time the pumps have been
running and that the elapsed time is what is recorded. The information required by
procedure and the data being recorded should be in harmony.
• There should be consistency when inventorying the dosimeters. Licensee's actions should
be consistent whenever an inventory is done and there are no discrepancies (missing
dosimeters) identified.
• Emphasize to workforce the importance of utilizing the specific dosimeter that is assigned to
them.
• Assess significance and consequences ofthe employee wearing the wrong OSL dosimeter.
• When filling out the Chain of Custody form it is good practice to fill in all the information
requested on the form even though the information is recorded elsewhere.
Page 4 of 5
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2015\lnspectionReportRev0.doc
Recommendation for the Next Inspection
• Evaluate the new yellow cake packaging area regarding health physics and radiation safety
considerations.
• Determine whether or not there was a personnel dose issue as a result of the worker
temporarily wearing another individual's dosimeter and if so, how was it resolved.
• Delete Item No. 26 from the checklist. It is redundant and can be confusing. In the process
of verifying compliance with Item 21, the Radiation Safety Personnel should be accounted
for as well.
• Section 1.4.3 of the Radiation Protection Manual: "Sample preparation will be done in an
area decontaminated to less than 25 dpm alpha (removable) per 100 cm2 prior to preparation
of samples." Determine if the desired limit specified is "removable" or "wipeable."
Contamination on a wipe/swipe sample is only a fraction of what is '"removable." Is the
Licensee using the terms synonymously? If not, the distinctions should be made clear. (This
was not discussed during the inspection but it is something to consider when addressing
contamination control.
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)
28, 2015
(Date)
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RADMOD-IEM-012015
Inspection Report
ana
Inspection Checklists
INSPECTION REPORT
Inspection Module: RADMOD-IEM-01 2015
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): May 20, 2015
Inspector(s): Phil Goble, Utah Division of Radiation Control (DRC)
Boyd Imai, DRC
Personnel Contacted: Dan Hillsten, David Lacy, Abel Mendoza, Garren Palmer, Justin Perkins,
Terry Slade, David Turk of Energy Fuels Resources (EFR)
Inspection Summary
The inspection was opened on May 20, 2015 with a meeting among Licensee's D. Hillsten and D.
Turk and DRC's P. Goble and B. Imai.
Areas/Topics inspected included:
• Follow-up to Prior Inspection
• Work Area Air Sampling
• Personnel Breathing Zone (BZ) Monitoring
• Equipment Calibration
• Airborne Radioactivity Area Posting
• External Monitoring
• Bioassay
The P. Goble and B. Imai held an exit meeting on May 20, 2015 with D. Hillsten, J. Perkins, and D.
Turk of EFR to review the inspection activities, observations, and conclusions.
Findings
No infractions or violations were detected or encountered during the course of the inspection.
Inspection Items
Follow-up to Prior Inspection
The DryCal instrument indicated that a calibration had been performed within the last year.
Air Sampling data are reviewed by the Radiation Safety Officer (RSO) routinely.
The Licensee has two DryCal instruments so one is always available when the other one is out for
calibration.
Page 1 of 5
U:\lvlON WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2015\RAD!V10D-IE!V1-01
2015\InspectionReportRev0.doc
The Breathing Zone Sampling Field Sheet is reviewed and verified by the RSO each time a batch of
air sample data is entered into the spreadsheet.
Work Area Air Sampling
No uranium ore was being processed, only ore stockpiling is taking place with processing planned
for 2016; therefore, minimum operations were taking place during the inspection. Processing of
Alternate Feed material is in progress but no activity was taking place at the time of the inspection.
No work area sampling was being conducted.
All 8 hour annual samples were collected and analyzed for the designated locations in April 2015.
Several of the locations prescribed for monthly sampling are not currently being used and/or locked,
e.g. women's locker room, Instrument Storage (formerly the Operator's Lunch Room); therefore,
the monthly air samples are not being collected in these areas. All other areas are being sampled as
required.
Based on a recommendation from a previous inspection, the Licensee is bringing the air samplers
off from the floor when sampling by placing them on stands at the selected locations.
Personnel Breathing Zone Monitoring
No personnel breathing zone monitoring was being performed on the day of the inspection. The
radiation safety technician described the process of issuing BZ monitoring equipment.
A worker is issued a BZ sampling pump and filter as directed by the RSO. The radiation safety
technician completes the Breathing Zone Pump Calibration Form each time a BZ unit is issued.
This form documents that the pump is calibrated and ready for use. The air flow is adjusted to ~4
liters per minute using a mass flow meter (Mesa Labs DryCal Defender 510 Primary Gas Flow
Calibrator). Three readings, and an average, are taken and recorded on the form. The technician fits
the BZ sampler on the worker and turns the pump on at the work site and retrieves the sampler when
the work for the period is done. The pump stores the air volume and the run-time.
The technician counts the air sample filter on a scaler and enters all pertinent information in the
Breathing Zone Sampling Field Sheet spread sheet.
Consistently high levels of air sampling measurements in the yellow cake packaging area prompted
the Licensee to redesign and rebuild this area in an attempt to reduce exposures to the workers.
Construction was in progress during the inspection with completion anticipated within the next
month.
Equipment Calibration
The area air sampling units (4) were checked and were not "due" for calibration until July 2015.
There was some discussion with the Licensee whether or not regular calibration of these pumps was
necessary or required. The Licensee indicated that a "functional check" was performed each time a
pump was used. This function check entailed ensuring the pump was drawing the desired air flow
as indicated on the flow rate meter attached to the pump. The concern is the accuracy of the flow
rate meter. Confidence in this regard is dependent on the airflow measuring device having been
Page 2 of 5
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2015\RADMOD-IEM-01
2015\lnspectionReportRev0.doc
adequately calibrated. Guidance (Regulatory Guide 8.25, Air Sampling in the Workplace, 5.2) only
suggests that "The licensee should calibrate airflow meters at least annually." The Licensee agreed
to follow the manufacturer's recommended calibration frequency (annual) and make it a procedural
commitment.
Calibration of a BZ air sampler is performed just prior to issuance for use in the field. The pump
calibration is performed as described above. The gas flow calibrator (DryCal) is sent to the
manufacturer for calibration. The DryCal unit in use indicated it had a current calibration.
It was difficult to trace a particular Breathing Zone Pump Calibration Form to the data reported in
the Breathing Zone Sampling Field Sheet. After this was brought to the Licensee's attention, the
calibration form was immediately revised to include the Filter ID number which identifies which
line item on the field sheet corresponds to the pump used to collect the BZ air sample.
Airborne Radioactivity Area Posting
The North Dryer and South Dryer doors were posted as required (verified via real time video).
External Monitoring
The Licensee utilizes Optically Stimulated Luminescence (OSL) dosimetry for external monitoring.
The Licensee requires that dosimeters remain at the mill, worn or stored on a badge board.
OSLs when not being worn are kept on badge boards located near the men's locker room and in the
administration building. The corresponding OSL is clipped next to the worker's name. An
inventory of the badges is performed periodically to ensure badges are not removed from the mill.
Because the number of staff is relatively low a visual review of the board can indicate if a dosimeter
is missing. A reviewer knows when a dosimeter is not on the board either the employee has it and is
working or the dosimeter is missing. The radiation safety technician performs this inventory and
records any discrepancies on a log sheet. It was noted that if there were no discrepancies identified
either an entry to the log was made indicating no discrepancies or no log was filled out.
The radiation safety technician indicated that after the end of the shift is the best time to check the
boards because most employees have departed for the day and the dosimeters should have been
returned to the board and there are fewer absent from the board that have to be accounted for.
Workers (8) encountered during the inspection were asked to show their dosimeter to verify that
each individual had one and was wearing it properly.
It was brought to the Licensee's attention that an employee when asked to display his OSL
dosimeter he discovered that he inadvertently had retrieved the wrong dosimeter from the badge
board and had been wearing it for a short period (the error was discovered at approximately 1330 hr,
5/20/15). The RSO indicated that the information would be noted in case any concerns or problems
arise for this reporting period (second quarter 2015) because of this oversight. At the time the
miscue was discovered the employee indicated that he had not been in any area where he could have
received a dose.
Bioassay
Page 3 of 5
U:\MONJWAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2015\RAD1V1OD-1E1VT-01
2015\I nspection ReportRev0.doc
Bioassay samples are being collected at the frequency prescribed, i.e. bi-weekly in specified areas
during production periods and monthly for workers in other areas. Since no production activities
are taking place at the time of the inspection, only bi-weekly samples are collected for workers at
the Sample Plant, Scale House, and the Sample Prep Room.
The sample preparation area is surveyed for alpha radiation contamination. The area must be
decontaminated to less than 25 dpm/100cm2 (removable alpha). 12.2 dpm/100cm2 was recorded on
a survey done on May 19, 2015. Prior to that, the last positive survey reading was 10.6 dpm/100cm2
on September 12, 2014. Removable disposable countertop sheeting is utilized to minimize surface
contamination.
Declared Pregnant Workers
There are currently no declared pregnant workers nor have there been since the last inspection.
Exit Meeting
P. Goble and B. Imai held an exit meeting with D. Hillsten, J. Perkins, and D. Turk of Energy Fuels
Resources (USA) on May 20, 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 relevant
requirements.
Recommendations for the Licensee
• Area air sampler equipment should be calibrated periodically. (Note: This was discussed
during the inspection and it is recognized that the procedure has since been revised to
address this recommendation.)
• For Quality Control purposes a backup scaler should be available to recount samples that
exceed action levels as per Section 1.1.2.8 of the Radiation Protection Manual. (Note: the
RSO indicated that another scaler, not currently in use, from another facility will be brought
to the mill and put in service)
• Section 1.1.2.6 of the Radiation Protection Manual indicates that start and stop times on BZ
pumps be recorded; however, the pumps indicate the amount of time the pumps have been
running and that the elapsed time is what is recorded. The information required by
procedure and the data being recorded should be in harmony.
• There should be consistency when inventorying the dosimeters. Licensee's actions should
be consistent whenever an inventory is done and there are no discrepancies (missing
dosimeters) identified.
• Emphasize to workforce the importance of utilizing the specific dosimeter that is assigned to
them.
• Assess significance and consequences of the employee wearing the wrong OSL dosimeter.
• When filling out the Chain of Custody form it is good practice to fill in all the information
requested on the form even though the information is recorded elsewhere.
Page 4 of 5
U:\MON WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\2015\RADrvlOD-IEM-0I
2015\lnspectionReportRev0.doc
Recommendation for the Next Inspection
• Evaluate the new yellow cake packaging area regarding health physics and radiation safety
considerations.
• Determine whether or not there was a personnel dose issue as a result of the worker
temporarily wearing another individual's dosimeter and if so, how was it resolved.
• Delete Item No. 26 from the checklist. It is redundant and can be confusing. In the process
of verifying compliance with Item 21, the Radiation Safety Personnel should be accounted
for as well.
• Section 1.4.3 ofthe Radiation Protection Manual: "Sample preparation will be done in an
area decontaminated to less than 25 dpm alpha (removable) per 100 cm2 prior to preparation
of samples." Determine if the desired limit specified is "removable" or "wipeable."
Contamination on a wipe/swipe sample is only a fraction of what is "removable." Is the
Licensee using the terms synonymously? If not, the distinctions should be made clear. (This
was not discussed during the inspection but it is something to consider when addressing
contamination control.
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) (Signature)
May 28, 2015
(Date)
Page 5 of 5
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2015\lnspectionReportRev0.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-IEM-01 2015
INTERNAL/EXTERNAL MONITORING
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT 1900479
Inspector(s): /3 ^ ^ *t P. U<? Date(s): sjz~\l£>
References:
• Radioactive Material License UT1900479
• Radiation Protection Manual, Section 1 Revision: EFR 10, 07/14
• 10CFR20
• NRC Regulatory Guide 8.13
• NRC Regulatory Guide 8.22
• Utah Administrative Code R313-12-3
• Utah Administrative Code R313-15.
FOLLOW-UP FROM PREVIOUS INSPECTION (September 2013)
A) Check DryCal instrument calibration.
B) Breathing Zone Sampling Field Sheet validation.
C) Out of calibration "as found" condition follow-up
D) Annual Review of Air Sampling Measurements (Reg Guide 8.25, Section 6.5)
AIR SAMPLING
Radiation Protection Manual, Section 1.1.2, Breathing Zone Sampling, Section 1.1.2.2, Applicability:
Breathing zone samples are required:
for all calciner maintenance activities,
at least quarterly during routine operating and maintenance tasks on
representative individuals performing these tasks,
when radiation work permits are issued in which airborne
concentrations may exceed 25% of 10CFR20 limits,
weekly for yellowcake operations, or
at the discretion of the RSO. . i • . a*-
1) Are BZ air samples being taken: ^H^f^M*^ iM* ^«^rt*v~
for all calciner maintenance activities? v*~ Yes No O
at least quarterly during routine operating and maintenance tasks
on representative individuals performing these tasks? Yes f)Cj No [ |
when radiation work permits are issued in which airborne
concentrations may exceed 25% of 10CFR20 limits? Yes [X] No I I
weekly for yellowcake operation?, 3/**f Yes [3 No I I
at the discretion ofthe RSO? Yes • No •
Page 1 of 11
Comments:
2) Section 1.1.2.3 is the procedure for BZ sampling. Is this procedure being followed?
Yes0 NoD
Comments:
3) Section 1.1.2.6 lists the Data Records that are to be kept. Are they being kept? /"
Yes^g] NoD
Comments: gvy £ erfP j^w^ nS r^vy^-Ww^t ?
4) Section 1.1.2.7 shows the calculations to be used. Are these calculations being used?
Yes1£] No •
Are they being used correctly?
Yes[^l NoD
Comments:
Radiation Protection Manual, Section 1.1.2.4, Calibration
3.2 PERSONNEL AIR SAMPLERS
The calibration procedure for personnel air samplers involves primary and secondary calibration procedures
Samplers will be calibrated prior to each use by either of two methodologies bubble tube or mass flow
determinations Air samplers may be calibrated to standard air conditions.
3.2.1 Bubble Tube Calibration Method
3.2.3 Electronic Calibration Method
5) Are calibrations for BZ air samplers being performed and documented prior to each use?
Yes(^ NoD
Comments:
Page 2 of 11
6) For BZ air samples being taken, are calibrations for BZ air samplers being performed and documented in
accordance with Section 3.2.1 or 3.2.3 of the Radiation Protection Manual?
Yes NoD
Comments:
7) Observe a BZ being calibrated. Which procedure was used and was it done correctly?
Procedure: Yes |S No •
Comments:
8) Is the RSO reviewing results that exceed 25% of 10FR20 limits? flection 1.1.2.8)
Yes ^ No •
Comments: c^JWC ? )
Radiation Protection Manual, Section 1.1.3.1, Frequency and Locations
The following principles usedfor the collection of area grab samples must be considered when collecting a
sample in order to obtain a representative concentration that workers may be exposed to during their
assigned work tasks.
1. The locations selected for sampling should be representative of exposures to employees working in the
area.
2. For special air sampling, the sampling period should represent the conditions during the entire period of
exposure. This may involve sampling during the entire exposure period.
3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow rate of 40 liters per
minute for at least 60 minutes.
4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector.
5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or
non-routine situations.
Page 3 of 11
9) Are area grab samples obtained in areas representative of workers exposure? (During the Mill tour Have
the HP Staff show where the air samples are being taken.)
YeS/S No •
Comments:
10) For routine sampling, did the licensee sample at a minimum flow rate of 40 liters per minute for at least
60 minutes?
Yes£3 No •
Comments: ^ >W fj&r &^r^ (J >*-dr\
11) Were air sample filters analyzed for gross alpha using a sensitive alpha detector?
YesJQ NoD
Comments:
Table l.l.l-l for areas where the ALI <.01 and the DAC is <0.01 it state, "Air sampling is generally not
necessary. However monthly or quarterly grab samples or some other measurement may be appropriate
to confirm that airborne levels are indeed low. "
12) Are periodical grab samples taken on a Monthly or Quarterly frequency to confirm that airborne
radioactivity remain below ALI <.01 and the DAC is <0.01 values?
YesNoD
Comments:
RML License Condition 11.4
Annually, the licensee shall collect, during mill operations, a set of air samples covering eight hours of
sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per minute), in routinely or
Page 4 of 11
frequently occupied areas of the mill. These samples shall be analyzed for gross alpha. In addition, with
each change in mill feed material or at least annually, the licensee shall analyze the mill feed or
production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the
fundamental constituent composition of air sample particulates.
13) Did the licensee perform high volume alpha air sampling in routinely or frequently occupied areas of the
mill in accordance with L.C. 11.4? ^
Yes rj4 No •
Comments: Ql/O^- -Jo-
14) Did the air samples cover eight hours of sampling, at a high collection flow rate (i.e., greater than or equal
to 40 liters per minute)?
Yes^ NoD
Comments:
15) With each change in mill feed material or at least annually, did the licensee analyze the mill feed or
production product for U-nat, Th-230, Ra-226, and Pb-2 TO and use the analysis results to assess the
fundamental constituent composition of air sample particulates?
Yes EJ No •
Comments: Mill fi*e-J Lp-f A^Jo^r
Radiation Protection Manual, Section 1.1.3.2 Sampling Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for
one hour or longer. Equipment utilized will be an Eberline RAS-1, or a Scientific Industries Model H25004,
or equivalent. Filter media will be of appropriate micron pore diameter. Equipment is calibrated prior to
each usage as per Section 3.3 of this manual.
Page 5 of 11
16) Are calibrations for area air samplers being performed and documented prior to usage?
7 Yes • No •
Comments: T^UA*C^U* Qj~t Jj^ ~~ S*Vs jpfn^ ra^X
[ 7) Is the filter media used appropriate (micron pore diameter)?
Yes0 No •
Comments :
18) Are calibrations for area samplers being performed and documented in accordance with Section 3.3 of this
Manual?
7 Yes • NoD
Comments: j^6^MAfvu>-Jk^ —'
19) Has the licensee provided proper documentation of the results of calibration for the following air sampling
equipment?
TV*?/',5 Air Sampler
i& Air Sampler
T/?/fS Air Sampler frf / 5
? ft Air Sampler <fe?o
S/N
S/N
S/N
S/N
No • Yes
No • Yes
Yes g No •
Yes p/ No •
Comments:
S)^\\ L^CW Page6ofl.
20) Section 2.1.2 Frequency/Locations
Has the Licensee performed monthly uranium dust monitoring in the following areas? (Table 2.1.2-1)
Airborne Radiation Sample Locations
BA1 Ore Scalehouse Yes g| No • BA17 Change Room Yes [g No • ft BA2 Ore Storage Yes |H] No • BA1« Administrative Building Yes fifi No •
BA6 Sample Plant Yes g) No •
BA7 SAG Mill Area Yes 0No[ BA19 Warehouse Yes E No •
BA8 Leach Tank Area Yes |Xl No • BA20 Maintenance Shop Yes IJK
Yes IK
No •
BA9 Wash Circ CCD Thickness YesgjNoD BA21 Boiler No •
BA105 Sol Ex Bldg/Stripping Sec Yes g No [ BA22 Vanadium Panel Yes No •
BA11 M Sol Ex Bldg/Control Room Yes [g No • BA22A Vanadium Dryer YesfA No •
BA12 YC Precip/W Storage Area Yes BA23
Yes'jg] No •
Filter Belt/R^rtary Dryer Yes X No •
BA12A No. YC Dryer Enclosure 9 BA24 Tails
BA12B So. YC Dryer Enclosure Yes gl No [
Yes K NoD
BA25 Central Control Room Yes No •
BA13 YC Drying/Packaging Area Yes B No • BA26 Shifter's Office Yes Re NoD
BA13A YC Packaging Enclosure Yes E No • BA27 Operator's Lunch Room Yes0 No •
BAH Packaged YC Storage Room Yes H No • BA28 Dump Station Yes g] No •
BA15 Met Lab Sample Prep Room Yes \E No • BA29 Emerg Generator Station Yes * No •
BA16 Lunch Room Area Yes |S No [ BA30 Truck Shop
Women's Locker Room*
Yes IX No •
BA31 Yes X No •
BA 32 Oxidation Yes IX NoU
BA33A AF South Pad Yes \X No •
BA33B AF North Pad Yes [£ No •
Comments: r_ fj^> f*-*>t\t *^^o^x.9 S-o^ U^Mg (SA- <*^-W.Q.->\ «»-»vg. ^ ^-fc^P
10CFR20 Table 1 of Appendix B DAC values for 238U retention class Y: 2E-lluCi/ml Footnote 3 (for
238
If a mixture of radionuclides consists of uranium and its daughters in ore dust (10 um AMAD particle
distribution assumed) prior to chemical separation of the uranium from the ore, the following values may be
used for the DAC of the mixture: 6E-llpCi of gross alpha activity from uranium-238, uranium-234, thorium-
230, and radium-226per milliliter of air; 3E-11 fid of natural uranium per milliliter of air; or 45 micrograms
of natural uranium per cubic meter of air.
21) Where any of the air sample results from the above areas found to be in excess of the DAC values listed in
10CFR20 Table 1 of Appendix B?
t< 0 Yes ^| No •
Areas Identified ' ^ ' 5 , ^'5
Area DAC Value Area DAC Value Area DAC Value
Page 7 of 11
Comments:
Utah Rules R313-12-3. Definitions
"Airborne radioactivity area" means: a room, enclosure, or area in which airborne radioactive material
exists in concentrations:
(a) In excess of the derived air concentrations (DACs), specified in Rule R3I3-I5, or
(b) To such a degree that an individual present in the area without respiratory protective equipment could
exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on
intake (ALI), or 12 DAC hours.
Utah Rules R313-15-902. Posting Requirements
(4) Posting of Airborne Radioactivity Areas. 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."
22) If yes to 15, were the areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of
Appendix B properly posted?
Yesjg NoD
Comments: \loci^Ux$ \/N~> ^\C\JUO ^)«v-rk IVyr < ^u^bL t>yr
BIOASSAY PROGRAM
Radiation Protection Manual, Section 1.4.1 Frequency
Urinalysis will be performed on those employees that are a) exposed to airborne yellowcake or involved in
maintenance tasks during which yellowcake dust may be produced, or b) routinely exposed to airborne
uranium ore dust. Baseline urinalysis will be performed prior to initial work assignments.
Urine samples are collected on a routine basis from mill employees as required in Regulatory Guide 8.22.
Urine samples will be collected from employees who have worked in yellowcake packaging, yellowcake
precipitation, grind area (SAG Mill), ore feed, sample plant, scale house, and the sample preparation
room every two weeks during production periods. Samples will be collected from all other employees
monthly during production periods. During non-production periods, bi-weekly samples will be collected if
individual exposures are expected to exceed 25% of the DAC value otherwise samples will be collected
from all employees quarterly. Non-routine urinalysis will usually be performed on employees who have
been working on assignments that require a Radiation Work Permit, and always on any individual that
may have been exposed to airborne uranium or ore dust concentrations that exceed 25% of the DAC level.
23) Are urine samples being collected from workers who are working under an RWP?
Cot Yes^ N°n
Page 8 of 11
Comments:
24) Are bi-weekly urine samples being collected from workers in the following areas during production?
Yellowcake Packaging
Yellowcake Precipitation
Grind Area (SAG Mill)
Ore Feed - W«^SEpr'
Sample Plant
Scale House
Sample Prep Room - ^3r*^*Mi
YesD
YesD
YesD
YesD
Yesgj
Yes
Yes
No •
Non off Non vw
No
No •
NoU
NoD
Comments:
25) During production periods, are monthly urine samples being collected from all employees working in
areas other than those listed above? y
Yes£3 No •
Comments:
26) Are urine samples being collected from Radiation Safety Personnel every two weeks during production
periods? (Radiation Safety Personnel routinely work in areas listed in #2^ above).
Yes@ NoD N/A •
Comments: C <r . A^si^-^ f^jL—o u^y-l^s 0s* Sc^/e ^M^-^our^t
Section 1.4.3 Sample Preparation
Sample preparation will be done in an area decontaminated to less than 25 dpm alpha (removable) per 100
cm2 prior to preparation of samples. All of the equipment that is used in sample preparation will be clean and
maintained in such condition.
27) Are the sample preparation area contamination levels maintained below 25dpm/100cm2 a (removable)?
YesD NoD
Page 9 of 11
Comments: d-X 1 Ug^r -U AJfc f 2^(6 /^qy Za< gj) ^ fosr-U.* „
EXTERNAL MONITORING
28) Section 1.3 Beta-Gamma Surveys
Were all observed personnel wearing a personal monitoring badge while in the Restricted Area?
Yes^ NoD
Comments: kWfcrs *^<^<A^Js^r^ Juur^—t, ~-V*^-r- . lAJ^ya- Peft^r, (^M Jt^/v^.^^
p-SMTV^ , 1
Section 1.3.1 Monitoring Procedures ^ r<-c-*«^ ^^JI
monitoring procedures consist of: i
7. Personnel issued personal monitoring devices will wear the device on the trunk (torso) of the body or
visibly on the exterior of their hard hat. The personal monitoring device records beta/gamma radiation as
well as other forms ofpenetrating radiation such as x-rays. A personal monitoring device is an exposure
record of an individual's personal exposure to radiation while on the job. Therefore, personal monitoring
devices are to remain at the Mill in the personal possession of each individual, in a locker or other secure
area. All exposure records obtained by a personal monitoring device which are not consistent with the
exposure rates of work tasks or work location measurements made throughout the Mill will be evaluated by
the RSO. This evaluation will result in an investigation by the RSO and a written explanation of the findings.
These written records will be maintained at the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be exchanged by the
Radiation Safety Department. Missing or lost badges will be reported to management.
3. Female employees that become pregnant and continue to work during the course of their pregnancy will be
placed on a monthly personal monitoring device exchange during this period. NRC Regulatory Guide 8.13
provides guidelines to be followed during pregnancy and is made part of this procedure.
29) Under routine conditions, were observed employees wearing monitoring badges properly on the torso?
Yes|S NoD
Comments:
Page 10 of 11
30) Has the licensee assured that personal monitoring devices are being kept at the Mill in the possession of
the individual, in a locker or in another secure area?
YesS No •
Comments: boStr^A*- 5o-ur4? (g CJ^X^JL rre*— £ ^dcux^ gvA^
31) Check the dosimeter boards in the locker rooms, maintenance building and administration building. Are
the badges properly stored?
YesJS NoD
Comments:
32) Have any female workers declared their pregnancy in the past 2 years?
YesD No^
Comments: AJ/V
33) If yes to 32
above, has the declared pregnant worker been placed on a monthly personal monitoring device exchange
during this period?
Yes • No • N/A J3
Comments:
Page 11 of 11
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-IEM-01 2015
INTERNAL/EXTERNAL MONITORING
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Inspects): J^' , ^7 Da,e(s): ^4./r
References:
Radioactive Material License UT1900479
Radiation Protection Manual, Section 1 Revision: EFR 10, 07/14
10CFR20
NRC Regulatory Guide 8.13
NRC Regulatory Guide 8.22
Utah Administrative Code R313-12-3
Utah Administrative Code R313-15.
FOLLOW-UP FROM PREVIOUS INSPECTION (September 2013)
A) Check DryCal instrument calibration.
B) Breathing Zone Sampling Field Sheet validation.
C) Out of calibration "as found" condition follow-up
D) Annual Review of Air Sampling Measurements (Reg Guide 8.25, Section 6.5)
AIR SAMPLING
Radiation Protection Manual, Section 1.1.2, Breathing Zone Sampling, Section 1.1.2.2, Applicability:
Breathing zone samples are required:
for all calciner maintenance activities,
at least quarterly during routine operating and maintenance tasks on
representative individuals performing these tasks,
when radiation work permits are issued in which airborne
concentrations may exceed 25% of 10CFR20 limits,
weekly for yellowcake operations, or
at the discretion of the RSO.
1) Are BZ air samples being taken:
for all calciner maintenance activities?
at least quarterly during routine operating and maintenance^ tasks
on representative individuals performing these tasks?
when radiation work permits are issued in which airborne
eh
/AS^ fcN /M MlnA Yes^ NoD
e tasks
/W/^ Yes'f^I No •
concentrations may exceed 25% of 10CFR20 limits? ^/f / Yes^^£ No •
weekly for yellowcake operation?, Af N^ccfflJ Yes^\ No | |
at the discretion ofthe RSO? ' Yes^C No •
Page I «fl1
Comments:
2) Section 1.1.2.3 is the procedure for BZ sampling. Is this procedure being followed?
Comments:
Yes No •
3) Section 1.1.2.6 lists the Data Records that are to be kept. Are they being kept?
Yes fcf" NoD
Comments:
4) Section 1.1.2.7 shows the calculations to be used. Are these calculations being used?
Yes [H/NO •
Are they being used correctly? ^
YesM No •
Comments:
Radiation Protection Manual, Section 1.1.2.4, Calibration
3.2 PERSONNEL AIR SAMPLERS
The calibration procedure for personnel air samplers involves primary and secondary calibration procedures
Samplers will be calibrated prior to each use by either of two methodologies bubble tube or mass flow
determinations Air samplers may be calibrated to standard air conditions.
3.2.1 Bubble Tube Calibration Method
3.2.3 Electronic Calibration Method
5) Are calibrations for BZ air samplers being performed and documented prior to each use?
Yes ]% No •
Comments:
6) For BZ air samples being taken, are calibrations for BZ air samplers being performed and documented in
accordance with Section 3.2.1 or 3.2.3 of the Radiation Protection Manual?
Yes^/f NoD
Comments:
7) Observe a BZ being calibrated. Which procedure was used and was it done correctly?
Procedure: Yes 5cl No I I
Comments:
8) Is the RSO reviewing results that exceed 25% of 10FR20 limits? (Section 1.1.2.8)
YesgJ No •
Comments:
Radiation Protection Manual, Section 1.1.3.1, Frequency and Locations
The following principles used for the collection of area grab samples must be considered when collecting a
sample in order to obtain a representative concentration that workers may be exposed to during their
assigned work tasks.
1. The locations selected for sampling should be representative of exposures to employees working in the
area.
2. For special air sampling, the sampling period should represent the conditions during the entire period of
exposure. This may involve sampling during the entire exposure period.
3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow rate of 40 liters per
minute for at least 60 minutes.
4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector.
5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or
non-routine situations.
Page 3 of 11
9) Are area grab samples obtained in areas representative of workers exposure? (During the Mill tour Have
the HP Staff show where the air samples are being taken.)
Yes^ NoD
Comments:
10) For routine sampling, did the licensee sample at a minimum flow rate of 40 liters per minute for at least
60 minutes? > /
YesX] No • 0
Comments:
\11) Were air sample filters analyzed for gross alpha using a sensitive alpha detector?
' Yes^J NoD #
Comments:^°y 2?Z1 f Wo CcA^T ?
Table 1.1.1-1 for areas where the ALI <.01 and the DAC is <0.0I it state, "Air sampling is generally not
necessary. However monthly or quarterly grab samples or some other measurement may be appropriate
to confirm that airborne levels are indeed low. "
f Cl2) Are J 2) Are periodical grab samples taken on a Monthly or Quarterly frequency to confirm that airborne
^Taaioactivity remain below ALI <.01 and the DAC is <0.01 values?
YesTKl No[
Comments:
RML License Condition 11.4
Annually, the licensee shall collect, during mill operations, a set of air samples covering eight hours of
sampling, at a high collection flow rate (i.e., greater than or equal to 40 liters per minute), in routinely or
Page 4 of 11
frequently occupied areas of the mill. These samples shall be analyzed for gross alpha. In addition, with
each change in mill feed material or at least annually, the licensee shall analyze the mill feed or
production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the
fundamental constituent composition of air sample particulates.
13) Did the licensee perform high volume alpha air sampling in routinely or frequently occupied areas of the
mill in accordance with L.C. 11.4? ,
Yes 13- No • >
Comments:
14) Did the air samples cover eight hours of sampling, at a high collection flow rate (i.e., greater than or equal
to 40 liters per minute)?
YesT^[ No • *
Comments:
15) With each change in mill feed material or at least annually, did the licensee analyze the mill feed or
production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the
fundamental constituent composition of air sample particulates?
YesH] NoD
Comments:
Radiation Protection Manual, Section 1.1.3.2 Sampling Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for
one hour or longer. Equipment utilized will be an Eberline RAS-1, or a Scientific Industries Model H25004,
or equivalent. Filter media will be of appropriate micron pore diameter. Equipment is calibrated prior to
each usage as per Section 3.3 of this manual.
Page 5 of 11
16) Are calibrations for area air samplers being performed and documented prior to usage?
Yesjp NoD
Comments: gfr F**-^ C^ * ^k'-
17) Is the filter media used appropriate (micron pore diameter)?
Yes j)J No •
Comments: /•<? V»A . ^7 4* j l^ff>t Al5 Ipo/ptpj
d/za tr
18) Are calibrations for area samplers being performed and documented in accordance with Section 3.3 of this
Manual?
Yes fa7 No •
Comments:
Yes M > yea
7*
19) Has the licensee provided proper documentation of the results of calibration for the following air sampling
equipment? d*s A —
Air Sampler
Air Sampler
"7.
7, S/N /P^ffT
S/N gggZ"
S/N W
Comments:
Air Sampler ~7/
Air Sampler > //f- S/N / / ^3^
Yes^g No •
Yesg No •
Yes0 NoD
Yes(JS NoD
Page 6 of 11
y.ffo
20) Section 2.1.2 Frequency/Locations
Has the Licensee performed monthly uranium dust monitoring in the following areas? (Table 2.1.2-1)
Airborne Radiation Sample Locations
BA1 Ore Scalehouse Yes • No [ BA17 Change Room Yes • No •
BA2 Ore Storage Yes • No [ BA18 Administrative Building Yes • No •
BA6
BA7
Sample Plant Yes • No •
SAG Mill Area Yes • No [ BA19 Warehouse Yes • No •
BA8 Leach Tank Area Yes • No [ BA20 Maintenance Shop Yes • No •
BA9 Wash Circ CCD Thickness Yes • No [ BA21 Boiler Yes • No [
BA10 Sol Ex Bldg/Stripping Sec Yes • No [ BA22 Vanadium Panel Yes • No [
BA11 Sol Ex Bldg/Control Room Yes • No • BA22A Vanadium Dryer Yes • No •
BA12 YC Precip/W Storage Area Yes • No [ BA23 Filter Belt/Rotary Dryer Yes • No [
BA12A No. YC Dryer Enclosure Yes • No [ BA24 Tails Yes • No [
BA12B So. YC Dryer Enclosure Yes • No • BA25 Centra] Control Room Yes • No •
BA13 YC Drying/Packaging Area Yes • No • BA26 Shifter's Office Yes • No •
BA13A YC Packaging Enclosure Yes • No [ BA27 Operator's Lunch Room Yes • No [
BAM Packaged YC Storage Room Yes • No • BA28 Dump Station Yes • No [
BA15 Met Lab Sample Prep Room Yes • No • BA29 Emerg Generator Station Yes • No •
BA16 Lunch Room Area Yes DNo [ BA30 Truck Shop Yes • No •
BA3 Women's Locker Room Yes • No [
BA32 Oxidation Yes • No [
BA33A AF South Pad Yes • No •
BA33B AF North Pad Yes • No •
Comments:
10CFR20 Table 1 of Appendix B DAC values for 238U retention class Y: 2E-lluCi/ml Footnote 3 (for
238U):
If a mixture of radionuclides consists of uranium and its daughters in ore dust (10 fim AMAD particle
distribution assumed) prior to chemical separation of the uranium from the ore, the following values may be
used for the DAC of the mixture; 6E-1 ljuCi of gross alpha activity from uranium-238, uranium-234, thorium-
230, and radium-226 per milliliter of air; 3E-1lpiCi of natural uranium per milliliter of air; or 45 micrograms
of natural uranium per cubic meter of air.
21) Where any of the air sample results from the above areas found to be in excess of the DAC values listed in
10CFR20 Table 1 of Appendix B?
Yes • No •
Areas Identified
Area DAC Value Area DAC Value Area
IL
DAC Value
(T
Page 7 of 11
Comments:
Utah Rules R313-12-3, Definitions
"Airborne radioactivity area" means: a room, enclosure, or area in which airborne radioactive material
exists in concentrations:
(a) In excess of the derived air concentrations (DACs), specified in Rule R3I3-15, or
(b) To such a degree that an individual present in the area without respiratory protective equipment could
exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on
intake (ALI), or 12 DAC hours.
Utah Rules R313-15-902, Posting Requirements
(4) Posting of Airborne Radioactivity Areas. 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. "
22) If yes to 15, were the areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of
Appendix B properly posted?
Yes No •
Comments: blorjk f~ (V/^ Dod^
BIOASSAY PROGRAM
Radiation Protection Manual, Section 1.4.1 Frequency
Urinalysis will be performed on those employees that are a) exposed to airborne yellowcake or involved in
maintenance tasks during which yellowcake dust may be produced, or b) routinely exposed to airborne
uranium ore dust. Baseline urinalysis will be performed prior to initial work assignments.
Urine samples are collected on a routine basis from mill employees as required in Regulatory Guide 8.22.
Urine samples will be collected from employees who have worked in yellowcake packaging, yellowcake
precipitation, grind area (SAG Mill), ore feed, sample plant, scale house, and the sample preparation
room every two weeks during production periods. Samples will be collected from all other employees
monthly during production periods. During non-production periods, bi-weekly samples will be collected if
individual exposures are expected to exceed 25% of the DAC value otherwise samples will be collected
from all employees quarterly. Non-routine urinalysis will usually be performed on employees who have
been working on assignments that require a Radiation Work Permit, and always on any individual that
may have been exposed to airborne uranium or ore dust concentrations that exceed 25% of the DAC level.
23) Are urine samples being collected from workers who are working under an RWP?
Yes f No •
Page 8 of 11
Comments:
24) Are bi-weekly urine samples being collected from workers in the following areas during production?
Yellowcake Packaging
Yellowcake Precipitation
Grind Area (SAG Mill)
Ore Feed
Sample Plant
Scale House
Sample Prep Room (
Yes L No *
2 • Yes No
YesU No
Yes No
No Yes
No _ Yes1E
Yes No •
Comments:
25) During production periods, are monthly urine samples being collected from all employees working in
areas other than those listed above?
Yesg No •
Comments: <?^^?< 6N^)fX d?o«L MpM-j
26) Are urine samples being collected from Radiation Safety Personnel every two weeks during production
periods? (Radiation Safety Personnel routinely work in areas listed in #3^ above).
Yes£& NoD N/A •
Comments:
Section 1.4.3 Sample Preparation
Sample preparation will be done in an area decontaminated to less than 25 dpm alpha (removable) per 100
cm2 prior to preparation of samples. AU of the equipment that is used in sample preparation will be clean and
maintained in such condition.
I 27yAre the sample preparation area contamination levels maintained below 25dpm/100cm a (removable)?
^ S^'^f YesD No • *
Page 9 of 11
Comments: 4 Q^.z) 0 Ls*~<"f
EXTERNAL MONITORING
28) Section 1.3 Beta-Gamma Surveys
Were all observed personnel wearing a personal monitoring badge while in the Restricted Area?
Yes t^L No •
Comments:
Section 1.3.1 Monitoring Procedures
The monitoring procedures consist of:
1. Personnel issued personal monitoring devices will wear the device on the trunk (torso) of the body or
visibly on the exterior of their hard hat. The personal monitoring device records beta/gamma radiation as
well as other forms ofpenetrating radiation such as x-rays. A personal monitoring device is an exposure
record of an individual's personal exposure to radiation while on the job. Therefore, personal monitoring
devices are to remain at the Mill in the personal possession of each individual, in a locker or other secure
area. All exposure records obtained by a personal monitoring device which are not consistent with the
exposure rates of work tasks or work location measurements made throughout the Mill will be evaluated by
the RSO. This evaluation will result in an investigation by the RSO and a written explanation of the findings.
These written records will be maintained at the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be exchanged by the
Radiation Safety Department. Missing or lost badges will be reported to management.
3. Female employees that become pregnant and continue to work during the course of their pregnancy will be
placed on a monthly personal monitoring device exchange during this period. NRC Regulatory Guide 8.13
provides guidelines to be followed during pregnancy and is made part of this procedure.
29) Under routine conditions, were observed employees wearing monitoring badges properly on the torso?
Yesl^kj^o •
Comments:
Page 10 of 11
30) Has the licensee assured that personal monitoring devices are being kept at the Mill in the possession of
the individual, in a locker or in another secure area? ,
Yes^l NoD
Comments: //P j/eC"*^ CD^^ TWC ^ ^«c(L
31) Check the dosimeter boards in the locker rooms, maintenance building and administration building. Are
the badges properly stored?
Yes No •
Comments:
32) Have any female workers declared their pregnancy in the past 2 years?
YesD No
Coirfments:
33) If yes to 32
above, has the declared pregnant worker been placed on a monthly personal monitoring device exchange
during this period?
Yes • No • N/A ^
Comments:
Page 11 of 11
Work Area Airborne
Sampling
Month: February-15
Monthly Area Airborne Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location
Date
Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
_BV_ Comments
BA-1 Scalehou.se 02/03/15 60 40 2.40E+06 JP Collected on desk in front loom
BA-2 Ore Storage 02/03/15 60 40 2.40E+06 JP Collected on the Ore Pad
BA-7 Sag Mill NA 0 00E+00 NA Area is no longci in use No sample collected
BA-8 Leach 02/09/15 60 40 2 40E+06 JP Collected near pre-leach tanks
Air Particulate Calculations Summary Sheet
Reviewed by
Count
Date/Time Filter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot.-Bkg )
LLD
(uO/mL)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted By
02/06/15 BA1 2929 19.30% 40 13.37 0.00 5 51E-12 0.00E+00 0 00% CM
02/06/15 BA2 2929 19.30% 52 5.2 13 37 0 00 5.51E-12 0.00E+00 0.00% CM
NA BA7 NA 20 14% 20 07 0 00 #DIV/0! #DIV/0! #DIV/0! NA
02/12/15 BA8 2200 20.14% 92 9.2 20.07 0 00 6.41E-12 0 00E+00 0.00% DT
Concentration ( fjCi/cc)= (Net CPM)
(2.22 E6)(V)(Eff.d)
LLD or MDA= 2 71+3.29 V Bkg.*Ts( 1+Ts/Tb)
(Ts)(Eff. d)(Eff. f)(FF)(V)(2 22E6)
Ts= Time of Sample
Tb= Background Count Time in Minutes
Eff. d= Detector efficiency in Counts per Disintegration
Eff. f = Filter Efficeincy
V= Total Volume in millilitres or Cubic Centimeters
2 22E6 = Factor to convert DPM to uCi
Net CPM = Total Counts - Background Count
Percent of DAC= Actual Concentration
DAC
Month February-15
Monthly Area Airborne Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location
Date
Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BA-9 CCD 02/09/15 60 40 40E+06 Collected on cast end on main llotu
BA-10 SX-South 02/03/15 60 40 2 40F.+06 .IP Collected on south end ol buildni"
BA11 S.VNoiHi 02/09/15 60 40 2 40E+06 .IP Collected outside control loom
BA12 N C' I'iccip 02/09/15 60 40 40E+06 .IP Collected on south tahle in piccip aici
BA12A North Dryci NA 40 0 00E+00 NA AICM is no longct in use No sample collected Aic.i is locked
Reviewed bv
Air Particulate Calculations Summary Sheet
Count
Date/Time liter ID
Instrument
Serial No. Efficiency
Total
Count/Time CPM
Bkg.
Count/Time
Net Count
(Tot -Bkg )
LLD
(uCi/ml.)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted By
02/12/15 BA9 2200 20 14% 90 20.07 0.00 6.41 E-12 0 00E+00 0.00% DT
02/06/15 BA10 ZOO 20 14% 76 7.6 20 07 0 00 641E-12 0 00E+00 0 00% CM
02/12/15 BA11 2200 20 14% 79 7 9 20 07 0.00 641E-12 0 00E+00 0 00% DT
02/12/15 BA12 2929 19 30% 426 42 6 13.37 29.23 5.51 E-12 .X4E-11 5.69% DT
NA BA12A NA 20.14% 20 07 0 00 //DIV/01 «DIV/0! //DIV/0! NA
Concentration ( pCi/cc) = (NelCPM)
(2 22 E6)(V)(Eff.d)
,LD or MPA- 2 71 13.29 V Bkg *Ts(l ' Ts/Th)
(Ts)(El'f. d)(Eff. f)(I'T)(V)(2 22E6)
Ts~ Time of Sample
Tb= Background Count Time in Minutes
Eff d= Detector efficiency in Counts per Disintegration
Eff f-~ Filter Effieeincy
V- Total Volume in millilitres of Cubic centimeters
2.22E6 =- Factor to convert DPM to uCi
Net CPM - Total Counts - Background Count
Percent of DAO Actual Concentration
DAC
Month February-15
Monthly Area Airborne Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location
Date
Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BA12B South Dryci 02/13/15 60 40 2.40E+06 JP Collected inside South Dryer Dryer was running
BA13 Pckg Area 02/13/15 60 40 2.40E+06 JP Collected on the north end
BA13A Pckg Encl 02/09/15 60 40 2.40E+06 JP Collected inside cnclosuic
BA14 YC Storage 02/09/15 60 40 2 40E+06 JP Collected on the south end
^A15 Bucking Room 02/09/15 60 40 2 40E+06 JP Collected on sample piep Lililc
Reviewed by:
Air Particulate Calculations Summary Sheet
Count
Date/Time Filter ID
Instrument
Serial No. Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot -Bkg )
LLD
(uCi/mL)
Concentration
uCi/ mL
Percent ol
DAC
Sample Counted
By
02/16/15 BA12B 2200 20 14% 17421 1742.1 20 07 1722.03 6.4IE-12 1 60E-09 7292.83% DT
02/16/15 BA13 2929 19.30% 170 17 13 37 3.63 5 51E-12 0.00E+00 0 00% DT
02/12/15 BA13A 2929 19 30% 164 164 13.37 3.03 5 51 E-12 0.00E+00 0 00% DT
02/12/15 BAH 2929 19 30% 51 13 37 0.00 5.51E-12 0.00E+00 0.00% DT
02/12/15 BA15 200 20 14% 102 10 2 20.07 0 00 6.41E-12 0.00E+00 0 00% DT
fv*icentration ( pCi/cc) = (Net CPM)
(2.22 E6)(V)(Eff.d)
LLD or MDA- 2 71+3 29 V Bkg *Ts(l+Ts/Tb)
(Ts)(Eff d)(Eff t)(FF)(V)(2 22E6)
Ts= Time of Sample
Tb= Background Count Time in Minutes
Eff d= Detector efficiency in Counts per Disintegration
Eff f-= Filter Efficeincy
V^ Total Volume in millihtres of Cubic centimeters
2 22E6 =- Factor to convert DPM to uCi
Net CPM ~ Total Counts - Background Count
Percent of DAC Actual Concentration
DAC
Month February-15
Monthly Area Airborne Sampling Held Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location
Date
Run Time
(Min.)
Flow Rate
(LPIV1)
Volume
(mL)
Sampled
Bv Comments
BA-16 L IMILII Room 02/09/15 60 40 2.40Er06 Collected on lunch table
BA-17 Change Room 02/03/15 60 40 2 40E+06 JP Collected on bench in lockci mom .ue.i
BA-18 Admin Bldg 02/10/15 60 40 2 40E+06 JP Collected inside the training loom
BA-19 Warehouse 02/03/15 60 40 2 40E+06 JP Collected on Receiving Table
BA-20 M.iml Shop 02/03/15 60 40 2 40E+06 JP Collected on bench on the south wall
Reviewed bv
Air Particulate Calculations Summary Sheet
Count
Date/Time Filter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot -Bkg )
LLD
(uCi/mL)
Concentration
uCV mL
Percent ol
DAC
Sample
Counted Bv
02/12/15 BA16 2929 19 30% 47 4 7 13 37 0 00 5.5 IE-12 0 00 If+00 0 00% DT
02/06/15 BA17 2929 19 30% 58 5 8 13 37 0.00 5 51E-L 0 00E »0() 0 00% CM
02/13/15 BA18 2929 19 30% 66 6.6 13 37 0.00 5 51E-12 000E+00 0 00% JP
02/06/15 BA19 2200 20.14% 72 7 2 20 07 0.00 6 41E-12 0 00E+-00 0 00% CM
02/06/15 BA20 2200 20.14% 96 9 6 20 07 0 00 641E-12 0 00E+00 0 00% CM
Concentration ( pCi/cc)-(Nct CPM)
(2 22 E6)(V)(Eff.d)
LLD or MDA= 2 7 H-3 29 *J Bkg *Ts(l+Ts/Tb)
(Ts)(Eff d)(Eff l)(FF)(V)(2 22E6)
Ts- Time of Sample
Tb= Background Count Time in Minutes
Eff. d= Detector efficiency in Counts per Disintegration
Eff f- Filter Efficeincy
V~ Total Volume in millilitrcs of Cubic centimeters
2 22E6 = Factor to convert DPM to uCi
Net CPM Total Counts - Background Count
Percent of DAC= Actual Concentration
DAC
Month February-15
Monthly Area Airborne Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date
Sampled
Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BA21 Boilci 2/63/15 60 40 2 40E+06 JP Collected al the west side room in boiler area
BA22 Van Panel NA 40 0.00E+00 NA Area is no longer in use No sample collected
BA22A Van Drying NA 40 0 00E+00 NA Aiea is no longer in use No sample collected
BA23 Van Filter NA 40 0 00E+00 NA Area is no longer in use No sample collected
BA24 Tails 02/02/15 60 40 2 40E+06 JP Collected al Cell tt 3
Reviewed by
Air Particulate Calculations Summary Sheet
Count
Date/Time Filter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg.
Count/Time
Net Count
(Tot-Bkg.)
LLD
(uCi/mL)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted Bv
02/06/15 BA21 2929 19 30% 57 5 7 13.37 0 00 5 51E-12 0.00E+00 0.00'%, CM
NA BA22 NA 20.14% 20 07 0 00 //DIV/0' //DIV/0' //DIV/0' NA
NA BA22A NA 20.14% 20.07 0 00 //DIV/0' //DIV/01 //DIV/01 NA
NA BA23 NA 20.14% 20.07 0.00 //DIV/0! //DIV/01 //DIV/01 NA
02/05/15 BA24 2929 19.30% 42 4.2 13.37 0.00 5.51E-12 0.00E+00 0.00% CM
"mcentration ( u.Cl/cc) (Net CPM)
(2 22 E6)(V)(Eff.d)
LLD or MDA- 2.71+3.29 V Bkg.*Ts( HTs/Tb)
(Ts)(Eff. d)(Eff. f)(FF)(V)(2 22E6)
Ts= Time of Sample
Tb= Background Count Time in Minutes
Eff. d= Detector efficiency in Counts per Disintegration
Eff. f = Filter Efficeincy
V= Total Volume in millilitres of Cubic centimeters
2.22E6 - Factor to convert DPM to uCi
Net CPM Total Counts - Background Count
Percent of DAC -= Actual Concentration
DAC
Month: February-15
ivionmiy Area Airoorne sampling tieia Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BA2S (TR 02/09/15 60 40 2.40E+06 .IP Collected ne.n entrv dooi
BA26 ShiltersOII NA 40 0 00E+00 NA Area is no lonyei m use No sample collected
BA27 ()pci's L Rin NA 40 0.00H+00 NA AiCii is no longci in use No sample LOHCLIOJ
BA28
C'.il ; Dump
Station 02/03/15 60 40 2.40E+06 .IP Collected inside enclosuic neai the dumpci .uca
BA29 (icncraloi 02/03/15 60 40 2 40E+06 Collected on the north cast comci ol the eineigency gcncraloi station
Reviewed by
Air Particulate Calculations Summary Sheet
Count
Date/Time liter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot-Bkg )
LLD
(uCi/mL)
Concentration
uCi/ ml.
Percent of
DAC
Sample
Counted Bv
02/12/15 BA25 2929 19 30% 107 10 7 13 37 0 00 5 51E-12 0.00E+00 0 00% DI
NA BA26 NA 20 14% 20 07 0 00 //DIV/0' //DIV/01 //DIV/01 NA
NA BA27 NA 20.14% 20.07 0 00 //DIV/0' //DIV/01 //DIV/01 NA
02/06/15 BA28 2200 20.14% 76 7 6 20 07 0 00 641E-12 0 OOE' OO 0 00% CM
02/06/15 BA29 2200 20 14% 89 8 9 20 07 0 00 6 41I-.-I2 0 00E+00 0 00% CM
Concentration ( JJCI/CC)-(Net CPM)
(2.22 E6)(V)(Eff d)
LLD or MDA= 2 7H3 29 V Bkg.*Ts( 1 ' Ts/Th)
(Ts)(Eff d)(Eff f)(IT)(V)(2 22E6)
Ts= Time of Sample
Tb- Background Count l ime in Minutes
Eff d= Detector efficiency in Counts per Disintegration
Eff f= Filter Efficcincy
VTotal Volume in millilitres of Cubic centimeters
2 22E6 = Factor to convert DPM to uCi
Net CPM ••= Total Counts - Background Count
Percent of DAC~ Actual Concentration
DAC
Month-February-15
Monthly Area Airborne Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BA30 Truck Shop 02/02/15 60 40 2 40E+06 JP Southeast comet
BA31 W Change Km 02/03/15 60 40 2 40E+06 JP Sink countei
BA6 Sample Plant 02/03/15 60 40 2 40E+06 JP Southwest comei (inside)
BA32 Oxidation 02/03/15 60 40 :40E+06 JP Bv oxidation tank
BA33A AF South I'.id 02/03/15 60 40 2 40E+06 JP End ol pad in the middle
Reviewed by
Air Particulate Calculations Summary Sheel
Count
Date/Time Filter ID
Instrument
Serial No Efficiency
lotal
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot-Bkg )
LLD
(uCi/mL)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted By
02/05/15 BA30 2929 19 30% 50 13.37 0 00 5 51 E-12 O.OOE'OO 0 00% CM
02/06/15 BA31 2929 19 30% 36 3 6 13 37 0 00 5 51E-12 0 00E-* 00 0.00% CM
02/06/15 BA6 2929 19 30% 36 3 6 13 37 0 00 5 51 E-12 0 OOE-i-OO 0 00'!',, CM
02/06/15 BA32 2200 20 14%, 65 6 5 20 07 0 00 641E-12 0 OOE+00 0 00% CM
02/06/15 BA33A 200 20.14% 73 7 3 20 07 0 00 641E-12 0 OOEiOO 0 00"/,, CM
' ">ncentration ( pCl/cc)-(NetCPM)
(2 22 E6)(V)(Eff.d)
LLD or MDA 2 7 H-3 29 V Bkg *Ts() *-Ts/Tb)
(Ts)(Eff. d)(Eff f)(FF)(V)(2.22E6)
Ts= Time of Sample
Tb= Background Count Time in Minutes
Eff. d= Detector efficiency in Counts per Disintegration
Eff f = Filter Efficeincy
V=- Total Volume in millihtres of Cubic centimeters
2.22E6 •= Factor to convert DPM to uCi
Net CPM = Total Counts - Background Count
Percent of DAC Actual Concentration
DAC
Month. February-15
iviontniy Area Airborne sampling Meld Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date Run Time Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BA33B Al North Pad 02/03/15 60 40 40E+06 Collected neat 11 ll oi pics
BA33C
111 , Dump
Station 02/03/15 60 40 2 40E+06 .IP Collected at dump station
Reviewed by
Air Particulate Calculations Summary Sheet
Count
Date/Time Filter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot -Bkg )
LLD
(uCi/mL)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted Bv
02/06/15 BA33B 2929 19 30% 13 37 0.00 5 51E-I2 0.00E+00 0 00% CM
02/06/15 BA33C 2200 20 14% 71 7 1 20 07 0 00 641E-12 OOOEHM) 0 00% CM
Concentration ( pCi/cc)^ (Net CPM)
E6)(V)(Elfd)
LLD or MDA- 2 71+3 29 V Bkg *Ts( H Ts/Th)
(Ts)(Eff d)(Eff 1)(FF)(V)(2.22E6)
Ts= Time of Sample
Tb= Background Count Time in Minutes
Eff d= Detector efficiency in Counts per Disintegration
Eff f= Filter Efficcincy
V= Total Volume in milhhtres of Cubic centimeters
2 22E6 = Factor to convert DPM to uCi
Net CPM = Total Counts - Background Count
Percent of DAC Actual Concentration
DAC
Area Airborne Conce*-Nation Instrument Efficiencies, Infor ^tion, and Data Sheet
February 2015
DAC N
ORE
LEACH
CCD
SX
PRECIP
PCKG.
TAILS
RADON
CaF2 Ore
UF4 Leach
Calcine Ore
KF Ore
UF4 Ore
2929 LLD=
Regen
Regen Leach
CaF2 Leach
umbers
6.00E-
1.10E-
1.20E-
1.20E-
5.00E-
2.20E-
1.70E-
3.30E-
8.00E-
3.70E-
1.30E-
2.60E-
3.00E-
7.48E-
4.20E-
4.60E-
1.60E-
Ludlum Model 2929 Efficiency Check
11
10
11
11
lu
01
12
10
1 1
10
10
13
10
10
11
Cnt. Time:
Background
Count No.
1
2
3
60 min. bkgd. Value
Total Bkgd.
Bkgd. Ave.
Source DPM
Efficiency
Standard Deviation
Efficiency Factor
MDA
Volume Collected
Factor to Convert
DPM to uCi/CC
Reading
14.8
12.6
12.7
1.6
13.4
10 Cnt. Time:
Efficiency Check
Count No.
1
2
3
Total CPM
CPM Ave.
Source Ser. No.
1.2
10 Min
Reading
2992.00
3012.80
3004.10
9008.9
3002.97
0314-02
15560
19.30%
10.45
5.18
102.13
2.40E+06
2.22 E+6
2Pi Laboratory Eff.at voltage with Pu-239:
2Pi WMM Eff.at yoltage with Pu-239:
85.10%
73.45%
2200 LLD=: 1.02E-12
Laboratory Calibration Efficiency Check
Reading
Count No. 2929 2200
1 27880.70 29708.70
2 27966.10 29700.20
3 27885.70 29736.10
Ludlum Model 2200 Efficiency Check
Cnt. Time:
Background
Count No.
1
2
3
Reading
19.8
21.2
19.2
10 Cnt. Time:
Efficiency Check
Count No.
1
2
3
10 Min
Reading
3142.60
3134.10
3126.80
Total Bkgd.
Bkgd. Ave.
Average 2791 1 29715 60 min. bkgd.
Source DPM 38000 38000 Source DPM
4Pi Efficiency 73.45% 78.20% Efficiency
at WMM Standard Deviation
Factor
MDA
Volume Collected
Factor to Convert
DPM to uCi'CC
2Pi Laboratory Eff.at voltage with Pu-239:
2Pi WMM Eff.at voltage with Pu-239:
60.2
20.1
2.7
1.0
Total CPM
CPM Ave.
Source Ser. No.
9403.5
3134.50
0314-02
15560
20.14%
7.91
4.96
116.86
2.40E+06
2.22 E+6
87.30%
78.20%
Notes:
The weather for sampling this month was very cold and no snow.
Area Airborne Conce* "-ation Instrument Efficiencies, Infor tion, and Data Sheet
February 2015
DAC Numbers Ludlum Model 3030 Efficiency Check
ORE
LEACH
CCD
SX
PRECIP
PCKG
TAILS
RADON
CaF2 Ore
CaF2 Leach
Calcine Ore
2929 LLD-
6 00E-U
1 10E-10
1 20E-1
1 20E-1
500E-1
2 20E-1
1 70E-1
3 30E-0
8 O0E-1
1 60E-1
1 30E-1
7 48E-13
Cnt Time
Background
Count No
1
2
3
60 min hkgd Value
Total Bkgd
Bkgd A\e
Source DPM
Efficiency
Standard De\ lation
Efficiency Factor
MDA
Volume Collected
Factor to Convert
DPM to uCi CC
Readme
10 Cnt Time
Efficiency Check
Count No
1
1 6
0 0
^DIV/01
frDIVO'
Total CPM
CPM Ave
Source Ser No
10 Mm
Reading
0 0
mw 0'
5994-09
19390
#DIV/0'
#DlV/0'
frDIV/0'
#DIV-0'
2 40E+06
2.22 E+6
2Pi Laboratory Eff at voltage with Pu-239
2Pi WMM Eff at voltage with Pu-239
85.10%
frDIV 0'
2200 LLD- 1 02E-12
Laboratory Calibration Efficiency Check
Reading
Count No 3030 2200
1
2
3
Ludlum Model 2200 Efficiency Check
Cnt Time
Background
Count No
1
~>
3
10 Cnt Time
Efficiency Check
Reading Count No
I
2
3
10 Min
Reading
Average
Source DPM
4Pi Efficiency
at WMM
frDIV/0'
38000
rfDIV/01
frDIV'0!
38000
frDIWO'
Total Bkgd
Bkgd Ave
60 min bkgd
Source DPM
Efficiency
Standard De\ lation
Factor
Volume Collected
Factor to Convert
DPM to uCVCC
2Pi Laboratory Eff at voltage with Pu-239
2Pi WMM Eff at voltase with Pu-239
00
frDIV'O'
2 65
frDIV/0'
Total CPM
CPM Ave
Source Ser No
0 0
#DIV/0!
S-1738
33000
#DIV/0!
#DIV/0'
frDIV/0!
2 40E+06
2 22 E-6
87 30%
fr'DIV'O'
Notes
Month:
Energy Fuels Resources (USA) Inc.
White Mesa Mill
^eb<^vnc^ Radiation Monitoring
Area Airborne Sampling Location's Field Sheet
February-15 Sampled B>: "J""f* T • ^ ^Q"vA.' Vo-S-
Filter Id. Location/Description
Scalehouse
Pump # Date Time On Time Off
Total Sample
Time in
Minutes
"fjrr
Volume in
L/Min.
411
Total Volume
2.4 b 6
Ore Storage 60 40 2.4 E 6
2.4 E 6 Sample Plant 60 40
SAG Mill NA 60 40 2.4 E 6
Leach Q32A-60 40 2.4 E 6
CCD 60 40 24E6
10 SX South/Stripping Section 60 40 2 4 E6
11 SX North /Control Room 60 40 2.4 E 6
12 YC Precip 60 40 2.4 E 6
12A North Dryer NA 60 40 2 4 E6
12B South Dryer lo-n 60 40 2.4 E 6
BA13 Pkg Area H>3r QL-i3>-iy-60 40 2.4 E 6
BA13A Pkg Enclosure 60 40 2.4 E 6
14 Packaged YC Storage 60 40 2.4 E 6
15 Bucking Room 60 40 2.4 E 6
16 Lunch Room/Training Room 60 40 2.4 E 6
17 Change Room 60 40 24E6
18 Administration Building 60 40 2.4 E 6
19 Warehouse 60 40 2.4 E 6
20 Maintenance Shop 60 40 2.4 E 6
21 Boiler 60 40 2.4 E 6
22 Vanadium Control Panel NA 60 40 2.4 E 6
22A Vandium Drying NA 60 40 2.4 E 6
23 Vanadium Filter Belt NA 60 40 2.4 E 6
24 Tails 60 40 2.4 E 6
25 Central Control Room 60 40 2.4 E 6
26 Shifter's Office NA 60 40 2.4 E 6
27 Operator's Lunchroom NA 60 40 2.4 E 6
28 CaF2 Dump Station 60 40 2.4 E 6
29 Emergency Generator Station 60 40 2.4 E 6
30 Truck Shop 60 40 2.4 E 6
31 Women's Locker Room 60 40 2.4 E 6
32 Oxidation NA 60 40 2.4 E 6
33A AF South Pad 60 40 2.4 E 6
33B AF North pad 60 40 2.4 E 6
33C UF4 Dump Station 60 40 2.4 E 6
Le,o.cv\ ^too^ oms- y^s- OUT o&s
4
Month:
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radiation Monitoring
Area Airborne Sampling Location's Field Sheet
January-15 Sampled By
Filter Id.
T
Location/Description
Scalehouse
Pump # Date Time On Time Off
Total Sample
Time in
Minutes
"f5TT
Volume in
L/Min. Total Volume
2.4 bb' n 10
Ore Storage 1 -i •/&-I/O 0 100 60 40 2.4 E 6
2.4 E" 6 Sample Plant jt1ij>-60 40
SAG Mill NA 60 40 24E6
Leach lUs~r 60 40 24E6
CCD )0H( It M 60 40 24E6
10 SX South/Stripping Section III 0 60 40 2.4 E 6
11 SX North /Control Room 07 u V 60 40 2.4 E 6
12 YC Precip win 60 40 2.4 E 6
12A North Dryer NA 60 40 2.4 E 6
12B South Dryer mi th QQ 17 QO 60 40 24E6
BA13 Pkg Area. 60 40 2.4 E 6
BA13A Pkg Enclosure 60 40 24E6
14 Packaged YC Storage '3 >(> 60 40 2.4 E 6
15 Bucking Room Jb3o 60 40 2.4 E 6
16 Lunch Room/Training Room # „ ^ LUS2. 60 40 2.4 E 6
17 Change Room l-"3-| s C~0 60 40 2.4 E 6
18 AdministratiomBuilding /Mo 60 40 2.4 E 6
19 Warehouse 60 40 2.4 E 6
20 Maintenance Shop 60 40 24E6
21 Boiler' IU3 60 40 2.4 E 6
22 Vanadium Control Panel NA 60 40 2.4 E 6
22A Vandium Drying NA 60 40 24E6
23 Vanadium Filter Belt NA 60 40 24 E6
24 Tails 60 40 2.4 E 6
25 Central Control Room 60 40 2.4 E 6
26 Shifter's Office NA 60 40 2.4 E 6
27 Operator's Lunchroom NA 60 40 2.4 E 6
28 CaF2 Dump Station 60 40 2.4 E 6
29 Emergency Generator Station •V3--S' \h IS 60 40 24E6
30 Truck Shop i- x-' ^ 60 40 2.4 E 6
31 Women's Locker Room 0 ^„K-60 40 24E6
Oxidation NA 60 40 2.4 E 6
33A AF South Pad \OH\ "(<r. 60 40 24 E6
vi :<A oJV ir 'on I / AM
0
Breathing Zone IBB
Mr Sampling
BREATHING ZONE PUMP CALIBRATION FORM
CALIBRATE AT 4 LITERS PER MINUTE
PUMP# DATE
READING l._
READING 2.
READING 3..
AVERAGE
TEMPERATURE
PURPOSE OF BREATHING ZONE
RADIATION/SAFETY TECHNICIAN
NAME OF EMPLOYEE WEARING SAMPLE
COMMENTS
BREATHING ZONE PUMP CALIBRATION FORM
CALIBRATE AT 4 LITERS PER MINUTE
PUMP# DATE
READING l._
READING 2.
READING 3._
AVERAGE
TEMPERATURE
PURPOSE OF BREATHING ZONE
RADIATION/SAFETY TECHNICIAN
NAME OF EMPLOYEE WEARING SAMPLE
BREATHING ZONE #:
COMMENTS
Month February-15
Breathing Zone Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BZ1 KOI I DUMI'KR 02/02/15 131 5 24E+05 WP RWP H2<i
BZ2 alternate Iced 02/04/15 133 5 32E+05 DT KWP 1326
BZ3 South Divci 02/07/15 26 1 04E+05 AM RWP 1327
BZ4 YC Pkg 02/10/15 179 7 16E+05 JP Weekly YC Packaging - CD PAPR Wom
BZ5 YC Pkg 02/11/15 107 4 28E+05 DT YC Packaging - CD in Ihe morning PAPR wom
Reviewed bv
Air Particulate Calculations Summary Sheet
Count
Date/Time 1'ilter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot.-Bkg )
LLD
(uCi/mL)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted Bv
02/03/15 BZ1 2929 19.30% 168 16 8 13.37 3 43 2 52E-1 1 53 E-0 00% IP
02/05/15 BZ2 2200 20 14% 1525 152.5 20 07 132 43 2 89E-I 5 57E-10 2530 18% JP
02/08/15 BZ3 2200 20 14% 130 13 20 07 0.00 1.48E-10 0 00E+00 0 00% DT
02/11/15 BZ4 2929 19 30% 22742 2274 13 37 2260 83 1 85E-1 1 7 37E-09 33499.55% DT
02/12/15 BZ5 2929 19 30% 21161 2116 13 37 2102 73 3.09E-11 1 15E-08 52122.33% Df
Micentration ( uO/cc) (Net CPM)
E6)(V)(Eff.d)
LLD or MDA 2 71 + 3 29 V Bkg *Ts(l+Ts/Th)
(Ts)(Eff d)(Eff. f)(V)(2 22E6)
1 s-
Th--
Eff d==
Eff f-
V=
2.22E6 =
Net CPM -
Time of Sample
Background Count Time in Minutes
Detector efficiency in Counts per Disintegration
Filter Efficeincy
Total Volume in millilitres of Cubic centimeters
Factor to convert DPM to uCi
Total Counts - Background Count
Percent of DAC Actual Concentration
DAC
Month February-15
Dreaming />one sampling rieia aneei
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
_Bv_ Comments
BZG V( Pkging 02/11/15 57 2 28E+05 CM YC Packaging - CD in ihe allcnioon PAPR wom
BZ7 YC Pkging 02/12/15 105 4 20E+05 DT YC Packaging PAPR wom BY CHUCK DAYISII
BZ8 LAB 02/13/15 243 9.72E+05 IP QUARTERLY BZ
BZ9 S D AUGI-.R 02/13/15 5.20E+04 IP RWP 132X
BZ10 S D AUGL:R 02/16/15 30 1 20E+05 RWP I32X
Reviewed by
Air Particulate Calculations Summary Sheet
Count
Date/Time Filter ID
Instrument
Serial No Efficiency
Total
Count/Time CPM
Bkg
Count/Time
Net Count
(Tot-Bkg )
LLD
(uCi/mL)
Concentration
u(V mL
Percent of
DAC
Sample
Counted Bv
02/12/15 BZ6 2200 20 14% 1767 176 7 20 07 156 63 6 75E-11 1.54E-09 6982 57% DT
02/13/15 BZ7 200 20.14% 54042 5404 2 20 07 5384 13 3 66E-11 2 87E-08 130296.33%
02/14/15 BZ8 2200 20 14% 9 1 20 07 0 00 1 58E-11 0.O0E+00 0 00"/,, .IP
02/14/15 BZ9 2929 19 30% 19 1 13 37 5 73 2 54E-10 2 57E-10 1169 73%
02/17/15 BZ10 2200 20 14% 182 18.2 20 07 0 00 1 28E-10 0 00E+00 0 00% JP
Concentration ( uCi/cc) (Net CPM)
(2 22 E6)(V)(Eff d)
LLD or MDA -- 2 71+3 29 V Bkg *Ts( 1 i-Ts/Tb)
(Ts)(Eff. d)(Eff f)(V)(2 22E6)
Ts=
Eff. d-
Eff f~
V^
2 22E6
Net CPM
Time of Sample
Background Count Time in Minutes
Detector efficiency in Counts per Disintegration
Filler Efficeincy
Total Volume in milhhtres of Cubic centimeters
Factor to convert DPM lo uCi
Total Counts - Background Count
Percent of DAC^ Actual Concentration
DAC
Month February-15
Breathing Zone Sampling Field Sheet
Energy Fuels Resources (USA) Inc. White Mesa Mill
Sampled By: Radiation Department
Filter
ID
Location Date Run Time
(Min.)
Flow Rate
(LPM)
Volume
(mL)
Sampled
Bv Comments
BZ11 YC 02/17/15 20 8.00E+04 JP RWP M2Q
AF 02/20/15 258 1.03E+06 WP KOH Start Up
BZ13 AK 02/20/15 257 1.03E+06 WP KOH Dumping
BZ14 South Drvei 02/16/15 60 40 2.40EH)6 JP Resample of Monthly Area Airborne
BZ15 0 00E+00
Reviewed by
Air Particulate Calculations Summary Sheet (An
Count
Date/Time Filter ID
Instrument
Serial No. Efficiency
Total
Count/Time CPM
Bkg.
Count/Time
Net Count
(Tot.-Bkg.)
LLD
(uCi/mL)
Concentration
uCi/ mL
Percent of
DAC
Sample
Counted Bv
02/18/15 BZ11 2929 19.30% 3593 359 3 13 37 345.93 1.65E-10 1.01E-08 45876.03% JP
02/21/15 BZ12 2200 20.14% 166 16.6 20.07 0.00 I 49 E-11 0 00E+00 0.00% JP
02/21/15 BZ13 2929 19.30% 292 29.2 13 37 15 83 1.29E-1 3.59E-11 59.91% JP
02/19/15 BZ14 2929 19 30% 6069 606 9 13 37 593 53 5 51E-12 5 77E-10 2623.72% JP
BZ15 20.14% 20.07 0.00 #DlV/0' frDIV/0' #DIV/0'
'""incentration ( uO/cc) (Net CPM)
(2 22 E6)(V)(ElTd)
LLD or MDA = 2 71+3.29 V Bkg *Ts(l H's/Tb)
(Ts)(EIT d)(Eff f)(V)(2 22E6)
Time of Sample
Ts= Background Count Time in Minutes
Tb^ Detector efficiency in Counts per Disintegration
Eff d= Filter Efficeincy
Eff f =• Total Volume in millilitrcs of Cubic centimeters
V= Factor to convert DPM to uCi
2.22E6 - Total Counts - Background Count
Net CPM ~
Percent of DAC Actual Concentration
DAC