DRC-2015-002729 - 0901a068805375db

DIVISION Ol RADIATION CONTROL
Rusty Lundberg
Direcior
Department of
Environmental Quality
Alan Matheson
Acting Executive Director
GARYR HERBERT
Governor
SPENCERJ COX
Lieutenant Governor
June 1,2015 DRC-2015-002729
Kathy Weinel
Quality Assurance Manager
Energy Kuels 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 ofthe 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/BMl:bi
Enclosure
cc/enc: David Turk, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City, 111
Mailing Address: P.O.Box 144850 • Salt Lake City. L'T 84114-4850
Telephone [phone] • Fax [phone] • T D D [phone]
www deq utah gov
Pnnted 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 lmai, DRC
Personnel Contacted: Dan Hillsten, David Lacy. Abel Mendoza. Garren Palmer. Justin Perkins.
Terry Sladc, 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. lmai.
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 lmai held an exit meeting on May 20. 2015 with D. I lillsten. 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.
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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
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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 wom 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 ofthe 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
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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. lmai 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.
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Recommendation for rhe 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 ofthe worker
temporarily wearing another individual's dosimeter and it'so, how was it resolved.
• Delete Item No. 26 from the checklist. It is redundant and can be contusing. 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. lmai
(Name)
28, 2015
(Date)
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