DRC-2016-010901 - 0901a0688067bb89

State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

October 27, 2016

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-SSS
Radioactive Material License Number UT 1900479

Dear Ms. Weinel:
On October 17, 2016 and October 18, 2016, a representative of the Division of Waste Management and
Radiation Control inspected the White Mesa Uranium Mill. Observations from the inspection were
discussed at the closeout meeting with the Mill staff. The inspection was an examination of the
activities conducted at the Mill as they relate to compliance with the Utah Radiation Control Rules, the license conditions of RML No. UT1900479 and federal regulations. The inspection consisted of an
examination of representative records, interviews of personnel and observations by the inspector.

Enclosed is the inspection report for your review. The Division considers this inspection closed. The
Division would like to thank the Mill staff for their cooperation during this inspection.
If you have any questions, please call Ryan Johnson at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control
(Over)
DRC-2016-010901 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
STA/ RMJ/ka

Enclosure: Health Physics Inspection RADMOD-SSS Inspection Reports
c: Rick Meyer, Environmental Health Director, San Juan County Health Department

INSPECTION REPORT
Inspection Module: RADMOD-SSS: Surveys, Sources and Security
Inspection Location: Energy Fuels-White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiological release surveys, Check Sources and Facility Security
Inspection Dates: October 17 &18, 2016
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted:
David Turk, Energy Fuels Resources Radiation Safety Officer (RSO)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
David Turk (RSO)
UtahDWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The main portion of the Mill was in operation during this inspection processing
natural ore and Dawn Mining alternate feed. The Mill staff reminded the inspectors ofthe safety
requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 7/21 /17
Contamination Ludlum 2360 245764 9/7117
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Inspection Summary
The inspection consisted of a RSO interview, reviewing documentation and a mill tour. The following
discussion provides more detail ofthe specific items reviewed.
Item 1. Radiological Surveys
Due to the lack of radiologic surveying activity at the Mill during the inspection, the inspector was unable
to observe the Mill's radiation staff perform any radiological release surveys. Therefore, the inspection
focused on the documentation of radiological release surveys.
Observations: The DWMRC inspector observed:
• The Intermodal Container Unrestricted surveys documented:
o The Mill uses the release criteria( for NRC Regulatory Guide 1.86;
o Used the Mill's release limits 0.2 mR/hr @ I cmand 1.0 mR/hr max for Ply readings;
o The survey forms were complete and legible;
o Appropriate units were used;
o Total Alpha were below release criteria;
o Total p!y readings ranged between 0.05 to 0.15 mR/hr and included background;
o Meter information such as efficiency, calibration, background was recorded on each form;
and
o The survey included 30 locations inside and outside the container.
• The Equipment Unrestricted surveys documented:
o The Mill uses the release criteria( for NRC Regulatory Guide 1.86;
o Used the Mill's release limits 0.2 mR/hr @ I cmand 1.0 mR/hr max for p!y readings;
o The survey forms were complete and legible;
o Appropriate units were used;
o Total Alpha were below release criteria;
o Total ply readings were below release criteria; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• The Ore truck restricted surveys documented:
o The Mill uses the release criteria( for NRC Regulatory Guide 1.86 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr @ 1 cmand 1.0 mR/hr max for Ply readings;
o The survey forms were complete and legible;
o Appropriate units were used;
o Total Alpha were below release criteria;
o Total ply readings were below release criteria; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• The Yellowcake (Product) surveys documented:
o The Mill uses the release criteria( for NRC Regulatory Guide 1.86 for the drums;
o The Mill uses U.S. Department for Transportation criteria found in 49 CFR 173.441(b)(l);
o The survey forms were complete and legible;
o Appropriate units were used;
o Removable Alpha was taken on 25 percent of the drums and below release criteria
o Total Alpha were below release criteria;
o Total p!y readings were below release criteria;
o Meter information such as efficiency, calibration, background was recorded on each form;
and
o In the comment section of each survey it is noted that the transport trailers were surveyed
prior to loading.
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Deficiencies: None
Item 2. Calibration Sources
Observations: The DWMRC inspector observed:
• The check sources are exempt sources;
• The check sources are kept in a locked safe in the rad tech office;
• Checked sources are checked out and checked in using a checkout form; and
• The inventory list of the check sources is kept up-to-date as an attachment to the Mill's Radiation
Safety plan.
Deficiencies: None
Item 3. Site Security
Observations: The DWMRC inspector observed:
• Perimeter gates are closed and locked except for when they are being used;
• The Mill has a 24-hr surveillance system, with cameras scattered throughout the Mill; and
• The RSO maintains control of the keys to the Yellowcake storage area and gives it to his designee
when he is not at the Mill.
Deficiencies: None
Item 4. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the tailing cells and solvent the extraction building.
Observations: The DWMRC inspector also observed:
• Ore (both alternate feed and conventional ore) being stockpiled on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE including respirators in posted areas; and
R d' I a 10 og1ca rea d' b mgs o serve dd . M 'll unng I
Location
Ore Pad
Mill
Solvent Extraction Building
Yellowcake storage area
Deficiencies: None
Closeout Meeting
Energy Fuels:
David Turk (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Findings
None
tour
Dose Rate (J..LRihr)
1,00
I 00-300
100-150
150
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Recommendations
Document that the cabs of the ore trucks are being surveyed.
Recommendation for Next Inspection
I. Spills (yellowcake and other materials) being cleaned up in the mill immediately;
2. Personnel Exit Monitoring;
Prepared By: Ryan Johnson
(Print Name)
Reviewed By: Phil Goble
(Print Name)
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