DRC-2017-001044 - 0901a068806adccb

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State of Utah
GARYR. HERBERT
Gwernor
SPENCERJ. COX
Lieuternnt Governor
Department of
Environmental Quality
Alan Matheson
Exzcutive Director
DIVISION OF WASTE MANAGEMENT
AND RADTATION CONTROL
Scott T. Anderson
Director
February 22,2017
Kathy Weinel
Quallty Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Unon Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-RPP and Follow-up on KOH Spill Incident
Radioactive Material License Number UT 1900479
DearMs. Weinel:
On January 25 and26,2017, an inspection was conducted at your facility by a representative of the
Division of Waste Management and Radiation Control. Observations from the inspection were
discussed at the closeout meeting with White Mesa Uranium Mill staff. The inspection was an
examination of the activities conducted at the facility as they relate to compliance with the Utah
Radiation Control Rules, the license conditions of the Radioactive Material License No. UT 1900479
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.
However, the Division has recommendations for you to consider, which are discussed in the inspection
report.
Ifyou have any questions, please call Ryan Johnson at (801) 536'4255.
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
195 North 1950 West ' Salt Lake City, UT
Mailing Address: P.O. Box 1,14880 ' Salt Lake City, UT 84114-4880
Telephone [phone]'Fax [phone] 'T.D.D. [phone]
uww.ileq.utah.goo
Printed on l00o/o recYcled PaPer
DRC-20174010,14
(Over)
STA/ RMJ/ka
Enclosure: REDMOD-RPP: Respiratory Protection Program Inspection Report
c: Rick Meyer, Acting, Health Officer/Environmental Health Director, San Juan Public Health
Scott Hacking, P.E., DEQ District Engineer
Inspection Module:
Inspection Location:
Inspection ltems:
lnspection Dates:
Inspectors:
Personnel Contacted:
INSPECTION REPORT
RADMOD-RPP: Respiratory Protection Program
Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Respirator Protection
January 25 &26,2017
Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Tim Butler, DWMRC
David Turk, Energy Fuels Resources Radiation Safety Officer (RSO)
Governing Documents:o UAC R3l3-15o Radioactive Materials License (RML) UT1900479. Applicable Mill procedures and manualso NRC Regulatory Guide 8.15
Openine Meetins
Energy Fuels Resources:
David Turk, RSO
Utah DWMRC:
Ryan Johnson (Health Physics lnspector)
Tim Butler (RAM Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. Tim Butler conducted a general license inspection on the Mill's fixed nuclear
gauges. The main portion of the Mill was not in operation during this inspection. However, the alternate
feed circuit was processing KOH feed material. The Mill staff reminded the inspectors of the safety
requirements for the Mill.
Inspection Summarv-he inrpection consisted of a RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items reviewed'
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DRC Meters Used Model SerialNumber Calibration Due Date
Dose Rate Ludlum l9 101673 7 tzt/17
Item l. Documentation Review: The Inspector reviewed applicable documentation.
observations: The DWMRC inspector reviewed the foilowing documents:o The current Respiratory Protection Manual and confirmed all required respirator protection
procedures are covered in the manuallo The respirator issuance log;o Respirator Damage Sheet;o Medical clearance, fit testing and respirator training documentation; ande Respirator survey forms.
Deficiencies: None
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the alternate feed circuit and the respirator rJom.
Observations: The DWMRC inspector also observed:o Alternate feed being stockpiled on the ore pad;o OSL badges were appropriately being used by all observed employees at the Mill;o Respirator room was clean and well organized;o Respirators were clean and in good repair;o Fit testing of respirators was performed appropriately; ando Respirator issuance to Mill personnel is performed appropriately.
Deficiencies: None
Item 3. other: f,'ollow-up on Leaking Alternate Feed (KoH) shipment
Observations: The DWMRC inspector followed up on a leaking alternate feed shipment from HoneywellMetropolis Works Facility (Honeywell) that was reported to the bWMRC on January 12,2017. Theinspector was able to inspect the drums that were reported to have leaked. The inspector noticed that thedrums had been used before and still had the old labels attached to the drums. These labels indicate thatthey once contained green salts (CaFz) material. The inspector also observed that all of the drums wereshowing signs of corrosion on the bottom and two of the 55 drums in this shipment were transported inoverpacks' During discussions with the Mill's RSO, he indicated that Honeywellasked that the Millreweigh the leaking drums. The drums were heavier than the original tare weight. The inspector asked forthe Mill's laboratory analysis of the KOH material. The laboratory information from the Mill documentsthat material is mainly uranium with progeny and a small amount of Thorium-232.
The lnspector contacted Honeywell and following information was obtained and/or confirmed:o The route of the shipment: From Honeywell, Hwy45 to Hwysl(purchase pkwy) into TN to ll55 toI55 south to l40w thru AR" OK, TX, into NM & in Gallup, NM take Hwy49l to Hwy64 into AZ toHwyl60 to Hwyl9l into UT to BlandinglEnergy Fuels.o The originaltare weight was established when the drums were filled (201l). Honeywell,s
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read observed d Milltour
Location Dose Rate (pR/hr)
Ore Pad s00
Mitl 150 to 200
Gate at the Product Storage Yard 70
assumption was based on the data received from EFRI and the visible contamination, is that the
drums took on some amount of moisture/water, thus contributing to the extra weight.
Honeywell does re-use drums at the facility, and it is evident that in this case the old label was not
properly removed or defaced.
These particular drums were in storage since 201 1.
While at Honeywell some of the drums were stored inside and some were stored outside on
concrete surface.
Honeywell conducts a visual inspection of the drums prior to shipping. Drums are over-packed
prior to shipment based on the results of the visual inspection, These drums were deemed
acceptable when loaded. Pictures of the load, as well as inspection of the loading area, showed no
signs of leakage.
Honeywell notified the National Response Center and their regionalNRC office (Region II).
Deficiencies:
EFRI
Contrary to Utah Administrative Code (UAC) R313-15-501 an appropriate radiological survey was not
conducted by EFRI on the transport truck prior to it being decontaminated to document:
. The magnitude and the extent of radiation levels; and
o Concentrations or quantities of residual radioactive material; and
r The potential radiological hazards ofthe radiation levels and residual radioactivity detected.
During discussions with the RSO, the Inspector determined that a radiological survey of the truck was not
done prior to the truck being decontaminated. According to the RSO, he was contacted by the "Utility
Crewi' about the shipment but he wasn't told the nature of problem. When investigating the truck the RSO
began to document the leaking shipment by taking photographs of the leakage with his cell phone. When
he went back to the Mill's administration building to get the appropriate radiological survey equipment the
"Utility Crew" sent the truck to the decontamination pad. Therefore, the truck was not surveyed prior to
deconiamination. The truck was surveyed after decontamination and prior to being released from the Mill's
restricted area. Since a pre-decontamination survey was not completed, an accurate radiological assessment
cannot be done on KOH spill incident.
Honeywell
Contrary to 49 CFR 173.428(a\(6)(ii) and l0 CFR 71.43(f) as incorporated by reference in UAC R313-19-
100, Honeywell shipped LSA I Class 7 radioactive material (KOH alternate feed material) in packaging
and/or conveyance that did not prevent the loss of radioactive material under "normal conditions of
transport". The DWMRC passed all information regarding this leaking shipment to other Agreement State
and Federal agencies for any enforcement action. The State of Utah does not have jurisdictionalauthority
to cite Honeywell for the incident.
Closeout Meetine
Energy Fuels:
David Turk (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Tim Butler (RAM InsPector)
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o
a
Findinss
The Inspector discussed with the RSO the need to do surveys on leaking shipments prior to
decontamination. The lnspector recommended training for the Mill's personnel. The training is to cover
the need to perform a radiological survey on containers and transport vehicles when a leaking shipment
arrives and not to decontaminate the containers and vehicles until the surveys are done. The DWMRC
recommended that additionalffaining be performed. The RSO notified the DWMRC by email on January
26,2017 that this additional training was conducted earlier that dat.
Recommendations
After discussing the findings of the inspection with DWMRC Management, it is recommended that EFRI's
procedure is modified to include:l. Incoming radiological surveys are performed on all incoming alternate feed, equivalent feed,
yellowcake and l1e.(2) shipments; and2. Annual training on the need for these surveys to be performed and documented.
Recommendation for Next Insnectionl. Spills (yellowcake and other materials) being cleaned up at the mill2. Personnel Exit Monitoring;
Prepared By:
Reviewed By:
Ryan Johnson 2^?-2./7
(Date) /(Print Name)
PhilGoble
(Print Name)(Signature)
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(Date)