DRC-2012-002923 - 0901a0688035c97d

UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-PEM-01 Revl
SURVEYS/POSTlNGS/EXrr MONITORING
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
DRC^20l2-002923
References:
Radioactive Material License UTl900479
License Renewal Application dated Febmary 28, 2007
Radiation Protection Manual, Appendix E, Sections 1 and 2
ALARA Program Manual, Appendix I, Section 2
10CFR20
Utah Administrative Code R313-15
49CFR173
Date of Inspection: November 15-16. 2012 Inspector(s) Kevin Camev
EXIT SURVEYS
Radiation Protection Manual Section 1.2.1, Restricted Area, states "All personnel who enter the
Restricted Area will monitor themselves each time they leave the Restricted Area and at the end of their
shift. The Radiation Safety Department will review the monitoring information. All personnel exiting
the Restricted Area must initial a record of their monitoring activity."
1) Did all employees observed monitor themselves in accordance with the Radiation Protection Manual
Section 1.2.1 upon exit from the Restricted Area?
Yes 13 No •
Comments: Observed personnel monitoring at the Lab. West Door and Guard Shack Restricted Area
exits.
Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to
perform proper personnel monitoring.
2) Section 1.2.3 step 1.
Were all exit monitor (count rate meter) alarms adjusted within the range of 500 to 750 dpm/lOOcm^?
(Note: Because the Ludlum Model 177 reads out in counts per minute, ensure proper calculations
were used to achieve a 500 to 750 dpm/lOOcm^ range).
Yes 13 No •
Comments:
3) Section 1.2.3 step 2.
Did all observed personnel exiting the Restricted Area slowly survey their hands, clothing and shoes,
including the shoe bottoms, at a distance from the surface of approximately VA inch?
Yes 13 No •
Comments:
4) Section 1.2.3 step 6.
Has the licensee provided documentation of individual (exit) surveys being logged and initialed?
Yes 13 No •
Comments: Personnel logs at the exits were properly maintained.
ROUTINE SURVEYS
The Mill's Radiation Protection Manual, Appendix E, Section 2.3 requires the licensee to perform alpha
surveys, both fixed and removable, at regular intervals in particular areas of the Mill. Table 2.3.2-1 lists
the areas to be surveyed. Section 2.3.2 requires the listed areas to be surveyed on a weekly basis during
production periods. During non-production periods, only those areas designated by the RSO as
authorized lunchroom/break areas are monitored.
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Lunch Tables
Maintenance Lunchroom Tables
Mill Office Lunchroom Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
5) For the period including the last three (3) months, on what dates was the Mill considered in
"production periods" and in "non-production periods"?
^ 1st Month 2nd Month 3rd Month
Production Periods August 2012 September 2012 October 2012
Non-Production Periods N/A N/A N/A
Comments: There were short intermptions in production in the above period. However, the Mill
conducted compliance items as if the Mill was in full time production.
6) During production periods, were all areas listed in Table 2.3.2-1 surveyed for removable alpha as per
Section 2.3.2?
Yes 13 No •
Comments: Maintenance Lunchroom Tables desienation needs to be clearly defined on maps.
7) During production periods, were all areas listed in Table 2.3.2-1 surveyed for fixed alpha as per
Section 2.3.2?
Yes 13 No •
Comments:
8) During non-production periods, were all areas designated by the RSO as authorized lunchroom/break
areas surveyed for removable alpha as per Section 2.3.2?
Yes • No • N/A |3
Comments:
9) During non-production periods, were all areas designated by the RSO as authorized lunchroom/break
areas surveyed for fixed alpha as per Section 2.3.2?
Yes • No • N/A |3
Comments:
The Mill's ALARA Program, Section 2.3.1, requires the RSO or designee to perform daily inspections
throughout the Mill and document the results on the Daily Mill Inspection form. Section 2.3.2 requires
the RSO and Shift Foreman or designees to perform weekly inspections throughout the Mill and
document the results on the Weekly Mill Inspection form.
Inspector shall review inspection documents for the period including the last three (3) months.
10) Has the licensee performed the daily Mill Inspections in accordance with Section 2.3.1?
Yes 13 No •
Comments: All daily records found in log for the previous three months.
11) Were the forms completed to satisfy the requirements of Section 2.3.1?
Comments:
Yes 13 No •
12) Has the licensee performed the weekly Mill Inspections in accordance with Section 2.3.2?
Yes 13 No •
Comments: All weekly records found in log for the previous three months.
13) Were the forms completed to satisfy the requirements of Section 2.3.2?
Yes 13 No •
Comments: l
RADIOLOGICAL POSTINGS
License Condition 9.9 states: The licensee is hereby exempted from the requirements of R313-15-902(5)
for areas within the mill, provided that all entrances to the mill are conspicuously posted in accordance
with R313-15-902(5) and with the words, "Any area within this mill may contain radioactive material".
14) Has the licensee conspicuously posted all entrances to the mill in accordance with R313-15-902(5)
and with the words, "Any area within this mill may contain radioactive material"?
Yes 13 No •
Comments: All observed entrances were properly posted.
Utah Administrative Code R313-15-902(1) requires that the licensee post each radiation area with a
conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIATION
AREA."
10CFR20.1003 defines a Radiation Areas as an area, accessible to individuals, in which radiation levels
could result in an individual receiving a dose equivalent in excess of 0.005 rem (0.05 mSv) in 1 hour at
30 centimeters from the radiation source or from any surface that the radiation penetrates.
15) Were all radiation areas posted in accordance with R313-15-902(1)?
Yes 13 No •
Comments: No un-posted areas > 5 mrem/hr were found.
16) Were all posted Radiation Area boundaries found to be < 5mrem/hr?
Yes 13 No •
Comments: Confirmed using Microrem S/N B288K cal due 6/20/2013
As required by Utah Administrative Code R313-15-902(4), the licensee or registrant shall post each
airborne radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words
"CAUTION, AIRBORNE RADIOACTIVITY AREA" or "DANGER, AIRBORNE RADIOACTIVITY
AREA."
17) Has the licensee employed the proper postings for Airborne Radioactivity Areas in accordance with
R313-15-902(4)?
Yes • No 13
Comments: Lower approach to SAG mill area not adequately posted: blue and white safety sign
stating that respirators were required.
18) Were all radiological postings observed found to be legible, conspicuously posted and unobstmcted?
Yes • No 13
Comments: Above mentioned SAG Mill area sign was not conspicuously posted. It was well off to the
left side and approximately 8-10 feet off the floor.
Additional Observations and Findings:
Comments: Survey map issues to be corrected - no violation recommended.
The exit monitors at the West Door and Lab Exit had probes with identical serial numbers. Lab Exit
meter was immediately removed from service and calibration documents verified by the inspector. Probe
will be re-numbered and the meter re-calibrated.
A violation is recommended for the SAG Mill posting.
UTAH DIVISION OF RADIATION CONTROL
Inspection Module PEM-01
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radioactive Materials License UTl900479
CLOSEOUT MEETING
Inspector(s) Kevin Camey
Date(s): November 16, 7017
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Ron Nieves Energy Fuels 435-678-2221
Teny Slade Energy Fuels 435-678-2221
Kevin Camey UDRC 801-536-4250 .
Dave Turk Energy Fuels 435-678-2221
-
UTAH DIVISION OF RADIATION CONTROL
Inspection Module PEM-01
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radioactive Materials License UT1900479
CLOSEOUT MEETING
DISCUSSION of FINDINGS
Tt was conveyed to the Mill staff that most ofthe items inspected were compliant. Tt was noted that there were
minor discrepancies - typos - on some ofthe routine inspection forms, and that the area known as
"Maintenance Lunchroom Tables" was not clearly identified on the Mill's routine survey maps. Tt was also
noted that the inspector found two exit monitors that had the same serial numbered probe Finally, the inspector
discussed that the posting at the lower approach to the SAG Mill designating the Airborne Radioactivity Area
was non-compliant and that, because ofthe hazard potential to personnel, an NOV would he generated.
SITE STAFF COMMENTS
The Mill's RSO and Manager. Environmental. Health and Safety informed the inspector that the paperwork
typo would he corrected and that the survey maps would be updated to clearly identify the "Maintenance
Lunchroom Tables" area. The RSO explained that several ofthe exit monitor alpha probes' serial numbers had
been worn off due to wear. This had been noted on a previous inspection. Subsequent to that inspection, the
probes in question were re-serial numbered via hand numbering the probes. The hand numbered probe found by
the inspector was mistakenly misnumbered. However, the RSO produced the calibration form to show that the
probe was calibrated with the instmment. The instmment was immediately taken out of service to he sent out
for re-calibration and to have the probe properly numbered. The RSO stated that he would review
documentation for all the radiological instmments to ensure there were no more misnumbered probes in use.
The Mill Staff agreed that the SAG Mill area sign was non-compliant.
UTAH DIVISION OF RADIATION CONTROL
Inspection Module PEM-01
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radioactive Materials License UT1900479
OPENING MEETING
Inspector(s) Kevin Camey
Date(s): November IS 7017
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Ron Nieves Energy Fuels 435-678-2221
Terry Slade Energy Fuels 435-678-2221
Kevin Camey UDRC 801-536-4250
UTAH DIVISION OF RADIATION CONTROL
Inspection Module PEM-01
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radioactive Materials License UT1900479
OPENING MEETING
DISCUSSION
The Inspector informed the Mill Staff of the scope of the inspection. The Inspector reqnested access into the
Restricted Area ofthe site and requested documentation to review for the purposes of completing the
inspection
SITE STAFF COMMENTS
The Mill Staff communicated that the Inspector would have access to any records requested and offered a tour
inside the Mill's Restricted Area. ^
INSPECTION REPORT
hispection Module: RADMOD-PEM-01
"A
Inspection Location: White Mesa Mill, Blanding, Utah
Inspection Items: Exit Surveys, Routine Surveys and Radiological Postings
Inspection Dates: November 15-16,2012
Inspector: Kevin Camey, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk, Ronnie Nieves and Terry Slade
Goveming Documents:
Radioactive Material License UTl900479
License Renewal Application dated Febmary 28, 2007
Radiation Protection Manual, Appendix E, Sections 1 and 2
ALARA Program Manual, Appendix I, Section 2
10CFR20
Utah Administrative Code R313 -15 (
49CFR173.
Opening Meeting
The opening meeting was held in the Administration Building conference room at 08:30 a.m. on
November 15, 2012. Present were Ronnie Nieves and Terry Slade of Energy Fuels Resources and
Kevin Camey of the Utah Division of Radiation Control.
The inspector informed the Mill staff that there would be two inspections conducted and discussed
the items that would be included in the inspections (see Inspection Report for Module RPP-02). The
inspector also requested documentation necessary to aid in the inspections.
Inspection Summary
Inspection included document review of personnel exit monitoring logs, routine alpha survey results,
daily and weekly inspections, radiological postings and daily instrument checks. A walk-through
inspection of the facility included areas on the Mill's routine survey logs, verification of postings for
radiation areas, airbome radioactivity areas and radioactive material postings at mill entrances.
Observations of personnel performing exit monitoring at several Mill exit locations and verification
of survey instmment compliance were also included in the inspection.
1 of Page 5
Findings
• Mill Office Lunchroom location not clearly marked on routine maps
• Two different exit monitor probes with the same serial number
• Improper radiological posting at SAG Mill
Findings are discussed in detail below:
Inspection Items
Item 1 EXIT SURVEYS
During observations of personnel exit monitoring, all personnel observed were found to have
monitored properly. Observations were conducted at the Lab Exit, West Door and Guard Shack. All
monitoring logs were found to be properly maintained. Exit point rate meters were found to have
properly established alarm set-points. One discrepancy was noted. The probes for the Lab Exit and
West Door had the identical serial number. The West Door probe had the number on the original
manufacturer's label and the Lab Exit probe was hand written by the Mill staff. An inspection
conducted by the DRC on March 26,2008 noted that several alpha probes used at the Mill had no
serial number visible on the probe. This was mainly due to continuous handling of the probes by Mill
personnel at the exh monitoring points that eventually led to the numbers wearing off". The Mill staff
was asked to renumber these probes for calibration and tracking purposes. The Lab Exit probe
identified during the current inspection appears to have been misumbered by the Mill staff. However,
a check of the current calibration record shows that the probe was calibrated with the meter. The Mill
staff immediately removed this meter and probe fi-om service to be recalibrated and have the probe
renumbered. No violation was cited.
Deficiencies: None
Item 2 ROUTINE SURVEYS/RSO INSPECTIONS
The Mill was considered to be "in production" during the months of August, September and October
2012. The inspector reviewed weekly routine survey documentation for these past three months. The
surveys included areas that are listed in the Mill's Radiation Protection Manual Table 2.3.2-1.
Section 2.3.2 of the Mill's Radiation Protection Manual states: "Fixed and removable alpha surveys
are made at those general locations on the Table 2.3.2-1, "Alpha Area Survey Locations. " Surveys
are completed weekly during production periods. During non-production periods, only those areas
designated by the RSO as authorized lunchroom/breaks areas are monitored. " Table 2.3.2-1 is as
follows:
2 of Page 5
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Lunch Tables
Maintenance Lunchroom Tables
Mill Office Lunchroom Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
All survey records were found to be in order. The only concem was that the area listed in the Table
as, "Mill Office Lunchroom Tables" is not clearly defined on the Mill's routine survey maps. The
RSO agreed to update the maps to include a clear indication of where this area is located.
The inspector reviewed daily and weekly inspection reports. The Mill's ALARA Program, Section
2.3.1, requires the RSO or designee to perform daily inspections throughout the Mill and document
the results on the Daily Mill Inspection form. Section 2.3.2 requires the RSO and Shift Foreman or
designees to perform weekly inspections throughout the Mill and document the results on the
Weekly Mill Inspection form.
No problems other than minor typographical errors were identified. These errors were brought to the
RSO's attention.
Deficiencies: None
Item 3 RADIOLOGICAL POSTINGS
Utah Administrative Code R313-15-902( 1) requires that the licensee post each radiation area with a
conspicuous sign or signs bearing the radiation trefoil symbol and the words "CAUTION,
RADIATION AREA" and 10CFR20.1003 defines a Radiation Areas as an area, accessible to
individuals, in which radiation levels could result in an individual receiving a dose equivalent in
excess of 0.005 rem (0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from any
surface that the radiation penetrates.
The inspector performed a walk through inspection of the Mill and performed spot check gamma
radiation surveys to verify Radiation Area postings and boundaries using Bicron Microrem S/N
B288K (cal due 6/20/13). All Radiation Areas identified were found to be properly posted. No
unposted areas greater than 5mrem/hr were identified. The inspection also included verification of
Airbome Radioactivity Area postings and postings at the Mill entrances required by Utah Rule
R313-15-902(4) stating, "Any area in this mill may contain radioactive materials."
3 of Page 5
All observed gated entrances to the restricted area of the Mill site were posted in accordance with
Utah Rule R313-15-902(4).
Airbome Radioactivity Areas were appropriately posted at the Yellowcake Drying and Packaging
areas and the Alternate Feed Circuit dump stations. The SAG Mill had one non-compliant posting
(see below).
Deficiencies: The approach to the SAG Mill area of the facility from the lower level was improperly
posted. All other approaches to this area were appropriately posted with yellow and magenta
radiological signs which bore the radiation trefoil and the words, "Caution Airbome Radioactivity
Area." However, the nonconforming sign was a general safety sign that did not meet the
requirements of 10CFR20.1901 and 1902. The sign was not of the proper color scheme, did not
include the three bladed trefoil and did not include the words, "Caution Airbome Radioactivity
Area." The sign was located well to the left of a wide walkway (which is approximately 10 to 15 feet
wide) and suspended from piping approximately 8 to 10 feet above the floor level. The opinion of the
inspector is that this sign was not conspicuously posted. During the walkthrough of this area, the
inspector asked the RSO why the area was not posted. In fact, the inspector had walked past the sign
without seeing it. A Notice of Violation is recommended for this infraction.
Area approaching SAG Mill
4 of Page 5
Closeout Meeting
The closeout meeting was held in the Administration Building Training Room on November 16,
2012. Present were Dave Turk, Ronnie Nieves and Terry Slade of Energy Fuels Resources and Kevin
Camey of the Utah Division of Radiation Control. The inspector informed the Mill staff of the
results of the inspection performed and recommendations for improvement to the Mill's various
radiological safety programs. This inspector discussed the minor deficiencies identified pertaining to
survey documentation and instmmentation issues. The inspector also discussed the discrepancy
involving the improper posting at the SAG Mill area and that a Notice of Violation would be
recommended to DRC Supervision.
Conclusion and Recommendations
A Severity Level IV violation is defined by R313 -14-10 as, ''less serious [than Levels I, II or III] but
are of more than minor concern, however, if left uncorrected, they could lead to a more serious
concern.''''
Given that airbome concentrations are normally low in this area of the Mill, but that there is a
potential for a significant uptake should the situation arise, the inspector recommends a Severity
Level IV Notice of Violation with a base civil penalty of $750.00 be imposed for the improperly
posted area.
Recommendation for Next Inspection
1. Assure compliance wdth posting requirements
2. Assure instrument probes are correctly identified
3. Verify update of survey maps to include Maintenance Lunchroom Tables location
Prepared By: Kevin J Camey
(Print Name)
Reviewed By: Phillip Goble
(Print Name)
5 of Page 5
ENERGYFUELS
En
13RC-2013-00 n36
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600
Lakewood, CO. US, 80228
303 974 2140
www energyfuels com
VIA EMAIL AND OVERNIGHT DELIVERY
Janaury 17, 2013
Mr Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P O Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill - RML UT1900479
Notice of Violation ("NOV") DRC Inspection Module PEM-01
Dear Mr Lundberg
This letter responds to the above named NOV and Division of Radiation Control ("DRC") letter dated
December 17, 2012 regarding Posting of Radiation Areas at the White Mesa Mill (the "Mill") Energy
Fuels Resources (USA) Inc ("EFRI") paid the penalty of $750 specified in that letter and NOV on
January 3, 2013 This letter responds to DRC's letter of December 17, 2012 and January 7, 2013
requesting a written response
1. Facts and Background
a) UAC R313-15-902(4) states "Posting of Airbome Radioactivity Areas The licensee or
registrant shall post each airbome radioactivity area with a conspicuous sign or signs bearing
the radiation symbol and the words "CAUTION, AIRBORNE RADIOACTIVTY AREA or
"DANGER, AIRBORNE RADIOACTIVTY AREA "
b) R313-15 does not define the term "airbome radioactivity area" However, R313-15-901
requires that the radiation symbol and posting be applied as prescnbed by 10 CFR 20 1901
(2010) which defines "airbome radioactivity area"
c) Section 1 1 1 of the Mill's Approved Radiation Protection Manual ("RPM"), states
"For work where there is the potential to cause airbome radiation doses to site
personnel, the frequency and type of air sampling to be conducted is determined
from measured air concentrations
0 01 DAC-0 1 DAC Quarterly or monthly area or sampling and/or
bioassay measurements
Letter to Rusty Limdberg
January 17, 2013
Page 2 of 6
>0 1 DAC Continuous sampling is appropnate is concentrations
are likely to exceed 0 10 DAC averaged over 40
hours or longer
The Radiation Safety Officer ("RSO") will determine the exact firequency of area
air sampling, breathing zone sampling and/or bioassay measurements and determine
how many workers in a group of workers performing similar jobs are to be
equipped with breathing zone air samples."
d) Typically, Mill radiation personnel collect airbome particulate samples for alpha measurement
from each area at least monthly If the sampling indicates the area is above the Mill's ALARA
goal of 25% of the Derived Air Concentration ("0 25 DAC"), the sampling is repeated weekly
until the resuhs show the area is below 25% ofthe DAC (0 25 DAC)
e) The Mill's RSO determines whether Airbome Radiation Area Posting is required based on the
results of the area air sampling The area is posted whenever the airbome alpha concentration
reaches or exceeds 25% of DAC
f) The four area airbome filter samples taken on November 3, 2012 (two samples) and November
4, 2012 (two samples) and November 6, 2012 (one sample) indicated that the concentrations
were below 25% of the DAC, ranging fi-om 0 to a maximum of 18 35% of DAC (0 to 0 18
DAC) That is, per the approved RPM and per R313-15-902(4), no posting was required The
Monthly Area Airbome Sampling Field Sheet for November 2012, used to determine the
percentage of DAC and whether posting is required, is provided m Attachment 1
g) The SAG mill area has been determined to generate dust hazards whenever the SAG mill
equipment is operating It is the Mill policy to require the use of respirators whenever the SAG
mill is in operation, for compliance with Mine Safety and Health Act requirements for general
respiratory protection from airbome dust, whether or not the dust contains radioactive
constituents Since July of 2012, for conservatism, the Mill's RSO has adopted the practice of
leaving Airbome Radioactivity Signs in place at all times whether or not the airbome sampling
indicates an exceedance of 25% of DAC Although, per the RPM, the Airbome Radioactivity
Area signs are not specifically required whenever the airbome concentrations are less than
25% of DAC, as was the case on November 15 and 16, 2012,
(i) Due to the use of penodic grab samples for airbome radioactivity and DAC
determination, there is a potential that between grab samples, the airbome radioactivity
may vary, and
(ii) The signs provide an additional reminder for workers to wear respiratory protection from
dust hazards any time the SAG mill is in operation
h) On November 15 and 16, 2012, DRC personnel conducted Inspection Module PEM-01 at the
Mill
i) The SAG mill had operated for some penod on November 15, 2012, but was not in operation at
Letter to Rusty Limdberg
January 17, 2013
Page 3 of 6
the time of the DRC inspection
j) Dunng the November 15 and 16, 2012 mspection, DRC personnel questioned why there was
no radiation hazard sign at the lower entrance to the SAG Mill area A specific sign (the
"Respiratory Protection sign") reading "NOTICE RESPIRATORS AND HEARING
PROTECTION REQUIRED WHEN SAG MILL IS IN OPERATION" was posted
k) The Mill's RSO did not present to DRC the data, discussed earlier, which demonstrates that the
area was below 25% of the DAC and no airbome radiation hazard sign was required The
Mill's RSO did not explain the Mill's policy of leaving the Airbome Radioactivity Area signs
in place whether or not the airbome sampling indicated they were required The Mill's RSO
apparently did show the DRC personnel that some Airbome Radioactivity Area signs were in
place at other entrances to the SAG mill area, without explaining why.
I) As discussed above, it is the Mill's current policy to leave both the respiratory Protection Sign
and the Airbome Radiation Sign in place at all times EFRI agrees that although the Airbome
Radioactivity Area sign may not have been required at the time of the DRC inspection, it is
pmdent to have it posted at all the SAG mill entrance locations where the Respiratory
Protection signs are posted.
2. Corrective Steps Taken and Results Achieved
Despite the fact that the Airbome Radioactivity Area signs were not required, for consistency with the
other entrances to the SAG mill area, on November 15, 2012, Mill radiation safety personnel placed an
Airbome Radioactivity Sign at the area indicated by DRC The sign was attached by chains below the
existing heanng and respiratory protection sign to the side of the lower walkway into the SAG mill
area
A photograph showing the sign in place is provided in Attachment 2
Mr Philip Goble of DRC was present in the Mill on December 20, 2012, observed and photographed
the location of the additional sign, and concurred that the placement was sufficiently conspicuous to
comply with R313-15-902(4).
3. Corrective Steps to Prevent Recurrence
The Mill proposes, for conservatism, to leave the Airbome Radiation Area signs at the entrances to the
SAG mill area, including the lower entrance, in place at all times.
4. Date Full Compliance Will Be Achieved
As discussed above, the Mill was in compliance wdth R313-15 at the time of the inspection For
consistency with signage at other entrances to the Sag mill area, the Mill placed the sign at the lower
entrance to the SAG mill area on December 15, 2012
Letter to Rusty Limdberg
January 17,2013
Page 4 of 6
If you have any questions, please contact me at [phone]
Yours very tmly.
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc Kevin Camey, Utah DRC
David C Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Ronme Nieves
Harold R Roberts
David E Turk
Kathy Wemel
Attachments
Letter to Rusty Limdberg
January 17,2013
Page 5 of 6
ATTACHMENT 1
Area Airbome Concentration and Determination of DAC
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Letter to Rusty Lundberg
January 17, 2013
Page 6 of 6
ATTACHMENT 2
Photograph of Airbome Radioactivity Sign in Place
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ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
Control
January 3, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Dear Mr. Lundberg:
Re: Division of Radiation Control ("DRC") Inspection Module PEM-01, November 15, though
November 16, 2012, Notice of Violation and Imposition of Civil Penalty, Energy Fuels Resources
(USA) Inc., White Mesa Mill, Radioactive Material License UT190479
This letter is in response to your letter dated December 17, 2012 which Energy Fuels Resources (USA)
Inc. received on December 20, 2012 relating to the above-referenced matter.
Enclosed please find a check in the amount of $750.00 in payment of the imposed penalty for the
violation cited in the Notice of Violation dated December 17, 2012.
If you have any questions, please contact me at [phone].
Yours very tmly.
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Kathy Weinel
State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
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U.S. Postal ServicGin
CERTIFIED MAIL™ RECEIPT
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December 17, 2012 • ^ 2/17/12 Module PEM-01 - NOV / KC
CERTIFIED MAIL
RETURN RECEIPT REQUIRED
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600
Lakewood, Colorado 80228
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CO
HI
IT
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JO ANN TISCHLER
ENERGY FUELS RESOURCES (USA) INC
225 UNION BLVD , STE 600
LAKEWOOKCO 80228
PS Form 3»00. August 2006 Soe Reverse for Instructions
RE DRC Inspection Module PEM-01, November 15 through 16, 2012, Notice of Violation,
RML UT1900479, White Mesa Mill
Dear Ms Tischler, DRC-201^ 0U2648
On November 15 through 16, 2012, Inspection Module PEM-01 was coii .;:ted at your facility by
a representative of the Division of Radiation Control (DRC) of the Utah Department of
Environmental Quality Results of the inspection were discussed with Mill Management at the
conclusion of the inspection
The inspection was an examination of activities conducted at your facility as they relate to
compliance with the Utah Radiation Control Rules and the conditions of your Radioactive
Matenals License The mspection consisted of selective examinations of procedures and
representative records, interviews of personnel, independent measurements, and observations by
the inspector The inspection focused on the Mill's Radiation Protection Program as it relates to
Exit Surveys, Routine Surveys and Radiological Postings
It was noted that not all of your activities were conducted in compliance with State requirements
A Notice of Violation is enclosed. The particular violation is descnbed in the enclosed Notice
Please continue to remember that radiation safety is the responsibility of the licensee
Sincerely,
Rusty Lundberg, Director
RL/KJCkc
Enclosure
cc Ronnie Nieves, Mill RSO
195 North 1950 West • Salt Lake City, UT
Maihng Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
www deq Utah gov
Pnnted on 100% recycled paper
UTAH DEP^^MENT OF ENVIRONMENTAL ^ALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600 License Number UT1900479
Lakewood, Colorado 80228
STATUTORY AUTHORITY
This Notice of Violation and Proposed Imposition of Civil Penalty (NOV-PICP) is issued by the
Director of the Utah Division of Radiation Control (hereinafter the DIRECTOR) under the Utah
Radiation Control Act, as amended, Utah Code Ann Sections 19-3-101 to 19-3-113 (the Act),
including Utah Code Ann. Sections 19-3-103 5, 19-3-108, and 19-3-109 This NOV PICP is also
issued in accordance with the Utah Adrmnistrative Procedures Act, Utah Code Ann Sections
63G-4-101 through 63G-4-601. The DIRECTOR is authonzed to issue such NOVs in
accordance with § 19-3-108 ofthe Utah Code.
Dunng an inspection conducted by a representative of the Utah Division of Radiation Control
(DRC), on November 15 through 16, 2012, a violation of the White Mesa Mill Radiation
Protection Manual was identified The current procedures for radiation protection at the Mill are
those set forth in the February 28, 2007 License Renewal Application
Violations are pnontized according to Seventy Levels, with Seventy Level V being the least
significant The particular violation of the White Mesa Mill Radiation Protection Program is set
forth below
VIOLATIONS
Utah Administrative Code R313-15-901, Caution Signs, states*
(1) Standard Radiation Symbol. Unless othenuise authonzed by the Executive
Secretary, the symbol prescribed by lo CFR 20.1901 y (2010), which is incorporated
by reference, shall use the colors magenta, or purple, or black on yellow
background. The symbol prescribed is the three-bladed design as follows:
(a) Cross-hatched area is to be magenta, orpmple, or black, and
(b) The background is to be yellow.
(2) Exception to Color Requirements for Standard Radiation Symbol
Notiuithstanding the requirements of 10 CFR 201901(a), (2010), which is
incorporated by reference, licensees or registrants are authorized to label sources,
source holders, or device components containing sources of radiation that are
subjected to high temperatures, with conspicuously etched or stamped radiation
caution symbols and without a color requirement.
(3) Additional Information on Signs and Labels. In addition to the contents of
signs and labels prescribed in Rule R313-15, the licensee or registrant shall provide,
on or near the required signs and labels, additional information, as appropriate, to
make individuals aware of potential radiation exposures and to minimize the
exposures.
Page 1 of 4
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600 License Number UT1900479
Lakewood, Colorado 80228
Utah Administrative Code R313-15-902, Posting Requirements, states
(1) Posting of Radiation Areas. The licensee or registrant shall post each
radiation area with a conspicuous sign or signs bearing the radiation symbol and
the words "CAUTION, RADIATION AREA."
(2) Posting of High Radiation Areas. The licensee or registrant shall post each
high radiation area with a conspicuous sign or signs bearing the radiation symbol
and the words "CAUTION, HIGH RADIATION AREA " or "DANGER, HIGH
RADIATION AREA."
(3) Posting of Very High Radiation Areas. The licensee or registrant shall post
each very high radiation area with a conspicuous sign or signs bearing the
radiation symbol and words "GRAVE DANGER, VERY HIGH RADIATION AREA "
(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, AIRBORNERADIOACTFVITYAREA"
or "DANGER, AIRBORNE RADIOACTIVITY AREA "
(5) Posting of Areas or Rooms in which Licensed or Registered Material is Used
or Stored. The licensee or registrant shall post each area or room in which there is
used or stored an amount of licensed or registered material exceeding ten times the
quantity of such material specified in Appendix C of 10 CFR 20.1001 to 20.2402,
(2010), which is incorporated by reference, with a conspicuous sign or signs
bearing the radiation symbol and the words "CAUTION, RADIOACTFVE
MATERIAL" or "DANGER, RADIOACTIVE MATERIAL."
Dunng the inspection, it was found that the approach to the SAG Mill area of the facility from
the lower level was improperly posted The nonconforming sign was a general safety sign that
did not meet the requirements of R313-15-901 and 902 The sign was not of the proper color
scheme, did not include the three bladed Standard Radiation Symbol and did not include the
words, "Caution (or Danger) Airbome Radioactivity Area " The sign was located well to the left
of a wide walkway (which is approximately 10 to 15 feet wide) and suspended from piping
approximately 8 to 10 feet above the floor level. The opinion of the inspector is that this sign was
not conspicuously posted as per R313-15-902(4)
This violation has been charactenzed as a Seventy Level IV The base penalty for this Seventy
Level is $750 Level IV Violations are of more than minor concem, however, if left uncorrected,
they could lead to a more senous concem. In this case, an mappropnately posted Airbome
Radioactivity Area could lead to a significant uptake to a worker Therefore, a civil penalty of
$750 IS proposed
Page 2 of 4
UTAH DEP^^MENT OF ENVIRONMENTAL ^ALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600 License Number UT1900479
Lakewood, Colorado 80228
NOTICE
Compliance with the provisions of this NOV-PICP is mandatory. Under UAC R313-14-15, the
Licensee's good faith efforts to comply with the NOV-PICP may impact the monetary penalty
that would apply m a settlement Providing false mformation may subject the Licensee to further
civil penalties
Utah Code Ann Section 19-3-109 provides that a violation of the Act or related order may be
subject to a civil penalty of up to $5,000 per violation.
A wntten response is required within 30 calendar days after receipt of this Notice Any reply to
this NOV-PICP should include, for each violation* (1) the conective steps which have been
taken and the results achieved, (2)"^ the corrective steps which have been taken to prevent
recurrence; and (3) the date full compliance will be achieved A response protesting the NOV-
PICP shall include: (1) an admission or denial of the item of non-compliance, (2) a
demonstration of extenuating circumstances, (3) a showing of error in the NOV-PICP, or (4)
other reasons why the penalty should not be imposed
Any response or wntten answer to this Notice of Violation should be addressed to Rusty
Lundberg, Director, Utah Division of Radiation Control, 195 North 1950 West, P O Box
144850, Salt Lake City, Utah 84114 4850
CIVIL PENALTY
The licensee must pay the civil penalty or Respond to this Notice of Agency Action imposing the
civil penalties by filing a wntten answer. Utah Code Ann Section 63G-4-201(2)(a)(vi) If the
licensee chooses to pay the civil penalty, payment shall be made within 30 calendar days of
the date of this NOV-PICP. Utah Administrative Code R313-14-15(2) and R305-6-106(2) An
extension may be given when extenuating circumstances are shown to exist. Payment shall be
made by check, payable to the Division of Radiation Control and mailed to the Division at the
address below
If the Licensee chooses not to pay the civil penalties, it must follow the procedures for
contesting the NOV-PICP described below.
Page 3 of 4
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc
225 Umon Blvd Suite 600 License Number UT1900479
Lakewood, Colorado 80228
CONTESTING THIS NOV-PICP
This NOV-PICP IS effective immediately You may contest this NOV-PICP by submitting a
Request for Agency Action in wnting as specified in Utah Administrative Code R305-6-202
Filing a request for a heanng or a general statement of disagreement is not sufficient under Utah
Code Section 63G-4-201(3)(a) of the Utah Administrative Procedures Act to preserve your nght
to challenge this NOV-PICP A Request for Agency Action must include the information
specified in R305-6-202
A Request for Agency Action must be received by the DIRECTOR withm 30 calendar days of
the date of the NOV-PICP or the NOV-PICP shall become final Failure to file a Request for
Agency Action within the penod provided waives any nght of administrative contest,
reconsideration, review, or judicial appeal An extension is only available under R305-6-110
Any response or wntten answer to this NOV-PICP should be addressed to Rusty Lundberg,
Division Director, Utah Division of Radiation Control, 195 North 1950 West, P O Box 144850,
Salt Lake City, Utah 84114-4850
Upon failure to pay any civil penalty due which has been subsequently determined m accordance
with the apphcable provisions of UCA 19-3-109 and R313-14, the matter may be referred to the
Attomey General, and the civil penalty may be collected by civil action pursuant to UCA
19-3-109(5)
Dated at Salt Lake City, Utah
This I'l-"^ day of December, 2012
Utah Division of Radiation Control
Rusty Lundberg, Director
RL/KJCkc
Page 4 of 4
State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Guvemoi
Department of
Environmental Quality
Amanda Smith
Executive Director RECEIVED
DIVISION OF RADIATION CONTROL
2 0 20)2
Per
December 17, 2012
CERTIFIED MAIL
RETURN RECEIPT REOUIRED
Jo Ann Tischler
Directoi, Compliance
Eneigy Fuels Resouices (USA) Inc
225 Union Blvd Suite 600
Lakewood, Colorado 80228
RE. DRC Inspection Module PEM-01, November 15 thiough 16, 2012; Notice of Violation,
RML UTl900479, White Mesa Mill
Dear Ms. Tischler,
On November 15 through 16, 2012, Inspection Module PEM-01 was conducted at your facility by
a lepiesentative of the Division of Radiation Contiol (DRC) of the Utah Department of
Envuonmental Quality Results of the inspection wei^e discussed with Mill Management at the
conclusion of the inspection
The inspection was an examination of activities conducted at your facility as they lelate to
compliance with the Utah Radiation Control Rules and the conditions of your Radioactive
Matenals License The inspection consisted of selective examinations of procedures and
representative records, interviews of personnel, independent measurements, and obseivations by
the inspector. The inspection focused on the MilFs Radiation Protection Program as it relates to
Exit Surveys, Routine Surveys and Radiological Postings
It was noted that not all of your activities weie conducted in compliance with State requiiements.
A Notice of Violation is enclosed The particular violation is descnbed in the enclosed Notice
Please continue to remembei that ladiation safety is the lesponsibility ofthe licensee
Sincerely,
Rusty Lundberg, Directoi
RUKJCkc
Enclosure
cc: Ronnie Nieves, Mill RSO
195 North 1950 West • Salt Lake City. UT
Mailing Address P O Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
M WW deq Utah gov
Printed on 100% rec)cled paper
UTAH I^ARTMENT OF ENVIRONMENT^QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600 License Number UT1900479
Lakewood, Colorado 80228
STATUTORY AUTHORITY
This Notice of Violation and Proposed Imposition of Civil Penalty (NOV-PICP) is issued by the
Director of the Utah Division of Radiation Contiol (hereinafter the DIRECTOR) undei the Utah
Radiation Control Act, as amended, Utah Code Ann Sections 19-3-101 to 19-3-113 (the Act),
including Utah Code Ann Sections 19-3-103 5,19-3-108. and 19-3-109 This NOV PICP is also
issued in accordance with the Utah Administrative Proceduies Act, Utah Code Ann Sections
63G-4-101 thiough 63G-4-601 The DIRECTOR is authonzed to issue such NOVs in
accordance with § 19-3-108 ofthe Utah Code
Dunng an inspection conducted by a representative of the Utah Division of Radiation Control
(DRC), on November 15 thiough 16, 2012, a violation of the White Mesa Mill Radiation
Protection Manual was identified The cuirent procedures for radiation protection at the Mill are
those set forth in the February 28, 2007 License Renewal Application
Violations are pnontized accoiding to Severity Levels, with Seventy Level V being the least
significant. The particular violation of the White Mesa Mill Radiation Protection Program is set
forth below.
VIOLATIONS
Utah Administrative Code R313-15-901, Caution Signs, states*
(1) Standard Radiation Symbol. Unless otherwise authorized by the Executive
Secretary, the symbol prescribed by lo CFR 201901, (2010), which is incorporated
by reference, shall use the colors magenta, or purple, or black on yellow
background. The symbol prescribed is the three-bladed design as follows
(a) Cross-hatched area is to be magenta, or purple, or black, and
(b) The background is to be yellow
(2) Exception to Color Requirements for Standard Radiation Symbol.
Notiuithstanding the requirements of 10 CFR 20 1901(a), (2010), which is
incorporated by reference, licensees or registrants are authorized to label sources,
source holders, or device components containing sources of radiation that are
subjected to high temperatures, with conspicuously etched or stamped radiation
caution symbols and without a color requirement.
(3) Additional Information on Signs and Labels In addition to the contents of
signs and labels prescribed in Rule R313-15, the licensee or I'egistrant shall provide,
on or near the required signs and labels, additional information, as appropriate, to
make individuals aware of potential radiation exposures and to minimize the
exposures
Page 1 of 4
UTAH ^^ARTMENT OF ENVIRONMENT1!^QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc
225 Union Blvd. Suite 600 License Number UT1900479
Lakewood, Coloiado 80228
Utah Administrative Code R313-15-902, Posting Requiiements, states
(1) Posting of Radiation Areas The licensee or registrant shall post each
radiation area with a conspicuous sign or signs bearing the radiation symbol and
the words "CAUTION, RADIATION AREA "
(2) Posting of High Radiation Areas. The licensee or registrant shall post each
high radiation area with a conspicuous sign or signs bearing the radiation symbol
and the words "CAUTION, HIGH RADIATION AREA" or "DANGER, HIGH
RADIATION AREA."
(3) Posting of Very High Radiation Areas The licensee or registrant shall post
each very high radiation area with a conspicuous sign or signs bearing the
radiation symbol and words "GRAVE DANGER, VERY HIGH RADIATION AREA "
(4) Posting of Airborne Radioactivity Areas. The licensee or registrant shall post
each airborne radioactivity area with a consjncuous sign or signs bearing the
radiation symbol and the words "CAUTION, yURBORNE im)IOACTIVITYAREA"
or "DANGER, AIRBOimE RADIOACTIVITY AREA "
(5) Posting of Areas or Rooms in which Licensed or Registered Material is Used
or Stored. The licensee or registrant shall post each area or room in which there is
used or stored an amount of licensed or registered material exceeding ten times the
quantity of such material specified in Appendix C of 10 CFR 201001 to 20.2402,
(2010), which IS incorporated by reference, with a conspicuous sign or signs
bearing the radiation symbol and ihe words "CAUTION, RADIOACTIVE
MATERIAL"or "DANGER, RADIOACTIVEMATERh\L."
Dunng the inspection, it was found that the appioach to the SAG Mill area of the facility from
the lower level was impropeiiy posted The nonconfoiming sign was a geneial safety sign that
did not meet the requiiements of R313-15-901 and 902 The sign was not of the proper color
scheme, did not include the three bladed Standard Radiation Symbol and did not include the
words, "Caution (or Danger) An borne Radioactivity Aiea " The sign was located well to the left
of a wide walkway (which is approximately 10 to 15 feet wide) and suspended fiom piping
approximately 8 to 10 feet above the flooi level The opinion of the inspector is that this sign was
not conspicuously posted as per R313-15-902(4)
This violation has been charactenzed as a Seventy Level IV The base penalty for this Seventy
Level IS $750 Level IV Violations aie of moie than minoi concem, however, if left uncoirected,
they could lead to a moie senous concem In this case, an mappropnately posted Aiibome
Radioactivity Area could lead to a significant uptake to a woiker Theiefore, a civil penalty of
$750 is proposed
Page 2 of 4
UTAH ^»ARTMENT OF ENVIRONMENT^ QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Eneigy Fuels Resouices (USA) Inc
225 Union Blvd. Suite 600 License Number UT1900479
Lakewood, Colorado 80228
NOTICE
Compliance with the piovisions of this NOV-PICP is mandatory Under UAC R313-14-15, the
Licensee's good faith efforts to comply with the NOV-PICP may impact the monetary penalty
that would apply in a settlement Pioviding false information may subject the Licensee to further
civil penalties
Utah Code Ann Section 19-3-109 provides that a violation of the Act or related oider may be
subject to a civil penalty of up to $5,000 per violation.
A written response is required within 30 calendar days after receipt of this Notice. Any reply to
this NOV-PICP should include, for each violation (1) the corrective steps which have been
taken and the lesults achieved, (2) the con*ective steps which have been taken to prevent
recurrence, and (3) the date full compliance will be achieved A response protesting the NOV-
PICP shall include (1) an admission or denial of the item of non-compliance, (2) a
demonstration of extenuating circumstances, (3) a showing of eiior in the NOV-PICP, or (4)
other reasons why the penalty should not be imposed
Any response or wntten answer to this Notice of Violation should be addressed to Rusty
Lundberg, Director, Utah Division of Radiation Control, 195 North 1950 West, P.O. Box
144850, Salt Lake City, Utah 84114 4850
CIVIL PENALTY
The licensee must pay the civil penalty or Respond to this Notice of Agency Action imposing the
civil penalties by filing a wntten answer Utah Code Ann. Section 63G-4-201(2)(a)(vi) If the
licensee chooses to pay the civil penalty, payment shall be made within 30 calendar days of
the date of this NOV-PICP. Utah Administiative Code R313-14-15(2) and R305-6-106(2) An
extension may be given when extenuating circumstances aie shown to exist. Payment shall be
made by check, payable to the Division of Radiation Contiol and mailed to the Division at the
address below.
If the Licensee chooses not to pay the civil penalties, it must follow the procedures for
contesting the NOV-PICP described below.
Page 3 of 4
UTAnlJfpARTMENT OF ENVIRONMENT^ QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Eneigy Fuels Resouices (USA) Inc
225 Union Blvd Suite 600 License Numbei UT1900479
Lakewood, Coloiado 80228
CONTESTING THIS NOV-PICP
This NOV-PICP IS effective immediately You may contest this NOV-PICP by submitting a
Request for Agency Action in wiiting as specified in Utah Administiative Code R305-6-202
Filing a request for a heanng or a general statement of disagreement is not sufficient under Utah
Code Section 63G-4-201(3)(a) of the Utah Administiative Procedures Act to pieseive youi nght
to challenge this NOV-PICP. A Request for Agency Action must include the information
specified in R305-6-202
A Request for Agency Action must be received by the DIRECTOR within 30 calendar days of
the date of the NOV-PICP or the NOV-PICP shall become final Failure to file a Request for
Agency Action within the penod provided waives any nght of administrative contest,
reconsideiation, review, or judicial appeal An extension is only available under R305-6-110.
Any response or wntten answei to this NOV-PICP should be addressed to Rusty Lundberg,
Division Directoi, Utah Division of Radiation Control, 195 North 1950 West, P O Box 144850,
Salt Lake City. Utah 84114-4850.
Upon failure to pay any civil penalty due which has been subsequently detei*mined in accordance
with the applicable piovisions of UCA 19-3-109 and R313-14, the mattei may be referred to the
Attomey Geneial, and the civil penalty may be collected by civil action pursuant to UCA
19-3-109(5)
Dated at Salt Lake City. Utah
This [^'^ day of December. 2012
Utah Division of Radiation Contiol
Rusty Lundberg. Director
RL/KJC kc
Page 4 of 4