DRC-2014-002681 - 0901a0688041dc30

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State of Utah
GARY R. HERBERT
Gover/zor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
March 26, 2014
DRC-2014-002442
DRC-2014-002681
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
RE: DRC Inspection Module RPP-02, March 20, 2014; RML UT1900479
Dear Ms. Weinel,
Inspection Module RPP-02 was conducted March 20, 2014, by the Division of Radiation Control
(DRC) at the White Mesa Mill. The inspection focused on the Mill's Respiratory Protection
Program. All items inspected met applicable regulatory requirements and site procedures.
All items inspected met applicable regulatory requirements and site procedures and no further
action is required in regard to this inspection.
If you have any questions regarding this inspection, please contact Kevin Carney at (801) 536-
4250.
Sincerely,
Rusty Lundberg, Director
RL/KJC:kc
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] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module:
Inspection Location:
RADMOD RPP-02 Rev 1
White Mesa Mill, Blanding Utah
RM License: UT1900479
Inspection Items:
Inspection Dates:
Inspectors:
Respiratory Protection Program
March 20, 2014
Kevin Carney, Utah Division of Radiation Control (DRC)
Personnel Contacted: David Turk, Ron Nieves and Dan Hillsten.
Governing Documents:
• Radioactive Material License UT 1900479, Amendment 5
• NRC Regulatory Guide 8.31
• NRC Regulatory Guide 8.15
• License Renewal Application Appendix L
• Utah Administrative Code R313 -15
• 10CFR20
Inspection Summary
The inspection was a verification of compliance with Utah Rules, 10CFR20, NRC Regulatory
Guides 8.31 and 8.15 and White Mesa Mill (the Mill) procedures as they pertain to the Respiratory
Protection Program at the Mill. The inspection consisted of a review of records, direct observations
and interviews with the Radiation Protection Staff as well as other personnel on site.
Discrepancies
No discrepancies were noted during the inspection.
Inspection Items
The inspection was divided into three main sections:
• Respiratory Protection Program
• Respirator Issue
• Respirator Maintenance
The inspection outlines are noted below according to section:
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Respiratory Protection Pro gram
The inspection consistecl of a review of records and s Respiratory
Protsction Program. The Mill's RespiratoryProtectio erlymanaged
with records and procedures properly maintained.
Resoirator Issue
The inspection looked at the Mill's issuance of respirators to personnel at the site, With the Mill's
RSO inaccompanimmt, a visit to the Respirator Room was made and the Respirator Technician
interviewecl. Tùe inspectorretrieved the names of individuals who were issued respirators on the last
several days and were compared with those individuals' personnel files including hainíng, medical
surveiflanðe and fit testingrecords. A]l reviewed ¡ecords were found to be in compliance.
Respi.rato¡ Mai ntenance
Ithe inspection considered themaintenance aspects oftheMill'sRqspiratoryProtectionProgram. A
documènt review showe<l Respirator Tectrniciáns had received training in respirator maintenance and
repair. Trainiug records are maintainecl in the 'Procedure Training Certificates' l,og Book in the
RSO's office. Óontamination surveys are perfomred on each respírator after cleaning. Swipes are
counted on the Mill's scalers (Ludlum 292b or Ludlum 3030) and the results are documented in the
'Respirator Survey Log' in the Radiation Safeff Office. Visual inspection of the Respirator Room
founrl the facility to be clean and orderly with respirators properly stored' Respirator cleaning
solutions an<l methods were found to be within manufacturer's specifications. No discrepancies were
noted.
Findines
The Respiratory Protection Progranr was found to be properly administered.
Conclusion and Recommendations
No violations are recommended for this inspection The findings noted should be re-addressed in the
Inspeoion Letter for this inspection and the DRC should require a response wíthin 30 clays.
Recommendation for Next Inspection
The faciat hai¡ issue should be included in the next inspection depørdent upon the outcome of the
debate on the issue,
Prepared By:Kevin Carnev (March 25.2014
Reviewecl By: Phìllìp Goble 3 z)
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02 - March 2014\.Rt'P42 lnspcction Rcporl3-20-2014.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-RPP-02 Rev 1
RESPIRATORY PROTECTION PROGAM
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
Inspectors: Kevin Carney
Inspection Dates: Start: March 20.2014 End: March 20.2014
Requirements, Procedures, Policies, Standards:
o Radioactive Materials License UT 1900479
o NRC Regulatory Guide 8.31
o NRC Regulatory Guide 8.15
o License Renewal Application Appendix L
o Utah Administrative Code R313-15
R313-15-703. Use of Individual Respiratory Protection Equipment
If the licensee or registrant uses respiratory protection equipment to limit the intake of radioactive
material:
(1) Except as provided in Subsection R313-15-703(2), the licensee or registrant shall use only
respiratory protection equipment that is tested and certified by the National Institute for Occupational
Safety and Health.
(2) The licensee or registrant may use equipment that has not been tested or certified by the National
Institute for Occupational Safety and Health or for which there is no schedule for testing or
certification, provided the licensee or registrant has submitted to the Executive Secretary and the
Executive Secretary has approved an application for authorized use of that equipment. The
application must include a demonstration by testing, or a demonstration on the basis of reliable test
information, that the material and performance characteristics of the equipment are capable of
providing the proposed degree of protection under anticipated conditions of use.
(3) The licensee or registrant shall implement and maintain a respiratory protection program that
includes:
(a) Air sampling sufficient to identify the potential hazard, permit proper equipment selection, and
estimate doses; and
(b) Surveys and bioassays, as necessary, to evaluate actual intakes; and
(c) Testing of respirators for operability, user seal check for face sealing devices and functional check
for others, immediately prior to each use; and
(d) Written procedures regarding
(i) Monitoring, including air sampling and bioassays;
(ii) Supervision and training of respirator users;
(iii) Fit testing;
(iv) Respirator selection;
(v) Breathing air quality;
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(vi) Inventory and control;
(vii) Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection
equipment;
(viii) Recordkeeping; and
(ix) Limitations on periods of respirator use and relief from respirator use; and
(e) Determination by a physician prior to initial fitting of respirators, before the first field use of non-
face sealing respirators, and either every 12 months thereafter or periodically at a frequency
determined by a physician, that the individual user is medically fit to use the respiratory protection
equipment; and
(f) Fit testing, with fit factor greater than or equal to ten times the APF for negative pressure devices,
and a fit factor greater than or equal to 500 for positive pressure, continuous flow, and pressure-
demand devices, before the first field use of tight fitting, face-sealing respirators and periodically
thereafter at a frequency not to exceed one year. Fit testing must be performed with the facepiece
operating in the negative pressure mode.
(4) The licensee or registrant shall advise each respirator user that the user may leave the area at any
time for relief from respirator use in the event of equipment malfunction, physical or psychological
distress, procedural or communication failure, significant deterioration of operating conditions, or any
other conditions that might require such relief.
(5) The licensee or registrant shall also consider limitations appropriate to the type and mode of use.
When selecting respiratory devices the licensee shall provide for vision correction, adequate
communication, low temperature work environments, and the concurrent use of other safety or
radiological protection equipment. The licensee or registrant shall use equipment in such a way as not
to interfere with the proper operation of the respirator.
(8) The licensee shall ensure that no objects, materials or substances, such as facial hair, or any
conditions that interfere with the face and facepiece seal or valve function, and that are under the
control of the respirator wearer, are present between the skin of the wearer's face and the sealing
surface of a tight-fitting respirator facepiece.
(9) In estimating the dose to individuals from intake of airborne radioactive materials, the
concentration of radioactive material in the air that is inhaled when respirators are worn is initially
assumed to be the ambient concentration in air without respiratory protection, divided by the assigned
protection factor. If the dose is later found to be greater than the estimated dose, the corrected value
must be used. If the dose is later found to be less than the estimated dose, the corrected value may be
used.
Respiratory Protection Program
1) Have the respirators that the licensee uses for respiratory protection been tested and certified by the
National Institute for Occupational Safety and Health? (R313-15-703)
Yes |3 No • N/A •
Comments: The Mill is currently utilizing MSA Advantage 3000 and MSA Ultraview respirators.
Both models are NIOSH approved.
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2) Upon review of the Respirator Protection Program and Mill procedures, are written procedures in the
following areas implemented and maintained? (R313-15-703(3)(d))
Written procedures EFR Book 14 - Respiratory Protection Program (RPP) Yes No
Monitoring, including air sampling and bioassays; RPP 2.13 •
Supervision and training of respirator users;
2.1/2.2
RPP IHI •
Fit testing; RPP 2.4 •
Respirator selection; RPP 2.5 El •
Breathing air quality; RPP 2.6 •
Inventory and control; RPP 2.8 ® •
Storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection
equipment; RPP 2.8, 2.9,
2.10
•
Recordkeeping; RPP2.11 •
Limitations on periods of respirator use and relief from respirator use; RPP 2.12 •
Comments: All applicable procedures are contained in EFR Book 14 - Respiratory Protection
Program (RPPV
Respirator Issuance
3) Have the licensee provide a list of 10 respirator users. Do the following users meet the requirements
of R313-15-703 for respirator training?
Name Exams Initial/ Refresher
Training Records
Medical
Clearance Fit Tests
1. Chad Little 2/27/2014 Yes No [ Yes [3 No [ Yes No C
2. Tyrone Little 2/25/2014 Yes [3 No [ Yes Kl No [ Yes M No C
3. Jacoby Bonn 3/18/2014 Yes [3 No [ Yes |S No [ Yes [X] No [
4. Karson Lacy 2/25/2014 Yes g] No [ Yes |K| No [ Yes S No[
Page 3 of 5
5. Verdale Boy
6. Gerald Joe
3/18/2014
2/25/2014
Yes El No •
Yes E| No •
Yes El No •
Yes El No •
Yes El No •
Yes El No •
7. Nathan Frisbee 2/29/2014 Yes El No • Yes El No • Yes El No C
8. Josh Taylor 3/3/2014 Yes El No [ Yes El No • Yes EJ No [
9. Johnson Benally 2/25/2014 Yes E No [ Yes E No • Yes E No •
10. Kevin Nez 2/28/2014 Yes E No C Yes E No • Yes E No •
Comments: Personnel that had been issued respirators in the past several days were randomly
selected from the Respirator Issue Log and checked against personnel records for Respirator Training,
Medical Clearance and Fit Testing.
Respirator Maintenance
4) Has the licensee provided documentation for training of personnel responsible for respirator
maintenance and repair?
Yes E No • N/A •
Comments: Tenava Begav (2/25/2010). Heath Latham (8/1/2012). Justin Perkins (11/9/2011) are
the Rad Techs currently qualified to perform respirator maintenance and repair. Documentation found
in personnel files.
5) Are used respirators being surveyed after each use?
Yes E No • N/A •
Comments: Respirators are surveyed after cleaning and prior to re-issue.
Page 4 of 5
6) Are respirators surveyed for removable contamination?
Yes E No • N/A •
Comments: Swipe surveys of respirators are performed prior to re-issue. Swipes are counted using
either the Ludlum 29-29 or Ludlum 30-30 scaler.
7) Do respirator surveys properly document the survey performed?
Yes E No • N/A •
Comments: Survey results are recorded on the 'Respirator Contamination Survey' log sheet.
8) Are respirators decontaminated as per Manufacturers Instructions?
Yes E No • N/A •
Comments: Respirators are deconned following MSA recommendations and using MSA approved
cleaning products.
9) Are respirators inspected in accordance with the licensee's Respiratory Protection Program?
Yes E No • N/A •
Comments: Monthly inspection of stored respirators performed. Visual inspection of respirators
performed prior to re-issue.
Additional Comments: Tour of site included taking pictures of the South Wildlife Pond for DRC staff-
Also observed drum rolling operation for Honeywell 'drum-shred' drums. Video taken and posted @
<U:\COMMON\Uranium millsMlel^YUT 1900479 EnergyFuels Res - White Mesa IIMi11\Pics\Drum
Roller Video>
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