DRC-2015-006024 - 0901a06880576a97

State of Utah
GARYR. IIERBERT
Governor
SPENCERJ. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Execative Director
DTVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
September 9,2015
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225Union Blvd., Suite 600
Lakewood, CO 80228
RE: HealthPhysicsInspectionRADMOD-ENVIRO-02
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
On August 17 and 18, 2015, 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 RML No. UTI900479 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 records. The Division considers this inspection closed. The
Division would like to thank the Mill stafffor their cooperation during this inspection.
Ifyou have any questions, please contact Ryan Johnson at [phone].
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/RMJ/ka
Enclosure: RADMOD-ENVIRO-02InspectionReport
c: Worthy Glover, Health Offrcer, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Department
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 1,14880 . Salt Lake City, UT 84114-4880
Telephone [phone]. Fax (801) s364222. T.D.D. [phone]
tuww.ileq.utah.goo
Printed on l00p/o recycled paper
DRC-2015-006024
INSPECTTON REPORT
InspectionModule: RADMOD-ENVIRO-02:EnvironmentalMonitoring
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection ltems: Environmental Soil Sampling and Air Monitoring
Inspection Dates: August 17 & 18,2015
Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control
(DWMRC)
Personnel Contacted: David Turk, Enerry Fuels Resources Radiation Safety Officer (RSO)
Tanner Holliday (Environmental Technician)
Garrin Palmer (Environmental Technician)
Governing Documents:
o UAC R3l3-15o Radioactive Materials License (RML) UT1900479. Applicable Mill procedures and manuals
Openins Meetins
Energy Fuels Resources:
David Turk (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspectors discussed the inspection items for the inspection. The Mill was
not in operation during the inspection. The Mill staff reminded the inspector of the safety requirements for
the Mill.
InsDection Summarv
The inspection consisted of observing Mill personnel collecting soil and air monitoring samples. The
following discussion provides more detail of the specific items.
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DWMRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Bicron 09048 t2nlt15
Item 1. Air Monitoring:
Observations: Air Monitoring observations: The Inspector observed an environmental technician from the
Millcollect three filters from high-volume air monitoring stations (BHV-4, BHV-5 and BHV-6). The
following activities were observed:o The old filter was removed, folded into fourths to keep the collected material on the filter. The
filter is placed into a folder with the end date and times recorded on it;
o The airflow of the pump was checked with a manometer and adjusted to the appropriate air flow;o A new filter placed at each air monitoring station with start times and date recorded;o The air flow for each air monitoring station, the start and end dates and times are recorded on the
Monthly Calibration and llteekly Flow Check llorluheet;o The air filters were taken back to office where it is weighed; and
r The air filters are stored until they are sent to the laboratory for analysis.
Note: Each air filter is the approximate size of a sheet of an 8 x I I inch paper
Deficiencies: None
Item 2. Soil Sampling: The main purpose of this inspection was to observe soil sampling and the
placement of the new soil sampling locations.
Observations: During this inspection the Mill collected soil samples at each air monitoring location and
established new soil sampling locations according to the Mill's new Environmental Monitoring Plan. The
following activities were observed:o Each soil sample location was marked with a 1.5 foot long piece of rebar that had a metal
identifi cation tag attached;o Each piece of rebar was painted orange and surveying tape was attached;o Each location was surveyed with a hand-held GPS unit;e Each soil sample was collected byo Marking a 12 inch square on the ground;
o Removing the soil within the square I to 2 inches deep;o Approximately one gallon of soil is placed in a large Ziploc type plastic bag; and
o Each bag is marked with the sample location, the date and time of collection.
During the inspection the inspector questioned:. Why one gallon of soilwas being collected from each location? ando Whether the ffowel being used to collect the soil should be decontaminated in between each
sample?
These questions were brought up during the closeout meeting and followed up by the inspector with an
email to Kathy Weinel (Energy Fuels Quality Assurance Manager). Ms. Weinel's response to the
inspector's email was as follows:o EFRI samples a I foot by I foot by 5 cm. area at each location;o The entire aliquot is submitted for analysis so that the entire zone is represented in the sample;o The 5 cm. depth was chosen because that is the depth recommended in the NRC Regulatory Guide
4.14 which is the basis for their effluent monitoring program;
o EFRI added several analyses to the soil sampling suite and the 1 cm. depth does not provide
adequate volume for the laboratory to complete all of the analyses and any associated lab QC
(matrix spikes, matrix spike duplicates and lab duplicates). The I cm. volume also does not provide
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enough sample should re-analysis be necessary; and
o A decontamination procedure will be added.
After reviewing Ms. Weinel's response, the inspector was satisfied with the response.
Deficiencies: None
Item 3. Radon and Gamma Monitoring:
Observations: While observing air monitoring and soil sampling, the inspector was able to confirm that
Radon and Gamma monitoring was being done at all of the air monitoring locations except for BHV-3.
During this inspection the inspector did not go to BHV-3. Therefore, the inspector was unable to confirm
radon and gamma monitoring at that location. The following was observed:o TLDs were used for gamma monitoring;o Each TLD was approximately one meter off the ground;
o Rad trackers were used for radon monitoring; ando The Rad trackers were also approximately one meter off the ground.
Deficiencies: None
Closeout Meetins
Energy Fuels:
David Turk (RSO)
Tanner Holliday (Environmental Technician)
Garrin Palmer (Environmental Technician)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the closeout meeting the inspector brought up the questions:
. Why one gallon of soil was being collected from each location? ando Whether the trowel being used to collect the soil should be decontaminated in between each
sample?
The RSO and environmental technician indicated that they were following the Environmental Monitoring
Plan. The inspector indicated that these questions would be sent to Kathy Weinel (Energy Fuels Quality
Assurance Manager) with a follow-up email.
Recommendations
None
Recommendation for Next Inspection
l. Spills (yellowcake and other materials) being cleaned up in the mill immediately;
2. Personnel Exit Monitoring;
Rvan Johnson ?-: -/{-
(Print Name)
Phil Goble
(Print Name)(Date)
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Prepared By:
Reviewed By:
(Signature)
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