DRC-2015-004904 - 0901a06880555864

Department of
Environmental Quality
Alan Matheson
Acting Executive Director
GARY R HERBERT
Governor
State of Utah DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
SPENCER J COX
Lieutenant Governor
June 30, 2015 DRC-2015-003142
Kathy Weinel —^
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Radioactive Material License (RML) Number UT1900479: Health Physics Inspection
RADMOD-RWP-02
Dear Ms. Weinel:
On June 16, 2015, an inspection was conducted at your facility by Ryan Johnson a representative
of the Division of Radiation Control (DRC) of the Utah Department of Environmental Quality.
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 in your facility
as they relate to compliance with the Utah Radiation Control Rules, the license conditions of the
RML 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 regarding this inspection for your review. The DRC considers
this inspection closed. The DRC would like to thank the Mill staff for their cooperation regarding
this inspection. If you have any questions concerning this letter contact Mr. Ryan Johnson
[phone].
Sincerely,
Rusty Lundberg, Director
INSPECTION REPORT
Inspection Module:
Inspection Location:
»
Inspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted:
RADMOD-RWP-02: Radiation Work Permits, PPE and Daily, Weekly and
Monthly Inspections
Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Radiation Work Permits, PPE and Daily, Weekly and Monthly Inspections
June 16,2015
Ryan Johnson, Utah Division of Radiation Control (DRC)
David Turk, Energy Fuels Resources Radiation Safety Officer (RSO)
Governing Documents:
• UACR313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Dan Hillsten (Mill Manager)
David Turk (RSO)
Utah DRC:
Ryan Johnson (Health Physics Inspector)
Russ Topham (Engineering Inspector)
Phil Goble (Compliance Section Manager)
Dean Henderson (Hydrogeology Inspector)
During the opening meeting, the inspectors discussed the inspection items and documentation to be
reviewed during the inspection. The main portion Mill was not in operation during this inspection. Only the
alternate feed circuit was in operation. The Mill staff reminded the inspectors of the safety requirements for
the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Contamination Ludlum 2360 245764 8/8/15
Dose Rate Bicron 09048 12/11/15
Inspection Summary
The inspection consisted of an RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items.
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Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DRC inspector reviewed:
• Radiation work permits from 2013, 2014, and 2015. The inspector observed that the following
supporting documents were attached as appropriate:
o Safety Work Permits;
o Confined Space Permits; and
o Breathing Zone sampling information; and
• Daily, Weekly, and Monthly Radiation Safety Inspection forms and Reports.
Deficiencies: None
Item 2. RSO Interview:
Observations: The DRC inspector discussed the following with the Mill's RSO:
• Proper PPE in the different working area within the Mill; and
• Discussed information that was recorded on RWPs, Daily reports, Weekly reports and Monthly
reports.
Deficiencies: None
Item 3. 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, the SX building, and the tailings cells.
Observations: The DRC inspector observed:
• Proper PPE was being worn by Mill employees within all observed areas of the Mill;
• Proper Radiological Posting were being used within all observed areas of the Mill; and
• OSL badges were appropriately being used by all observed employees at the Mill;
Deficiencies: None
Closeout Meeting
Energy Fuels:
Dan Hillsten (Mill Manager)
David Turk (RSO)
Tanner Holliday (Environmental Technician)
Utah DRC:
Ryan Johnson (Health Physics Inspector) Phil Goble (Compliance Section Manager)
Russ Topham (Engineering Inspector) Dean Henderson (Hydrogeology Inspector)
Findings
None
Recommendations
The following are DRC recommendations regarding items for improvement:
• Put a signature, date and time line on the RWP forms to document when radiation safety staff
check on active RWPs; and
• Write the RWP number(s) on the Daily inspection sheets of any active RWP being worked on.
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Recommendation for Next Inspection
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately;
2. Personnel Exit Monitoring;
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Signature)
(Print Name) (Signature)
(Date)
(Date)
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UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-RWP-02
RWPs/PPE
ENERGY FUELS RESOURCES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Radioactive Material License UT 1900479, License Renewal Application dated February 28, 2007,
Radiation Protection Manual, Section 5, 10CFR20, NRC Regulatory Guide 8.30, NRC Regulatory Guide 8.31,
Utah Administrative Code R313-15.
RADIATION WORK PERMITS (Appendix E Section 5, 2007 License Renewal)
Radiation Protection Manual Section 5 Radiation Work Permits (RWPs) (Appendix E license renewal)
1) According to the Radiation Protection Manual RWPs are required to contain the following information and
copies of the RWPs are kept on file for five years. Review five (5) RWPs from the past 2 years (starting
from the present year). Verify (Yes or No) that the forms contain all of the information that is required.
Date RWP
Number
Work to
be Done
Location
of Work
Duration
of Work
Personnel
Working
PPE
Required
Monitoring
Required
RSO
Signature
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2) Were all of the RWPs that were reviewed complete?
Comments: , ML
Yes XT No
3) Was supporting documentation (i.e. Safe Work Permits and Confined Space Permits) attached to the RWPs?
Comments: . Yes \<T No
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4) Were non-applicable items on the RWPs lined out or marked with an NA?
Comments:
Yes No
5) Does the RWP form adequately cover all of the information required? Yes yt£ No
Comments:
6) On average, how much time does the RSO and Radiation Safety staff has to review requests for RWPs
before they approve them?
Comments: * *
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7) How does the RSO/Radiation Safety staff verify the RWPs are being followed?
8) Section 5.1 of the Mills Radiation Protection manual says "The receipt, handling or processing of any
alternate feed material, which has been determined by the RSO, not to within existing operating procedure".
What is the Alternate feed being processed in the Alternate feed Circuit?
Comments: ,
9) If no SOP for the alternate feed is there a RWP? Yes No
Comments: . .
10) Observe the Alternate Feed Circuit are the employees following the SOP or RWP for the material they are
processing? Yes X? No
Comments:
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11) Identify a RWP that is being worked under during the inspection and go to that work site and verify that the
RWP is being followed. What are the details of the job?
Comments: ~ *
12) What precautions are necessary to reduce exposure to Uranium and daughters
Comments: .
7&
13) What are the monitoring requirements for the RWP?
Comments:^ .
14) Are the following being done for the RWP being observed?
Yes No
Monitoring requirements
Mill personnel wearing the appropriate PPE?
Other ALARA practices being done?
Was there specialized training documented?
Comments:
fey
15) Are RWP jobs being documented on the daily and weekly inspections?
16) Any non-compliance issues observed?
Comments: _ .
M
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17) If yes, was it corrected and how was it corrected?
Comments:
Daily, Weekly and Monthly Inspections
18) Review the Daily inspections for the last year. Were any non-compliance issues identified?
Comments: ^
19) How was the non-compliance issue resolved?
Comments: y^*^-
20) Were there any re-occurrences?
Comments: , ,
MJ-
21) Review the Weekly inspections for the last year. Were any non-compliance issues identified?
Comments:.^ / /
22) How was the non-compliance issue resolved?
Comments: . .
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23) Were there any re-occurrences?
Comments:
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24) Review the monthly Reports Are the following being documented?
Yes No
A summary of the recent personnel exposure data, including
bioassay and time-weighted calculations X
A summary of all pertinent radiation survey records
A discussion of any trends or deviations from the radiation
protection and ALARA programs, including an evaluation of the
adequacy of the implementation of license conditions regarding
radiation protection and ALARA
A description of unresolved problems and the proposed corrective
measures
Comments:
25) Review the Monthly reports for the last year. Were any non-compliance issues identified?
Comments:
26) How was the non-compliance issue resolved?
Comments:
"71
27) Were there any re-occurrences?
Comments:
28) Were any non-compliance issues need to be reported to the State?
Comments:
29) Were all issues reported?
Comments:
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30) Determine the PPE requirements for each Department/Mill Location from the RSO. Then during mill tour,
visit each area and the observe workers to see if they are wearing the appropriate PPE.
Department/Location PPE Requirements (check applicable)
Laboratory
PPE Observed Y/N
Hard Hats
Safety Glasses 7< Hearing
Safety Boots Y-* Respirators
Rubber Boots
Coveralls
Tyvek
Lab Coats
Gloves
Disp. Gloves /*r-
Face Shields
Rubber Suits
Other
ML
Mill
PPE Observed Y/N
Hard Hats K Tyvek Disp. Gloves
Safety Glasses ^ Hearing Face Shields
Safety Boots X Respirators Rubber Suits
Rubber Boots Lab Coats Other
Coveralls Gloves
Alternate Feed Circuit
PPE Observed Y/N
Hard Hats Tyvek Disp. Gloves
Safety Glasses
Safety Boots
Hearing Face Shields
Respirators Rubber Suits
Rubber Boots Lab Coats Other
Coveralls Gloves
Maintenance
PPE Observed Y/N
Hard Hats
Safety Glasses
Tyvek Disp. Gloves
Hearing Face Shields
Safety Boots Respirators Rubber Suits
Rubber Boots Lab Coats Other
Coveralls 2: Gloves
Office
PPE Observed Y/N
Hard Hats Tyvek Disp. Gloves
Safety Glasses Hearing Face Shields
Safety Boots Respirators Rubber Suits
Rubber Boots Lab Coats Other
Coveralls Gloves
Ore Receiving
PPE Observed Y/N
Hard Hats
Safety Glasses
Tyvek Disp. Gloves
Safety Boots
Hearing Face Shields
Respirators Rubber Suits
Rubber Boots Lab Coats Other
Coveralls Gloves
Warehouse
PPE Observed Y/N
Hard Hats
Safety Glasses
Tyvek Disp. Gloves
Safety Boots
Hearing Face Shields
Rubber Boots
Respirators Rubber Suits
Lab Coats Other
Coveralls Gloves
Utility Crew
PPE Observed Y/N
Hard Hats Tyvek Disp. Gloves
Safety Glasses Hearing Face Shields
Safety Boots
Rubber Boots
Respirators Rubber Suits
Lab Coats Other
Coveralls Gloves
:her
Decon Crew
PPE Observed Y/N
Hard Hats
Safety Glasses
Tyvek Disp. Gloves
Hearing Face Shields '<
Safety Boots
Rubber Boots
Y' Respirators Rubber Suits <
Coveralls 2-Lab Coats Other
Gloves
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PERSONAL PROTECTIVE EQUIPMENT (PPE)
31) Were there any areas in the mill that were observed that did not have an appropriate type or amount of PPE
required? Yes No s*C
Comments: .
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32) Where do the mill personnel find out what PPE requirements there are for the department or area that they
are working in?
Comments: - ^
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33) How does the Mill verify that the mill personnel are wearing their PPE?
Comments: /J— S , J y
34) How is PPE stored and distributed to employee?
Comments: . w
35) When PPE needs to be replaced what is the Mills policy?
Comments:
FOLLOWUP ITEMS
36) Observe employees exiting the Restricted Area are the properly surveying themselves?
Comments:
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37) During the Mill Tour look for yellowcake and see if it is being cleanup.
Comments: * .
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