DRC-2017-002663 - 0901a068806e73ec

State of Utah
GARYR. HERBERT
Governor
SPENCERJ. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Exzcutive Director
DIVISION OF WASTE MANAGEMENT
AND RADI,ATION CONTROL
Scott T. Anderson
Director
April2l,2017
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-IM
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:
On April 5 and 6,2017, 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 Mill staff. The inspection was an examination of the activities conducted at your
facility as they relate to compliance with the Utah Administrative Code (Radiation Control Rules), the
license conditions of your license 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 Division considers this
inspection closed. We appreciate the cooperation of the Mill staff during this inspection. If you have
any questions, please call Ryan Johnson at [phone].
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
Tefephone [phone] . Fax [phone]. T.D.D. (801) 5364284
tutuw.ileq.utah.goo
Printed on l00o/o recycled paper
DRC-2017-002663
(Over)
STA/ RMJ/ka
Enclosure: Energy Fuels Resources (USA) Inc Health Physics Inspection RADMOD-IM
c: Kirk Benge, Health Ofiicer/Environmental Health Director, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Department
Scott Hacking, P.8., DEQ District Engineer
[NSPECTION REPORT
InspectionModule: RADMOD-IM:InternalMonitoring
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
lnspection ltems: Occupational Air Sampling and Bioassay
Inspection Dates: April 5 &6,2017
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted:
David Turk, Energy Fuels Resources Radiation Safety Officer (RSO)
Justin Perkins, Radiation Safety Technician (RST)
Governing Documents:o UAC R3l3-15o Radioactive Materials License (RML) UT1900479. Applicable Mill procedures and manuals
Onenins Meetine
Energy Fuels Resources:
David Turk (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed
during the inspection. The main portion of the Mill was not in operation during this inspection. The Mill
staff reminded the inspector of the safety requirements for the Mill.
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DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 7tzln7
Inspection Summarv
The inspection consisted of a RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
. The spreadsheets when occupational air sampling results are entered;
o Calibration sheets for general area and breathing zone sample pumps;
o General area air sampling worksheets;
r Breathingzone sampling worksheets; and
o Bioassay analytical results and chain of custody forms.
While reviewing the paperwork for breathing zone sampling, the inspector noticed that there were some
very high derived air concentration (DAC) values being recorded during the last year. The DAC values
observed ranged from 102. 13% DAC to 77,020.43% DAC. The work at the Mill has been done under
Radiation Work Permits (RWPs) or according to Standard Operating Procedures (SOPs). The inspector
followed up with the RSO and verified that:
. Respirator protection was being used by the mill personnel performing the work;
o Bioassay samples were being collected from the mill personnel performing the work;
o Bioassay results indicated that the mill personnel were not inhaling uranium; and
o Bioassay sampling and analysis standard operating procedure (SOP) was being followed.
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 altemate feed circuit and solvent extraction building.
Observations: The DWMRC inspector also observed:
o Altemate feed material being stored on the ore pad;
r OSL badges were appropriately being used by all observed employees at the Mill; and
o Locations where general area air samples are collected.
ical readi observed d Mill
Deficiencies: None
Item 3. Follow-up: The Inspector finished the inspection that was done February 27 and 28. The inspector
reviewed the shipping paperwork for ore shipments and reviewed the Mill's Emergency Response Plan.
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Kadlo n un tour
Location Dose Rate (rrR/hr)
Ore Pad 600
Mill I 50 to 300
Yellowcake Storage Area 70
Solvent Extraction Bui ldine 80
Alternate feed Circuit 45
Observations:
The DWMRC inspector reviewed Bill of Lading shipping paperwork for Uranium Ore shipments. The
following information is required on all shipping paper work with the associated 49 CFR reference:
o UN Identification Numbero Proper shipping Name as per $ 1 72.101 tableo Hazard Classr Total Activity of each packageo Number and types of packagesr Name of each radionuclideo Description of Physical formo Description of Chemical formo Category of label usedo Transportation Index. 24 hour Emergency Telephone number. Shipper Certification
The following is required on shipping paper work for Exclusive use Shipments:
. Speci0 "exclusive use shipment". SpeciS instructions for maintaining exclusive use controls
$172.202(a'S(t)
$172.202(a)(2)
$172.202(a)(3)
$ r 72.203(dX3)
$172.202(a'SQ)
$r72.203(dXr)
$ r 72.203(dX2)
s172.203(d>(2)
$ r 72.203(dX4)
$ r 72.203(dxs)
9172.604
s172.204
$ r 72.203(dxe)
5173.427(4)(6)(iv)
After reviewing the bill of ladings for ore shipments, the Inspector recommended that the Mill:
o Puts an "NA" on any shipping paperwork requirement that does not apply to ore; ando Make it clear that ore shipments are "exclusive use" on the bill of ladings.
The Inspector also reviewed the Mill's Emergency Response Plan and compared it to the requirements
found in R3l3-22-32(8Xc). The Inspector observed:
o The Emergency Response Plan conforms to the requirements in R3l3-22-32(S)(c);o The Mill's assembly areas are clearly marked; ando The Mill regularly performs and documents quarterly drills.
Deficiencies: None
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Closeout Meetins
Energy Fuels:
Kathy Weinel (Corporate Quality Assurance Manager)
David Turk (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics lnspector)
Findines
None
Recommendations
None
Recommendation for Next Inspectionl. 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
(Print Name)
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(Signature)(Date)