DRC-2017-001705 - 0901a068806c909b

State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

March 10, 2017

Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228

RE: Health Physics Inspection RADMOD-DOT
Radioactive Material License Number UT 1900479
Dear Ms. Weinel:

On January 27 and 28, 2017, an inspection was conducted at the White Mesa Mill by a representative of
the Division of Waste Management and Radiation Control. Observations from the inspection were
discussed at the closeout meeting with the Mill staff. The inspection was an examination of the activities conducted at the Mill as they relate to compliance with the Utah Radiation Control Rules, the
license conditions of the Radioactive Material License No. 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 for your review. The Division considers this inspection closed.
However, the Division has recommendations for you to consider. The Division would like to thank the
Mill staff for their cooperation regarding 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
(Over)
DRC-2017-001705 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
STA/ RMJ/ka

Enclosure: Health Physics Inspection Report RADMOD-DOT
c: Kirk Benge, Health Officer/Environmental Health Director, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Department
Scott Hacking, P.E., DEQ District Engineer

INSPECTION REPORT
Inspection Module: RADMOD-DOT: 49 CFR 171-173 Transportation and Packaging Requirements
Inspection Location: Energy Fuels-White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Uranium Ore, Alternate Feed, II e.(2), Equivalent Feed and Yellowcake Shipments
Inspection Dates: February 27 & 28, 2017
Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control
(DWMRC)
Personnel Contacted: Justin Perkins, Energy Fuels Resources-Radiation Safety Technician (RST)
Terry Slade -Lab Manager
Governing Documents:
• UACR313-15
• Radioactive Materials License (RM L) UT 19004 79
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Justin Perkins (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Spencer Wickham (Health Physics Inspector)
During the opening meeting, the inspectors discussed the inspection items and documents to be reviewed
during the inspection. The Mill was not in operation during the inspection. The Mill staff reminded the
inspectors of the safety requirements for the Mill.
DWMRC Meters Used Model Serial Number Calibration Due Date
Contamination Ludlum 2360 237303 3/8/17
Dose Rate Ludlum 19 101673 7/21/17
Inspection Summary
The inspection consisted of interviewing Mill staff, 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 DWMRC inspector reviewed Bill of Lading shipping paperwork for :
• Alternate feed shipments;
• I I e.(2) disposal shipments;
• Equivalent feed shipments;
• Yellowcake slurry shipments; and
• Yellowcake shipments.
Note: The Inspector was not able to review Bills of Lading from the ore shipments during this inspection.
The inspector will review that paperwork during the next inspection.
The Inspector also observed a Yellowcake shipment leaving the White Mesa Mill. This shipment was:
• Properly placarded;
• Drums were properly labeled;
• The conveyance met DOT radiological requirements; and
• The shipping paperwork was appropriately filled out.
Item 1 Deficiencies: According to 49 CFR 172, Subpart C Shipping Papers (incorporated by reference in
Utah Administrative Code R313-19-l 00), the following information is required on all shipping paper work
with the associated 49 CFR reference:
• UN Identification Number
• Proper shipping Name as per§ 172.10 I table
• Hazard Class
• Total Activity of each package
• Number and types of packages
• Name of each radionuclide
• Description of Physical form
• Description of Chemical form
• Category of label used
• Transportation Index
• 24 hour Emergency Telephone number
• Shipper Certification
The following is required on shipping paper work for Exclusive use Shipments:
• Specify "exclusive use shipment"
• Specify instructions for maintaining exclusive use controls
§ 172.202(a)( I)
§ 172.202(a)(2)
§ 172.202(a)(3)
§I 72 .203( d)(3)
§ 172 .202(a)(7)
§ 172.203( d)( I)
§ 172 .203(d)(2)
§ 172.203(d)(2)
§ 172.203(d)(4)
§ 172.203(d)(5)
§ 172.604
§ 172.204
§ 172.203(d)(9)
§ 173 .427(4)(6)(iv)
The inspector observed that the following information was missing on all or some of the Bi ll of Ladings:
• Alternate Feed Shipments
o Proper Shipping, as per current § 172.10 I table, appropriate names were not always used
sometimes old names fro m older versions of the table were used (i .e. Cabot);
o Types of packages; (multiple)
o Category of label (If applicable); (i.e. Fan steel)
o Chemical form (i.e. Fan steel and Honeywell); and
o Transportation Index (i.e. Fan steel)
• I I e.(2) Shipments (Mastene)
o Chemical form
o Transportation Index; and
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o Category oflabel (If applicable)
In addition, it was noted on several Bills of Lading from Fansteel and Cabot, that placards were not required
as per 49 CFR 172.504 Table I, footnote 1. However, the October 1, 2014 version of 49 CFR Parts I 00 to
177, the above reference states "RADIOACTIVE placards are also required for: All shipments of
unpackaged LSA-1 material or SC0-1; all shipments required by§§ 173.427, 173.441 and 173.457 of this
subchapter to be operated under exclusive use; and all closed vehicles used in accordance with
§ 173.443(d)." 49 CFR 172.504 Table I, footnote I requires placards on exclusive use unpackaged LSA-1
and SC0-1 shipments arriving at the White Mesa Uranium Mill.
The Inspector did notice an overall improvement in the shipping paperwork from the last time that the DOT
inspection was done in August of2015. After the Inspector discussed these observations with DWMRC
management, it was decided to wait until the next DOT inspection to see if deficiencies are fixed. If the
same deficiencies still exist during the next DOT inspection, then the DWMRC will forward their findings
to the appropriate NRC region, Agreement State or to the U.S. DOT who has regulatory authority over the
company shipping the material to the Mill.
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, and the alternate feed circuit.
Observations: The DWMRC 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;
• Truck Drivers delivering materials to the Mill were being instructed on health and safety issues;
• Mill personnel were surveying themselves out of the restricted area;
• OSL badges were appropriately being used by all observed employees at the Mill; and
• Shipping labels on alternate feed shipping containers (i .e. 55-gallon drums and supersacks).
R d' I . I d' b a 10 og1ca rea mgs o serve dd urmg
Location
Guard Shack next to front gate
Mill
Scale house
Product Storage Yard
Alternate Feed Storage area
SX building
Item 2 Deficiencies: None
Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Justin Perkins (RST)
Terry Slade
Utah DWMRC:
M'll t I
Ryan Johnson (Health Physics Inspector)
Spencer Wickham (Health Physics Inspector)
our
Dose Rate (!J.Rihr)
26
300
100
200
425
110
During the closeout meeting, the inspector discussed the deficiencies observed on the shipping paperwork
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for the different shipments coming to and leaving the White Mesa Mill site. The inspector concluded that
an enforcement action was not warranted at this time.
Recommendations
The following are DWMRC recommendations for Energy Fuels Resources regarding items for
improvement:
• Write a letter and CC: the DMWRC informing shippers/transporters what information is required
on all shipping paperwork coming to and leaving from the White Mesa Mill.
Follow-up Items for Next Inspection
This inspection wasn't fully completed. Due to travel delays because of snowy weather in Northern Utah,
the inspector ran out of time. Therefore the following items will be included in the next quarterly
inspection:
I. Review the ore shipments paperwork
2. Review the Emergency response plan
Prepared By: Ryan Johnson
(Print Name)
Reviewed By: Phil Goble
(Print Name) (Signature) 1 (Date)
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