DRC-2018-004101 - 0901a068808021b5

DRC-2018-004101 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
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

May 3, 2018

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

RE: Health Physics Inspection RADMOD-AFIL
Radioactive Material License Number UT1900479
Dear Ms. Weinel:

Representatives of the Division of Waste Management and Radiation Control inspected the White Mesa
Mill April 16 through April 18, 2018. The inspection was an examination of the activities conducted at
the Mill as they relate to compliance with Utah’s Radiation Control Rules, the conditions of RML No. UT1900479 and federal regulations. The inspection consisted of an examination of representative
records, interviews of personnel and observations by the inspector. Observations from the inspection
were discussed at the closeout meeting with Mill staff.

Enclosed is the inspection report. The Division considers this inspection closed. The Division would also like to thank the Mill staff for their cooperation 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 (Over)

STA/ RMJ/ka
Enclosure: RADMOD-AFIL Health Physics Inspection Report (DRC-2018-004161)

c: Kirk Benge, Health Officer, San Juan Public Health Department Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer

Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted:
Governing Documents:
INSPECTION REPORT
RADMOD-AFIL: Alternate Feed and lnsitu Leach
Energy Fuels Resources Inc. (EFRI) -White Mesa Uranium Mill, Blanding Utah.
Alternate Feed Material storage and processing, 11 e(2) disposal, and Equivalent
Feed and Yellowcake Slurry storage and processing; ALARA Audit
April 16, 2018 through April 18, 2018
Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Tim Butler, DWMRC
David Turk, Energy Fuels Resources, Radiation Safety Officer (RSO)
Terry Slade, Energy Fuels Resources, Chemist/Assistant RSO
Justin Perkins, Energy Fuels Resources, Radiation Safety Technician (RST)
Kathy Weinel, Energy Fuels Resources, Quality Assurance Manager
Julia Yeckes, Energy Fuels Resources, Staff Attorney
Peter Luthiger, Energy Fuels Resources, Mestef\a ISL facility
• U AC R3 13-1 5
• Radioactive Materials License (RML) UT 19004 79
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
David Turk, RSO
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Tim Butler (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 except for
the grizzly and pulp storage which is being used for the Sequoyah Fuels alternate feed. The Mill staff
reminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 7/12/2018
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 reviewed.
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Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
• I I e.(2) Shipment paperwork;
• Alternate Feed receipts;
• Equivalent Feed paperwork; and
• Tailing Capacity Form.
The l le.(2) shipment paperwork documented:
• Where and how the l le.(2) material was disposed of in Tailing Cell #3;
• Where the l le.(2) material came from and how much material has been sent to the White Mesa
Uranium mill for disposal; and
• The radiological surveys of the truck and I le.(2) material that was received by the mill.
The alternate feed receipts documented:
• Which alternate feed material is currently being accepted and stored on the Mill's ore pad; and
• How much alternate feed material is currently onsite.
The equivalent feed paperwork documented how much equivalent feed material has been accepted and
processed at the mill.
The Tailing Capacity Form documents that there is space in the tailing cells for the amount of feed material
(both alternate feed and conventional ore) that is currently stored on the ore pad.
Defi ciencies: 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, and the alternate feed circuit. Currently KOH alternate feed material is being
processed at the alternate feed circuit, Sequoyah Fuels alternate feed is being placed into the grizzly and
being stored in the pulp tanks.
Observations: The DWMRC inspector also observed:
• Alternate feed being stored on the ore pad;
• Two Sequoyah Fuels alternate feed shipments being accepted, unloaded and staged next to the
Mill's grizzly in bags. Due to high winds and a clogged pipe inside the Mill on Monday and
Tuesday the Sequoyah Fuels material was not put into Grizzly during the inspection;
• 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;
• Proper Radiological Monitoring was being done at the Alternate Feed Circuit; and
• OSL badges were appropriately being used by all observed employees at the Mill;
R ct· I . I ct· b a 10 og1ca rea mgs o serve dd . M.11 unng I tour
Location Dose Rate (µR/hr)
Product Storage Yard 450
Alternate Feed Pad 250
Sequoyah Fuels Bags 2,100
Solvent Extraction 180
Alternate Feed Circuit 50
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Deficiencies: None
Item 3. ALARA Audit: During this in spection EFRI was performing an internal ALARA Audit. The
inspectors observed part of that audit.
Observations: During the inspection the In spectors observed:
• That the ALARA Audit was being conducted by three qualified EFRI Personnel
o Kathy Weinel, Quality Assurance Manager;
o Julia Yeckes, Staff Attorney; and
o Peter Luthiger, from the EFRJ Mestena ISL facility;
• A checklist was prepared prior to the ALARA Audit to aid in the Audit process. The list is made up
of:
o A LARA Audit requirements found in NRC Reg. Guide 8.3 I;
o Follow-up items from the previous year;
o Recommendations from the DWMRC; and
o MSHA requirements; and
• The Audit was an examination of records and on site observations. The records that were being
reviewed by the Audit team at the time of the inspection included (but not limited to):
o Training Records;
o Standard Operating Procedures; and
o Radiation Work Permits.
A member of the Audit Team also observed the receiving and unloading of two Sequoyah Fuels
alternate feed shipments.
Deficiencies: None
Closeout Meeting
Energy Fuels:
David Turk (RSO)
Kathy Weinel, Energy Fuels Resources, Quality Assurance Manager
Julia Yeckes, Energy Fuels Resources, Staff Attorney
Peter Luthiger, Energy Fuels Resources, Mestena ISL facility
UtahDWMRC:
Ryan Johnson (Health Physics Inspector)
Tim Butler (Health Physics Inspector)
Findings
None
Recommendations
None
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Recommendation for Next AFIL Inspection
I. Confirm procedures are being followed if Alternate Feeds are stored off the ore pad;
2. Verify appropriate postings and radiolo · al mo 'toring for processing alternate feeds;
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Print Name) (Signature)
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