DRC-2018-005401 - 0901a0688083683b

DRC-2018-005401 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

June 7, 2018

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 May 21 and 22, 2018, an inspection was conducted at your facility by representatives 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 Utah’s Radiation Control Rules, the
license conditions of the Radioactive Material License Number 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. 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)

STA/ RMJ/ka
Enclosure: RADMOD-IM Health Physics Inspection Report (DRC-2018-005525)

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:
INSPECTION REPORT
RADMOD-IM: Internal Monitoring
Energy Fuels -White Mesa Uranium Mill, Blanding Utah.
Occupational Air Sampling and Bioassay
May 2 1 & 22, 2018
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Spencer Wickham, DWMRC
Personnel Contacted:
David Turk, Energy Fuels Resources Radiation Safety Officer (RSO)
Justin Perkins, Radiation Safety Technician (RST)
Terry Slade, Chemist/Assistant RSO
David Lacy, Laboratory Technician
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RM L) UT 19004 79
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
David Turk (RSO)
Justin Perkins (RST)
Terry Slade
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Spencer Wickham (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.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 7/12/18
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Inspection Summary
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:
• Calibration sheets for general area and breathing zone sample pumps;
• General area air sampling worksheets;
• Breathing zone sampling worksheets; and
• 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 up to 598, 122% 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;
• Bioassay samples were being collected from the mill personnel performing the work;
• Bioassay results indicated that the mill personnel were not inhaling uranium; and
• Bioassay sampling and analysis standard operating procedure (SOP) was being followed .
Deficiencies: None
Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the alternate feed circuit and solvent extraction building.
Observations: The DWMRC inspector also observed:
• Alternate feed material being stored on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill; and
• Locations where general area air samples are collected.
After collecting bioassay samples, the Mill analyzes its bioassay samples in its own lab. The Inspector
interviewed the Laboratory Technician that analyzes the bioassay samples. In that interview the Inspector
verified:
• The Laboratory follows a procedure that uses ANSI/HPS N 1330-2011 Performance Criteria f or
Radiobioassay as a guide (which is referenced in NRC Regulatory Guide 8.22 Bioassay at Uranium
Mills);
• Results are reviewed by the Laboratory Technician and given to the RSO;
• 25% of the samples are sent to an off site laboratory as a quality control check; and
• The sample preparation area is regularly surveyed for Alpha to prevent contamination of the
samples.
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Rd" I a 10 og1ca rea d" b mgs o serve d d . unng Mill tour
Location Dose Rate (uR/hr)
Ore Pad 250-850
Mill 200
Yellowcake Storage Area 280
Solvent Extraction Building 42
Alternate feed Pad 180
Deficiencies: None
Item 3. Follow-up: The Mill's RSO was not at the Mill for the second day of the inspection. Therefore the
Inspector followed up with the RSO via email and a telephone conversation after the closeout meeting.
In an email dated May 24, 2018, the Inspector asked the RSO the following questions:
1. While I was reviewing the Breathing Zone (BZ) sample results, I noticed that some of the DAC
values in the YC packaging were very high. For example, in June of 2017 the Derived Air
Concentration (DAC) values were 130,443 % DAC; 598,122 %DAC; and 163,556 %DAC. This
raises a red flag for me because when you factor in the protection factor for the respirator the
results are still above 100%DAC. This means there is a potential for intake. My questions are
what is happening in the YC Packaging that is different.from when you have DAC values greater
than 100,000 %DA C than the other times when you don't? and what can be done to bring those
DAC values down?
2. Also when I was reviewing the BZ sampling results I noticed that you had some DAC values with
work associated with Sequoyah Fuels. My question, do those DAC values include the Thorium
component of that material?
3. And finally while I was looking at your Bioassay results I did notice one result that was slightly
over the Mill's 15 g/1 action level. I know that you resample. However, how do evaluate the
original sample with the resample? and what steps does the Mill take to look at the bigger picture
when evaluating a potential intake?
The RSO in a telephone conversation on the same day gave the following answers:
Response to Question I: The higher DAC values are a result of the smaller sample size of the breathing
zone samples being collected for 15 minutes. Plus the bioassay results indicated that there have not been
any intakes from operating the yellowcake packaging area.
Response to Question 2: Yes, the DAC values for the work being done for the Sequoyah Fuels material
includes Th-nat.
Response to Question 3: The RSO reviews the Bioassay results on a regular basis and wondered if I saw a
spiked sample. However, if a Bioassay results is higher than the action level then the RSO and the
radiation staff conducts an investigation on why the result was high. This includes collecting another
bioassay sample from the individual to verify the first result.
As a follow-up to the questions, the Inspector requested the bioassay results from the personnel who worked
in the yellowcake packaging area for 2017. The inspector used the bioassay data to calculate the dose in
rem received by the operators. The dose of the 12 individuals ranged from non-detect (8 individuals) to 164
mrem.
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Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Justin Perkins (RST)
Terry Slade (Chemist/Assistant RSO)
UtahDWMRC:
Ryan Johnson (Health Physics Inspector)
Spencer Wickham (Health Physics Inspector)
Findings
None
Recommendations
None
Recommendation for Next Inspection
I . 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) (Signature)
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