DRC-2018-006861 - 0901a06880876137

DRC-2018-006861 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

July 25, 2018

Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-SSS
Radioactive Material License Number UT 1900479

Dear Ms. Weinel:
On July 9 and 10, 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 your facility as they relate to
compliance with Utah’s Radiation Control Rules, the license conditions of the Radioactive Material
License Number UT 1900479 and federal regulations. The inspection consisted of an examination of
representative records, interviews of personnel and observations by the inspectors.
Enclosed is the inspection report regarding this inspection. 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/al
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 REPORT
Inspection Module: RADMOD-SSS: Surveys, Sources and Security
Inspection Location: Energy Fuels -White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiological Release Surveys, Check Sources and Facility Security
Inspection Dates: July 9 & I 0, 2018
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Phil Goble, DWMRC
Personnel Contacted: David Turk, Radiation Safety Office (RSO)
Governing Documents:
Justin Perkins, Radiation Safety Technician (RST)
Heath Latham, RST
• UACR313-15
• 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)
Phil Goble (U-Mill/RAM Section Supervisor)
During the opening meeting, the in spector discussed the inspection items and documentation to be reviewed
during the inspection. The main portion of the Mill was processing Sequoyah Fuels alternate feed material
during this inspection. 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 6/1 5/2019
Contamination Ludlum 2360 245764 11 /14/2018
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Inspection Summary
The inspection consisted of reviewing documentation, interviewing the RSO and RSTs and a mill tour. The
following discussion provides more detail of the specific items reviewed.
Item 1. Radiological Surveys
Observations:
The Inspector was able to observe an ore truck being surveyed an RST. The inspector was able to see
verify:
• The RST was following Mill procedure;
• The appropriate radiation detection meters were being used; and
• The survey consisted of direct measurements and wipe samples.
The Inspector was able to perform a survey on an ore truck and a yellowcake drum and found them to meet
the appropriate release criteria. The inspector's survey consisted of direct measurements and wipe samples.
The DWMRC inspector reviewed completed release survey forms and observed:
• The lntermodal Container Unrestricted surveys documented:
o The Mill uses the release criterial for NRC Regulatory Guide 8.30 Table 2;
o Used the Mill 's release limits 0.2 mR/hr @ I cm 1.0 mR/hr max for ~/y readings;
o The survey forms were complete and legible;
o Appropriate units were used;
o Meter information such as efficiency, calibration, background was recorded on each form ;
and
o The survey included 30 locations inside and outside the container.
• The Equipment Unrestricted surveys documented:
o The Mill uses the release criterial for NRC Regulatory Guide 8.30 Table 2;
o Used the Mill's release limits 0.2 mR/hr @ l cmand 1.0 mR/hr max for ~/y readings;
o The survey forms were complete and legible;
o Appropriate units were used; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• The Ore truck restricted surveys documented:
o The Mill uses the release criteria I for 49 CFR 173 .443 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr @ l cmand 1.0 mR/hr max for ~/y readings;
o The survey forms were complete and legible;
o Appropriate units were used; and
o Meter information such as efficiency, calibration, background was recorded on each form;
• The Yellowcake (Product) surveys documented:
o The Mill uses the release criterial for NRC Regulatory Guide 8.30 Table 2 for the drums;
o The Mi II uses U.S. Department for Transportation criteria found in 49 CFR 1 73 .441 (b )( 1 );
o The survey forms were complete and legible;
o Appropriate units were used;
o Meter information such as efficiency, calibration, background was recorded on each form;
and
o In the comment section of each survey it is noted that the transport trailers were surveyed
prior to loading.
• Restricted Release Surveys documented:
o The survey forms were complete and legible;
o Appropriate units were used;
o Meter information such as efficiency, calibration, background was recorded on each form;
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Deficiencies: It was observed that the RSTs were not being consistent with documenting calibration dates
on the survey forms. Sometimes they would use the calibration date and sometimes they would use the
calibration due date. The RSO discussed this inconsistency with the RSTs to correct the problem during the
inspection. No further action is necessary.
Item 2. Calibration Sources
Observations: The DWMRC inspector observed:
• The check sources are exempt sources;
• The check sources are kept in a locked safe in the rad tech office;
• Checked sources are checked out and checked in using a checkout form; and
• The inventory list of the check sources is kept up-to-date as an attachment to the Mill's Radiation
Safety plan.
Deficiencies: None
Item 3. Site Security (10CFR37.l l(c))
Observations: The DWMRC inspector observed:
• A short-circuit camera system that record activities at each of the gates, the product yard and other
locations scattered throughout the Mill;
• Gates were closed and locked except when being used; and
• Exterior doors are lock and require a badge to open them.
Deficiencies: None
Item 4. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, the tailing cells and solvent the extraction building.
Observations: The DWMRC inspector also observed:
• Ore (alternate feed) being stockpiled on the ore pad;
• Sequoyah Fuels alternate feed material being unloaded into the Mill's grizzly. The inspector
observed:
o Three Mill personnel were working together to unload the Sequoyah Fuels material into the
grizzly;
o Each transport container consisted of an outer bag that contained smaller inner bags;
o The inner bags were removed from the outer bags and taken to the grizzly using a forklift;
o Once the inner bags were above the grizzly, a worker would cut the bottoms of the inner
bag to allow the Sequoyah fuels material to dump into the grizzly;
o The outer bags were folded up to be shipped back to Sequoyah Fuels for reuse. The inner
bags were collected to be taken for disposal in the tailings impoundments;
o The Mill personnel were wearing PPE such as Tyvek, Full-face respirators, hard hats,
gloves, and etc.; and
o Two of the three workers were wearing breathing zone air samplers;
• OSL badges were appropriately being used by all observed employees at the Mill; and
• OSL badges are properly being stored;
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Rd. I a 10 og1ca rea b mgs o serve d d . M.11 unng I
Location
Mill
Alternate Feed Pad
Ore Pad
Packaging Area
Solvent Extraction Building
Yellowcake storage area
Deficiencies: None
Closeout Meeting
Energy Fuels:
Logan Shumway, Mill Manager
David Turk, RSO
UtahDWMRC:
Ryan Johnson, Health Physics Inspector
Phil Goble, U-Mill/RAM Supervisor
Findings
None
Recommendations
tour
Dose Rate (µR/hr)
JOO -450
150
800
1000
50
320
Conduct refresher training on doing and documenting release surveys.
Recommendation for Next Inspection
I. Review survey forms to see if documentation inconsistencies are still occurring; and
2. Interview RS Ts to see if they had refreshe tr ·ni g on release surveys.
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Print Name)
?-/?2c)/~
(Signature)
(Date)
~13 '(Oat
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