DRC-2018-010331 - 0901a068808f46e0

DRC-2018-010331 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
October 12, 2018 Kathy Weinel Quality Assurance Manager Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-ALARA Radioactive Material License Number UT 1900479
Dear Ms. Weinel: October 1, 2018 and October 2, 2018, 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 White Mesa 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 conditions of the referenced 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 for your review. The Division considers this inspection closed. We appreciate the assistance 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 STA/ RMJ/ka Enclosure: Inspection Report for RADMOD-ALARA UT 1900479 (DRC-2018-010435)
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
InspectionModule: RADMOD-ALARA
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection ltems: 20 | 7 Annual ALARA Report, Daily and Weekly lnspections and Monthly Reports
Inspection Dates: October I and 2,2018
Inspector(s): Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted:
Terry Slade, Energy Fuels Resources Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Goveming Documents:o UAC R3l3- 15o Radioactive Materials License (RML) UTI900479, License Condition | | .6r Nuclear Regulatory Commission (NRC) Regulatory Guide 8.3 I
Ooening Meetins
Energy Fuels Resources:
Terry Slade (RSO)
Ganin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Heahh Physics lnspector)
During the opening meeting, the inspector discussed the inspection items and documentation 1o be reviewed
duringthe inspection. TheMill staffreminded the inspectors of the safety requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Dale
Dose Rate Ludlum l9 t01673 6il5fig
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Inspection Summarv
Item l. Document Review- License Condition I 1.6 of the Mill's RML requires the Mill to perform an
annual ALARA audit of the radiation safety program as per NRC Regulatory Guide 8.3 I . The 201 7
ALARA Audit took place in April of20l8. The inspector reviewed the report ofthat audit. The ALARA
report is not required to be submitted to the DWMRC, therefore, it is reviewed by DWMRC Staffat the
Miil.
Observations: The DWMRC inspector observed:
ALARA Reporto The Mill followed the outline in NRC Regulatory Guide 8.3 l, Section 2.3.3 Radiation Protection
and ALARA Audit for the ALARA Report; and
o The ALARA report contained information on each subject ofthe outline;
o The tables and graphs have general information on the radiological conditions observed at the Mill;
. Appropriate units were used
. The report has meaningful information and describes the radiological and ALARA conditions
around the Mill.
Daily and Weekly lnspections and Monthly Reports
o Several different people do daily inspection specific to theirjob function;
o Occupational Safety Staff Daily inspections documents housekeeping issues and postings
around the Mill.
o Operating Forman's Daily inspection documents maintenance issues and, ifobserved. any
radiation issues;o The daily inspection forms are clear, concise and legible;
. The lnspector spot checked the daily inspection forms. Of the inspection forms reviewed by the
lnspector, no non-compliance issues were identified;o The weekly inspections are done by the RSO (or designee) and someone from operations;
o The weekly inspection forms are clear, concise and legible;
o Weekly inspection forms mainly document housekeeping and maintenance issues around the Mill
and the inspection forms have initials and check marks next to the items identified indicating that
the issue had been taken care of;. The Inspector spot checked the weekly inspection forms. Ofthe inspection forms reviewed by the
Inspector, no non-compliance issues were identified; and
o The Monthly reports adequately summarize the information from the daily and weekly inspections.
Follow-up ltem: The RSO and the lnspector discussed formalizing the radiation safety staffdaily checks
into a daily inspection form. The lnspector suggested that the RSO work with his staff and the EFRI's
Quality Assurance Manager to develop the form. The Inspector told the RSO that he would review the new
form in a future inspection.
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 tailing cells, solvent the extraction building and the alternate feed circuit.
Observations: The DWMRC inspector also observed:
. Altemate feed being stockpiled on the ore pad;
o OSL badges were appropriately being used by all observed employees at the Millio OSL badges are properly being stored; and
o Mill personnel were wearing appropriate PPE.
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observed durine Mill tour
Location Dose Rate (uR/hr)
Yellowcake Storase Yard l,s00
Ore Pad 200
Miil t20
Solvent Extraction Buildine 70
Alternale Feed Storaee Pad 500
Alternate Feed Circuit 45
Sequoyah Fuels Bag next to Grizzly 1,s00
Deficiencies: None
Item 3, Other Items:
The Mill RSO and the Inspector also discussed what to do when an employee loses their OSL badge. The
RSO informed the Inspector that there is an employee who has lost their OSL badge 4 times in the last 3
months. In one instance, the OSL badge was lost in the yellowcake solution and recovered but the radiation
readings were no longer representative ofthe employee's occupational radiation exposure. The inspector
told the RSO to document:
o How and when the OSL badge was lost;. How the Mill was estimating the occupational exposure for the employee who lost their OSL
badge; ando What has been done to prevent reoccurrence ofthe incident.
The Inspector suggested putting the documentation of lost OSL badges into the RSO's Monthly report.
The RSO and the Inspector discussed doing efficiency checks (aka constancy checks) on radiation detection
meters. The Inspector told the RSO that meters should be checked prior to use. The RSO asked what
method should be used and the Inspector suggested finding an ASTM or ANSI or a manufacture
recommended procedure and use that as their method. The RSO and the Inspector also briefly discussed
what type of meters (i.e. Geiger-Mueller, sodium iodide, and scintillation) should be used. The lnspector
told the RSO the type of meter is up to the Mill to decide as long as the Mill can demonstrate that it is
appropriate for the type ofsurveys that it will be used for. However, the Division uses sodium iodide and
scintillation meter because ofthe low levels ofradiation found at the Mill. The Inspector encouraged the
RSO to work with EFRI'S corporate office to come up with a plan evaluate, budget and replace when need
radiation detection meters at the Mill.
During the inspection conducted on August 7 & 8, 2018, the Inspector identified several perimeter postings
that were missing or no longer legible. The Inspector verified that those perimeter posting had been
replaced during this inspection.
The RSO asked the lnspector what to do with old check sources. The Inspector told the RSO that most
check sources are exempt and can be thrown away. The RSO then asked if he could throw them into the
tailing cell with the rest ofthe Mill's garbage. The Inspector told the RSO that he would discuss that
question with Division Management and the Inspector will letthe RSO during the next inspection. The
inspector also suggested that the Mill keeps an up to date inventory ofcheck sources. That documentation
should include the isotope, the activity, serial number and the date ofmanufacture. The Mill should also
document how and when a check source is disposed of.
The Mill agreed to help the Division to help dispose ofsome uranium contaminated laboratory glassware in
the Mill's tailing cells. The glassware was contaminated by a citizen on Utah who made yellow cake and
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uranium metal in their garage and then posted a video of them doing it on YouTube. The Division deemed
this contaminate glassware as lle.(2) material andtheMill agreed to dispose of it for the Division. The
inspector gave the Mill's RST the box and the box was placed in a container of Mill garbage to be disposed
in the Tailing cell.
Closeout Meetins
Energy Fuels:
Terry Slade (RSO)
Garrin Palmet (RST)
Utah DWMRC:
Ryan Johnson (Health Physics lnspector)
Findines
None
Recommendationsr Formalize a Daily Radiation Inspection sheet
Recommendation for Next Insoectiono Follow up on the Daily Radiation Inspection sheeto Discuss with the RSO on what to do with
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
1a-7-arr
(Print Name)(Signature)
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