DRC-2018-012452 - 0901a068809449fc

DRC-2018-012452 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
December 5, 2018 Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228
RE: Health Physics Inspection RADMOD-RWP
Radioactive Material License Number UT 1900479 Dear Ms. Weinel:
On November 26, 2018 and November 27, 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 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 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. The Division would like to thank the Mill staff for their cooperation during this inspection.

If you have any questions, please contact Ryan Johnson at [phone] or by email at “[e-mail]”. Sincerely,
Scott T. Anderson, Director Division of Waste Management and Radiation Control
(Over)

STA/ RMJ/kb
Enclosure: RADMOD-RWP Inspection Report (DRC-2018-012473) 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 Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
INsPEcrtoN REPoRT
Inspection Module: RADMOD-RWP: Radiation Work Permits
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection ltems: Radiation Work Permits and Supporting Documentation
Inspection Dates: November 26 &.27,2018
lnspectors: 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)
Justin Perkins. RST
Governing Documents:o UAC R3l3-15o Radioactive Materials License (RML) UT1900479. Applicable Mill procedures and manuals
Ooeninq Meetins
Energr Fuels Resources:
Terry Slade (RSO)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. The Mill was not operating and maintenance activities were being
performed. The Mill staffreminded the inspectors of the safety requirements for the Mill.
Insoection Summarv
The inspection consisted of a RSO interview, reviewing documentation and a mill tour. The following
discussion provides more detail ofthe specific items reviewed.
Item l. Documentation Review: The inspector reviewed RWPs from the beginning of 2018 to
present.
Observations: The DWMRC inspector observed:. The Mill's RWPs were appropriately filled out and contained the following information:
o A unique identification number;
o The date the RWP was issued;
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DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum l9 t0t673 6/t5/20t9
o A description ofthe work to be done;
o The location were the work is to be done;o Identified the personnel working on thejob being done and how much time they were
working on the specificjob assignment;o The estimated time that it would take to do the job;
o The PPE requirements forthejob;o The radiological and occupational monitoring requirements for thejob;o The radiation technician observations and surveillance ofthejob; and
o The RSO's signature indicated that he reviewed everything associated with the work
that was done under the RWP.o Other documents attached to the RWPS included:o The Mill's Safe Work permits, which document occupational safety concems;o The Mill's Confined Space Work permits (when applicable);o Lock ouVtag out information (when applicable);o Breathing Zone air sample results (when applicable); ando Bio assay results of personnel working on the RWP (when applicable).o All forms that were observed were legible and complete.
Deficiencies: 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, the tailing cells, solvent the extraction building and the altemate 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 Mill;
o OSL badges are properly being stored; ando Mill personnel were wearing appropriate PPE.
Deficiencies: None
Item 3, Other Items: During the Inspection the Inspector was able to observe the tailing
impoundment's leak detection systems being vacuumed out, observed the alternate feed storage areas
and checked on the startup ofthe Vanadium Circuit.
Observations: The DWMRC Inspector observed with the leak detection system:
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observed Mill tour
Location Dose Rate (uR/hr)
Ore Pad 500
Mill 150
Product Yard 480
Tailing Impoundment #l l5
Tailing Impoundment #3 900
o Tailing impoundment #l leak detection pipe being vacuumed out with a large vacuum truck:o 'l'he contractor had to use pressurized water on two different occasions to loosen up the
mud and debris; ando It took the contractor three times to vacuum all ofthe debris and water out ofthe leak
detection pipe;. T'ailing impoundment #3 leak detection pipe being vacuumed out with a large vacuum truck;o No water was used but it did take the truck two attempts to vacuum out the debris; and. The lnspector did not observe the leak detection pipe for tailing impoundment #2 being
vacuumed out.
The DWMRC Inspector observed with the alternate feed storageo Calcine, Regen. KF. Sequoyah Fuels. Dawn Mining and Fansteel alternate feeds are currently
at the Millio All alternate feeds are being stored on the ore pad;o Calcine. Regen and KF are being stored in drums; Sequoyah Fuels and Dawn Mining are being
stored in supersacs; and Fansteel is in a large pile; ando The drums and the supersacs appear to be in good condition and the pile of Fansteel is covered
with top soil.
The Vanadium Circuit is not operating but will be soon.
Deficiencies: None
Closeout Meetinq
Energy Fuels:
Logan Shumway (Mill Manager)
Terry Slade (RSO)
Garrin Palmer (RS'l')
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Findings
None
Recommendations
None
Recommendation for Next Inspectionl. Spills (yellowcake and other materials) being cleaned up in the mill immediately:
//-zq^ze/{
2. Personnel Flxit Monitoring;
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
( Date)
rt/ot-,/z"tF
(Print Name)
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(Signature)(Date)