DRC-2021-004705 - 0901a06880e5a404

INSPECTION REPORT
PRC-Zozi- 004-705
Inspection Module: RADMOD-DOT/Emergency: 49 CFR 171-173 Transportation and Packaging
Requirements & Emergency Response Plan
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Uranium Ore, Alternate Feed, 11 e.(2), Equivalent Feed and Yellowcake Shipments
and the White Mesa Mill's Emergency Response Plan
Inspection Dates: January 25 & 26, 2021
Inspectors:
Personnel Contacted:
Ryan Johnson, Utah Division of Waste Management and Radiation Control
(DWMRC)
Phil Goble, DWMRC
Logan Shumway — Mill Manager
Teny Slade - Radiation Safety Officer (RSO)
Garrin Palmer - Radiation Safety Technician (RST)
Wayne Palmer - Safety Manager
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Openin2 Meeting
Energy Fuels Resources:
Teny Slade, RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (Uranium Mill/RAM Section Manager)
During the opening meeting, the inspectors discussed the inspection items and documents to be reviewed
during the inspection. The Mill is preparing to receive and process the Chemours uranium/rare earth
mineral ore. The Mill staff reminded the inspectors of the safety requirements for the Mill.
DWMRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 4/27/2021
Inspection Summary
The inspection consisted of interviewing Mill staff, reviewing applicable documentation and a mill tour.
The following discussion provides more detail of the specific items.
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Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed Bill of Lading shipping paperwork for:
• Ore shipments;
• Alternate feed shipments;
• 11e.(2) disposal shipments; and
• Yellowcake slurry shipments.
Note: There were no yellowcake shipments in 2020
Item 1 Deficiencies: According to 49 CFR 172, Subpart C Shipping Papers (incorporated by reference in
Utah Administrative Code R313-19-100), the following information is required on all shipping paper work
with the associated 49 CFR reference:
• UN Identification Number §172 .202(a)(1)
• Proper shipping Name as per §172.101 table §172.202(a)(2)
• Hazard Class §172.202(a)(3)
• Total Activity of each package §172.203(d)(3)
• Number and types of packages §172.202(a)(7)
• Name of each radionuclide §172.203(d)(1)
• Description of Physical form §172.203(d)(2)
• Description of Chemical form §172.203(d)(2)
• Category of label used §172.203(d)(4)
• Transportation Index §172.203(d)(5)
• 24 hour Emergency Telephone number §172.604
• Shipper Certification §172.204
The following is required on shipping paper work for Exclusive use Shipments:
• Specify "exclusive use shipment" §172.203(d)(9)
• Specify instructions for maintaining exclusive use controls §173.427(4)(6)(iv)
The inspector observed that the following information was missing on all or some of the Bill of Ladings:
• Ore Shipments
o Chemical form;
o Category label (If applicable); and
o Transportation Index
• Alternate Feed Shipments
o Chemical form
• lle. (2) Shipments
o Chemical form;
o Transportation Index; and
o Category of label (If applicable)
Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour
included the mill, the Solvent Extraction building, the warehouse, and the Chemours ore storage area.
There were no shipments coming to or leaving the Mill during the inspection. Therefore the inspectors
were unable to observe incoming or outgoing shipments for this inspection for placarding, labeling,
markings and perform radiological surveys.
Observations: The DWMRC inspector observed:
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• 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;
• Mill personnel were surveying themselves out of the restricted area; and
• OSL badges were appropriately being used by all observed employees at Ole Mill.
Radiolo ical readin s observed durin Mill tour
Location Dose Rate (µ12/hr)
Warehouse 20
Mill 50-70
Solvent Extraction Building 50-70
Chemours Storage 2,500 on contact
Item 2 Deficiencies: None
Item 3. Emergency Preparedness Plan:
Observations: The Inspectors reviewed the Emergency Response Plan. The Inspector reviewed revision 6
of the Mill's Emergency Response Plan dated May 21, 2019. The Mill's Emergency Response Plan meets
all of the requirements for an Emergency Response Plan found in R313-22-32. Revision 6 updated
information and no longer referenced former employees.
The Inspector also interviewed the Safety Manager. During the interview, the Safety Manager discussed
with the Inspector how the Mill conducts 1/41y drills. The Safety Manger explained that during these drills
they try to use scenarios that could happen at the Mill (i.e. fire or confined space) to give their emergency
response team realistic training. The Safety Manager also discussed how they try to meet with the local fire
department and other local emergency response personnel to discuss possible emergency scenarios.
However due to COVID-19 those annual meetings did not occur.
Item 3 Deficiencies: None.
Item 4. ALARA Report: - License Condition 11.6 of the Mill's RML requires the Mill to perform an
annual ALARA audit of the radiation safety progyam as per NRC Regulatory Guide 8.31. Due to Covid-19,
the 2019 ALARA Audit took place in September of 2020 and was done remotely. The inspector reviewed
the report of that audit. The ALARA report is not required to be submitted to the DWMRC, therefore, it is
available to review by DWMRC Staff at the Mill.
Observations: The DWMRC inspector observed:
ALARA Report
• The Mill followed the outline in NRC Regulatory Guide 8.31, Section 2.3.3 Radiation Protection
and ALARA Audit for the ALARA Report; and
• The ALARA report contained information on each subject of the outline;
• The tables and graphs have general information on the radiological conditions observed at the Mill;
• Appropriate units were used; and
• The report has meaningful information and describes the radiological and ALARA conditions
around the Mill.
Deficiencies: None
Item 4. Other: Chemours Ore
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Recommendations
None
Follow-up Items for Next Inspection
None
Prepared By:
Reviewed By:
(Print Name)
,
( )672 (
(Date)"
(Date) (Signature)
Currently the Mill is preparing to accept and process the uranium/rare earth mineral ore from Chemours.
While onsite the Inspectors:
• Discussed what work was being done to prepare the Mill
o Cleaning out the leach tanks
o Leach tanks were being fitted with steam pipes
o Adding another tank inside the Mill (the tank came from the boneyard and was
reconditioned so it could be used)
o Adding a drum centrifuge to dewater the rare earth material after milling so it can be packaged
• During the Mill tour the Inspectors observed the areas where the work was being done
• Also during the Mill tour the Inspectors observed where the Chemours ore was:
o Being stored in SuperSaks
o Being stored in a covered area to keep them dry and out of the elements
o Roped off and posted as a "Radiation Area"
• The Inspectors emphasized for the tailings from the processing the Chemours ore to be classified as
1 1 e.(2) byproduct material, the uranium also has to be recovered.
After returning from the inspection the Inspectors informed the DWMRC Engineers of the work being done
so they could follow up with the Mill on Surety and Engineering related issues.
Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Teny Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (Uranium Mill/RAM Section Manager)
During the closeout meeting, the inspector discussed the deficiencies observed on the shipping paperwork
for the different shipments coming to the White Mesa Mill site. The inspector concluded that an
enforcement action was not warranted at this time because the DWMRC does not have regulative authority
of companies that ship to the Mill. However, the Mill did indicated that they would be sending a letter to .
those companies of the deficiencies observed.
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