DRC-2020-018822 - 0901a06880d8d723

INSPECTION REPORT 1)RC-2020-0/00Z2_
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: October 5 & 6, 2020
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Larry Kellum, DWMRC
Personnel Contacted: Teny Slade, Radiation Safety Office (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Onenina Meeting
Energy Fuels Resources:
Teny Slade, RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Lany Kellum (Health Physics Inspector)
During the opening meeting, the inspectors discussed the inspection items and documentation to be
reviewed during the inspection. The Mill staff reminded the inspectors of the safety requirements for the
Mill. The Mill is currently processing uranium from tailing solution.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 78 301072 8/12/2021
Dose Rate Bicron 9048 6/1/2021
Contamination Ludlum 2360 245764 11/8/2020
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 for release from the restricted area by an
RST. The inspector was able to see verify:
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• The RST was following the Mill's 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 confirmatory survey on the ore truck and a yellowcake drum. The
Surveys indicate that both the truck and the drum meet the appropriate release criteria. The inspector's
survey consisted of direct measurements and wipe samples.
The inspector reviewed completed release survey forms and observed:
• The Intermodal 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 @1 cm 1.0 mR/hr max for f3/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 Daily Vehicle Scan for Vehicles Leaving the Restricted Area surveys documented;
o The Mill uses the release criterial for 49 CFR 173.443 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr @1 cm and 1.0 mR/hr max for 0/7 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 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 @1 cm and 1.0 mR/hr max for Wy 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 criterial for 49 CFR 173.443 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr @1 cm and 1.0 mR/hr max for 13/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;
• 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;
Deficiencies: While reviewing documents, the inspectors found that the Radiation Safety Technicians
(RSTs) at the Mill have been performing radiological surveys of vehicle being released from the restricted
area. However, not all of the RSTs have been documenting the results of the radiological surveys on the
Licensee's "Daily Vehicle Scan for Vehicles Leaving the Restricted Aree survey sheets. On September
15, 2020 at the West Gate vehicle number C0158CVQ a radiological survey was performed to release the
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vehicle from the restricted area but the results were not documented. Upon further review additional
surveys from 2020s "Daily Vehicle Scan for Vehicles Leaving the Restricted Aree survey sheets were
found that were missing survey results. The RSO committed to provide training to staff. The inspector will
follow up on that training in a future inspection.
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 (10CFR37.11(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 inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the mill, and solvent the extraction building.
Observations: The DWMRC inspector also observed:
• Ore (natural ore and alternate feed) being stockpiled on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill; and
• OSL badges are properly being stored;
Radiolo ical readin s observed durin Mill tour
Location Dose Rate (µR/hr)
Mill 100
Alternate Feed Circiut 100
Solvent Extraction Building 120
Tailing Impoundment #2 50
East Gate 100
Deficiencies: None
Item 5. NESHAP Sampling: During the inspection, the Mill was performing its 1/41y radon NESHAP
sampling of tailing impoundment 2 and 3.
Observations: The DWMRC inspector observed:
• Activated carbon being put into the sampling canisters; and
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• The sampling canisters being placed on tailing impoundment #2
o The canisters were placed in a grid pattern
o Soil was placed around the edge of the canisters to seal the canisters
o The date and time of placement was recorded on each canister;
Deficiencies: None
Closeout Meeting
Energy Fuels:
Terry Slade, RSO
Garrin Palmer, RST
Justin Perkins, RST
Abel Mendoza, Jr., Safety Technician
Utah DWMRC:
Ryan Johnson, Health Physics Inspector
Larry Kellum, Health Physics Inspector
Findings:
While reviewing documents. The inspectors found that the Radiation Safety Technicians (RSTs) at the Mill
have been performing radiological surveys of vehicle being released from the restricted area. However, not
all of the RSTs have been documenting the results of the radiological surveys on the Licensee's "Daily
Vehicle Scan for Vehicles Leaving the Restricted Aree survey sheets. On September 15, 2020 at the West
Gate vehicle number C0158CVQ a radiological survey was performed to release the vehicle from the
restricted area but the results were not documented. Upon further review additional surveys from 2020s
"Daily Vehicle Scan for Vehicles Leaving the Restricted Aree survey sheets were found that were missing
survey results. The RSO committed to provide training to staff. The inspector will follow up on that
training in a future inspection.
Recommendations
Conduct refresher training on doing and documenting release surveys.
Recommendation for Next Year's RADMOD-SSS Inspection
1. Follow-up on the RSO commitment to retrain RS s to properly document survey results.
2. Review documentation to confirm all rIoJoa1 survey are being properly documented.
Ryan Johnson
(Print Name)
- -2020
(Dat
to --ea 10
(Signature) (Date)
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Prepared By:
Reviewed By: