DRC-2020-017061 - 0901a06880d54cb5

INSPECTION REPORT
Inspection Module: RADMOD-RWP: Radiation Work Permits DRC -2020 -017061
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Work Permits and Supporting Documentation
Inspection Dates: August 10 and 11, 2020
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Larry Kellum, DWMRC
Personnel Contacted:
Terry Slade, Radiation Safety Officer (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Governing Documents:
• UAC R313-15
• Radioactive Materials License (RML) UT1900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Larry Kellum (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 recovering uranium at the time of the inspection but
was recovering vanadium from its process liquids that are stored in the tailing impoundments. 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 4/27/2021
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Inspection Summary
The inspection consisted of reviewing documentation, a mill tour and interviewing Mill staff. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The inspector reviewed radiation work permits (RWPs) from the
beginning of 20 1 9 to present. The Inspector also reviewed dosimetery records from 20 1 9.
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;
o A description of the work to be done;
o The location where the work is to be done;
o Identified the personnel working on the job being done and how much time they were
working on the specific job assignment;
o The estimated time that it would take to do the job;
o The personal protective equipment (PPE) requirements for the job;
o The radiological and other occupational monitoring requirements for the job;
o The radiation technician observations and surveillance of the job (when applicable); and
o The RSO's signature indicated that he reviewed everything associated with the work that
was done under the RWP.
• Other documents attached to the RWPs included:
o The Mill's Safe Work permits (SWPs), which document occupational safety concerns;
o The Mill's Confined Space Work permits (when applicable);
o Lock out/tag out information (when applicable);
o Breathing Zone air sample results (when applicable);
o Bioassay results of personnel working on the RWP (when applicable); and
o Photographs of work being done (i.e. Sequoyah Fuels project).
• The Mill's dosimetry documentation for the calendar year of 20 1 8 included:
o The dosimetry logbook that is used to document what happened to the missing OSL badges
(i.e. The employee took the OSL badge home, left the OSL badge in their office or locker,
or lost their OSL badge).
• Other documentation associated with dosimetry included;
o The computer spreadsheet that is used to calculate the annual TEDE for each employee.
• All forms that were observed were legible and complete.
Deficiencies: None
Item 2. RST Interview:
Discussion Points: The DWMRC inspector discussed with the Mill RST:
• The Mill has spare (aka "blank") OSL badges and they assign Mill personnel who lose their
OSL badges a new badge; and/or
• Depending on the situation, to account for the lost badge, the Radiation Safety Staff will assign
the Mill personnel who lost their OSL badge the highest dose received by a coworker of the
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same work crew that they work with.
In addition, the Inspector also discussed with the RST how an RWP request is reviewed:
• Each RWP request is different but it could take up to 2 hours to review and RWP;
• The RWP process begins when a supervisor requests an RWP;
• The Radiation Safety Staff goes out to the job location and determines:
o If an RWP is required;
o What type of PPE will be needed;
o What type of radiological monitoring is needed; and
o What other safety issues are present.
• The Radiation and Occupational Safety Staff will then fill out the necessary paperwork:
o The RWP;
o The SWP; and when applicable
o Confined Entry Permits; and
o Lockout/Tag out forms.
• After the RWP is completed the RSO reviews the RWPs for completeness.
Deficiencies: None
Item 3. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour
included the ore pad, the new decontamination (decon) pad, the mill, the tailing impoundments, solvent
the extraction building and the alternate feed circuit.
Observations: The DWMRC inspector also observed:
• The product yard containing full yellowcake (uranium) and black-flake (vanadium) drums;
• Alternate feed and ore being stockpiled on the ore pad;
• OSL badges were appropriately being worn and used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE.
Radiolo ical readin s observed durin Mill tour
Location Dose Rate (µR/hr)
Ore Pad 100-4,000
Mill 100
Product Yard (at fence line) 50
Solvent Extraction Building 100
Deficiencies: None
Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
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—2o2c,
(Date)
Prepared By:
Reviewed By:
Recommendation for Next Inspection
None
(Print Name) (Signature) (Date)
Ryan Johnson (Health Physics Inspector)
Larry Kellum (Health Physics Inspector)
Findino
None
Recommendations
None
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