DRC-2019-002761 - 0901a068809f81d4

DRC-2019-002761 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 Ty L. Howard Director
March 28, 2019
Kathy Weinel
Quality Assurance Manager Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228

RE: Health Physics Inspection RADMOD-DOT/Emergency Response Plan Radioactive Material License Number UT 1900479 Dear Ms. Weinel:

On March 18 and 19, 2019, an inspection was conducted at your facility by representatives of the Division of Waste Management and Radiation. 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 your facility as they relate to compliance with the Utah Radiation Control Rules,
the license conditions of the RML No. UT1900479 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 regarding this inspection for your review. The DWMRC considers this inspection closed. The DWMRC would like to thank the mill staff for their cooperation regarding this
inspection.
If you have any questions, please contact Ryan Johnson by phone at [phone] or by email at [e-mail]. Sincerely,
Ty L. Howard, Director Division of Waste Management and Radiation Control
(Over)

TLH/RMJ/kb
Enclosure: RADMOD-DOT/Emergency Response Plan Inspection, RML No. UT 1900479 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, Mill Manager, White Mesa Uranium Mill, EFRI
INSPECTION REPORT
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, I le.(2), Equivalent Feed and Yellowcake Shipments
and the White Mesa Mill's Emergency Response Plan
Inspection Dates: March 18 & 19, 2019
Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control
(DWMRC)
Tim Butler, DWMRC
Personnel Contacted: Terry Slade -Radiation Safety Officer (RSO)
Governing Documents:
Garrin Palmer -Radiation Safety Technician (RST)
Abel Mendoza (Junior) -Occupation Safety Technician
Wayne Palmer -Safety Manager
• UAC R313-l 5
• Radioactive Materials License (RML) UTl900479
• Applicable Mill procedures and manuals
Opening Meeting
Energy Fuels Resources:
Terry Slade, RSO
Garrin Palmer, RST
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Tim Butler (Health Physics Inspector)
During the opening meeting, the inspectors discussed the inspection items and documents to be reviewed
during the inspection. The Mill is in operation during the inspection producing Vanadium. The Mill staff
reminded the inspectors of the safety requirements for the Mill.
DWMRC Meters Used Model Serial Number Calibration Due Date
Contamination Ludlum 2360 245764 I 0/3/1 9
Dose Rate Ludlum 19 101673 7/21/19
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.
1 of Page 4
\\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT I 900479 EnergyFuels Res -White Mesa UMill\HP Inspection modules\2019\2019
Inspection Reports\lnspection Report RADMOD-DOT _Emergency 03 -1 8-1 9-pg.docx
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;
• 11 e.(2) disposal shipments;
• Yellowcake slurry shipments; and ·
• Yellowcake shipments.
Item 1 Deficiencies: According to 49 CFR 172, Subpart C Shipping Papers (incorporated by reference in
Utah Administrative Code R3 l 3-l 9-100), the following information is required on all shipping paper work
with the associated 49 CFR reference:
• UN Identification Number
• Proper shipping Name as per§ 172.101 table
• Hazard Class
• Total Activity of each package
• Number and types of packages
• Name of each radionuclide
• Description of Physical form
• Description of Chemical form
• Category of label used
• Transportation Index
• 24 hour Emergency Telephone number
• Shipper Certification
The following is required on shipping paper work for Exclusive use Shipments:
• Specify "exclusive use shipment"
• Specify instructions for maintaining exclusive use controls
§ 172.202(a)( I)
§ 172.202(a)(2)
§ l 72.202(a)(3)
§ 172.203(d)(3)
§ l 72.202(a)(7)
§ 172.203( d)( 1)
§ 172.203(d)(2)
§ 172.203(d)(2)
§ 172.203( d)( 4)
§ 172.203(d)(5)
§ 172.604
§ 172.204
§ 172.203(d)(9)
§ 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 Types of packages;
o Name of Radionuclide;
o Category of label (If applicable);
o Physical form;
o Chemical form;
o Transportation Index; and
o Shipper Certification
• 11 e.(2) Shipments
o Hazard Class;
o Package Type;
o Name of Radionuclide;
o Chemical form;
o Transportation Index; and
o Category of label (If applicable)
2 of Page 4
\\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res -White Mesa UM ill\HP Inspection modules\2019\2019
Inspection Reports\lnspection Report RADMOD-DOT _Emergency 03-18-19-pg.docx
• Yellowcake Slurry
o Type of Package; and
o Category 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 maintenance shop, tailing impoundment #3 and the
alternate feed circuit. 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:
• 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 the Mill.
Rd' I a 10 og1ca rea d" mgs o serve b dd urmg M'II I tour
Location Dose Rate (uR/hr)
Product Yard 150
Mill 80
Solvent Extraction Building 80
Alternate Feed Circuit 38
Dpm/100 cml
Yellowcake Drum a-7 0-7
Yellowcake Drum a-10 0-41
Yellowcake Drum a-I 0-10
The inspector also checked the meters used to do DOT surveys and found them to be appropriate, in
calibration and in good repair.
Item 2 Deficiencies: None
Item 3. Emergency Preparedness Plan:
Observations: During the Mill Tour one of the Mill 's Safety technicians showed the Inspectors the
different emergency equipment around the Mill. This included:
• AEDs;
• First aid kits;
• Eyewash stations;
• Emergency Showers;
• Fire suppression equipment; and
• Posted Emergency assembly areas.
One of the Inspectors also reviewed the Emergency Response Plan and documentation of Drills and
Exercises that have been done over the past year. The Inspector also interviewed the Safety Coordinator.
Item 3 Deficiencies: The Emergency Response plan that Mill personnel provided the Inspector was
outdated. It had many references to the former RSO who no longer works for the company.
3 of Page 4
\\Cbwfp2\shw\Shared\RADICOMMON\Uranium mills\UTl900479 EnergyFuels Res• White Mesa UMill\HP Inspection modules\2019\2019
Inspection Reports\lnspection Report RAD MOD-DOT _Emergency 03-1 8-1 9-pg.docx
Closeout Meeting
Energy Fuels:
Logan Shumway (Mill Manager)
Terry Slade (RSO)
Garrin Palmer (RST)
Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Tim Butler (Health Physics Inspector)
During the closeout meeting, the inspector discussed the deficiencies observed on the shipping paperwork
for the different shipments coming to and leaving the White Mesa Mill site. The Inspectors also discussed
items that need to be updated in the Emergency Response Plan. The inspector concluded that an
enforcement action was not warranted at this time.
Recommendations
The following are DWMRC recommendations for Energy Fuels Resources regarding items for
improvement:
• Put required Information on Ore shipment Bill of Ladings;
• Update Emergency Response Plan by removing all references to former RSO. Suggested using job
titles verses actual names; and -
Follow-up Items for Next Inspection
I. Documentation for medical clearance for respirator use still isn't complete for individuals at the
Mill. The Medical examinations were done at the first of the year but documentation from the
medical provider had not been obtained b · I for all of the employees.
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Print Name)
s --2~2c::J1r
(Date)
(Signature)
~d/411
(Date)
4 of Page 4
\\Cbwfp2\shw\Shared\RADICOMMON\Uranium mills\UT1900479 EnergyFuels Res -White Mesa UMill\HP Inspection modules\2019\20 19
Inspection Reports\lnspection Report RADMOD-DOT _Emergency 03-18-19-pg.docx