DRC-2019-005501 - 0901a06880a76285

INSPEcTtoN REPoRT
lnspection Module: RADMOD-RWP: Radiation Work Permits
lnspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Work Permits and Supporting Documentation
Inspection Dates: June 4,2019
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted:
Garrin Palmer, Radiation Safety Technician (RST)
Justin Perkins, RST
Carlos Collins, Operations
Goveming Documents:o UACR313-15r Radioactive Materials License (RML) UT1900479o Applicable Mill procedures and manuals
Openins Meetine
Energy Fuels Resources:
Justin Perkins (RST)
Utah DWMRC:
Ryan Johnson (Health Physics lnspector)
Madi Poston-Brown (NRC Inspector)
During the opening meeting, the inspector discussed the inspection items and documentation to be
reviewed during the inspection. The Inspector also explained that the NRC Inspector was doing an
accompaniment and an evaluation ofthe Inspector as part ofan Integrated Materials Performance
Evaluation Program (IMPEP) audit of the State of Utah's Radiation Program. The Mill was not
recovering uranium at the time ofthe inspection but was recovering vanadium from its process liquids
that are stored in the tailing impoundments. The Mill staffreminded the inspectors of the safety
requirements for the Mill.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum l9 101673 s/13/20
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Inspection Summarv
The inspection consisted of reviewing documentation, a mill tour and interviewing Mill staff. The
following discussion provides more detail ofthe specific items reviewed.
Item l. Documentafion Review: The inspector reviewed radiation work permits (RWPs) from the
beginning of2018 to present. The Inspector also reviewed dosimetery records from2018.
Observations: The DWMRC inspector observed:
r 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 ofthe work to be done;
o The location where the work is to be done;
o Identified the persormel 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 requiranents for the job;
o The radiation technician observations and surveillance ofthe job (when applicable); ando 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 (SWPs), which document occupational safety concems;
o The Mill's Confined Space Work permits (when applicable);o Lock ouVtag out information (whan applicable);o Breathing Zone air sample results (when applicable);o Bioassay results ofpersonnel working on the RWP (when applicable); ando Photographs ofwork being done (i.e. Sequoyah Fuels project).
o The Mill's dosimetry documentation for the calendar year of 20 I 8 included:
o Quarterly reports from the optically stimulated luminescence (OSL) badges that the Mill
used for employee occupational gamma radiation exposure;o The daily RST inspection of the dosimetry boards to identify missing OSL badges; ando The dosimetry logbook that is used to document what happened to the missing OSL badges
(i.e. The ernployee took the OSL badge home, left the OSL badge in their offrce or locker,
or lost their OSL badge);
o Other documentation associated with dosimetry included;o The "Employee Exposure to Airbome Radionuclides" tracking form, the Mill employee's
fill out to document which areas of the Mill each employee was working in and how long.
(This form is used in correlation with air monitoring to assigrr the appropriate derived air
concentration (DAC) values for the use ofcalculating each employee Total Effective Dose
Equivalent (TEDE) value.);o The computer spreadsheet that is used to calculate the amual TEDE for each employee;
ando An example of the letter that the Mill gives each employee documenting what their
occupational exposure was from the previous calendar year.
o All forms that were observed were leeible and most were comDlete.
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Deficiencies: A few of the RWPs were missing the respirator technician's initials.
Item 2. Employee Interviews: While reviewing the dosimetry logbook, the Inspector noticed that one
employee had lost his OSL badge twice. The inspector asked to interview this employee. After the
interview with the employee, he Inspector asked follow-up questions with Ganin Palmer, one of the
Mill's RSTs.
Discussion Points: The DWMRC inspector discussed with the Mill employee:
o How the OSL badges were lost;
o How employee informed the Mill's radiation staffthat he lost his dosimetry as soon as he
noticed it was gone;
r The Mill radiation safety staff gave him a new OSL badge after he reported it missing; and
. He was told to wear his dosimetry inside his coveralls to reduce the chances oflosing his
dosimetry in the future.
Discussion Points: The DWMRC inspector discussed with the Mill RST:
o The Mill has spare (aka "blank") OSL badges and they assigr 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 Staffwill assign
the Mll personnel who lost their OSL badge the highest dose received by a coworker of the
same work crew that they work with.
In addition, the lnspector also discussed with the RST how an RWP request is reviewed:
o Each RWP request is different but it could take up to 2 hours to review and RWP;
o The RWP process begins when a supervisor requests an RWP;
o Ths Radiation Safety Staffgoes out to thejob location and determines:
o If an RWP is required;
o What type ofPPE will be needed;
o What type of radiological monitoring is needed; and
o What other safety issues are present.
o The Radiation and Occupational Safety Staffwill then fill out the necessary paperwork:
o The RWP;o The SWP; and when applicable
o Confined Entry Permits; and
o Lockout/Tag out fotms.
o After the RWP is completed the RSO reviews the RWPs for completeness.
Deficiencies: None
Item 3. Mill Tour: The Inspector 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 altemate feed circuit.
Observations: The DWMRC inspector also observed:
o The product yard containing full yellowcake (uranium) and black-flake (vanadium) drums;
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Alternate feed and ore being stockpiled on the ore pad;
OSL badges were appropriately being wom and used by all observed employees at the Mill;
OSL badges are properly being stored;
Mill personnel were wearing appropriate PPE;
The test pad on tailing impoundment #2 had "green" vegetation on it; and
The Vanadium Circuit was operating during this inspection.
Deficiencies: None
Closeout Meetins
Energy Fuels:
Logan Shumway (Mill Manager)
Garrin Palmer (RST)
UtahDWMRC:
Ryan Johnson (Health Physics Inspector)
Findinss
None
Recommendationso Review with staffto completely fill out forms and to "NA" any part of the form that is not
used.
Recommendation for Next Inspection
1. Spills (yellowcake and other materials) being cleaned up in the mill immediately;2. Personnel Exit Monitoring;
Prepared By: Ryan Johnson /-6->t7
(Print Name)
Reviewed By: Phil Goble
(Print Name)
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observed Mill tour
Location Dose Rate (uR/hr)
Ore Pad 100-l,200
Mill 150-200
Product Yard (at fence line)<n
Locker Room 30
Decon Pad 80
Solvent Extraction Buildine 50
Alternate Feed Circuit 50