DRC-2019-012686 - 0901a06880b40e48

DRC-2019-012686 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
L. Scott Baird Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director
October 18, 2019
Kathy Weinel
Quality Assurance Manager Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228

RE: Compliance Evaluation Inspection: Radioactive Material License Number UT 1900479 Dear Ms. Weinel:
On October 9 and 10, 2019, an inspection was conducted at your facility by a representative of the
Division of Waste Management and Radiation Control (DWMRC) of the Utah Department of Environmental Quality. 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 concerning this letter please contact Ryan Johnson by phone at
[phone] or by email at [e-mail]. Sincerely,
Phil Goble, Manager Division of Waste Management and Radiation Control (Over)

PRG/RMJ/kb
Enclosure: RADMOD-ALARA Inspection Report 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
Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
Inspector( s):
Personnel Contacted:
Governing Documents:
INSPECTION REPORT
RADMOD-ALARA
Energy Fuels -White Mesa Uranium Mill, Blanding Utah.
2018 Annual ALARA Report, Daily and Weekly Inspections and Monthly Reports
October 9 and 10, 2019
Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Terry Slade, Energy Fuels Resources Radiation Safety Officer (RSO)
Wayne Palmer, Energy Fuels Safety Officer
e UAC R313 -15
• Radioactive Materials License (RML) UT1900479, License Condition 11.6
• Nuclear Regulatory Commission (NRC) Regulatory Guide 8.31
Opening Meeting
Energy Fuels Resources:
Terry Slade (RSO)
UtahDWMRC:
Ryan Johnson (Health Physics Inspector)
During the opening meeting, the inspector 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 recovering vanadium from its process solution.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 5/13/2020
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Inspection Summary
Item 1. Document Review-License Condition 11.6 of the Mill's RML requires the Mill to perform an
annual ALARA audit of the radiation safety program as per NRC Regulatory Guide 8.31. The 2018
ALARA Audit took place in April of 20 19. 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
• The report has meaningful information and describes the radiological and ALARA conditions
around the Mill.
Daily and Weekly Inspections and Monthly Reports
• Several different people do daily inspection specific to their job function;
o Occupational Safety Staff Daily inspections documents housekeeping issues and postings
around the Mill;
o Operating Forman's Daily inspection documents maintenance issues and, if observed. any
radiation issues;
• The daily inspection forms are clear, concise and legible;
• The Inspector spot checked the daily inspection forms. Of the inspection forms reviewed by the
Inspector, no non-compliance issues were identified;
• The weekly inspections are done by the RSO (or designee) and someone from operations;
• The weekly inspection forms are clear, concise and legible;
• Weekly inspection forms mainly document housekeeping and maintenance issues around the Mill
and the inspection forms have initials and check marks next to the items identified indicating that
the issue had been taken care of;
• The Inspector spot checked the weekly inspection forms. Of the inspection forms reviewed by the
Inspector, no non-compliance issues were identified; and
• The Monthly reports adequately summarize the information from the daily and weekly inspections.
Deficiencies: None
Item 2. Mill Tour: The Inspector walked through the restricted area on a general site tour. The tour
included the ore pad and the mill.
Observations: The DWMRC inspector also observed:
• Alternate feed being stockpiled on the ore pad;
• OSL badges were appropriately being used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE.
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R d. 1 . 1 d. b a 10 og1ca rea mgs o serve d d . M·n t unng I our
Location Dose Rate (µR/hr)
Yellowcake Storage Yard 50
Ore Pad 300-1,800
Mill 100
During the Mill Tour the Inspector was able to confirm that the Posting of Notices to Workers as required
by R313-18-l l are on the bulletin board in the break room of the administration building. This included:
• The DWMRC-04 form: and
• A memo indicating where the following documents can be found:
o State of Utah rules R313-15 and R313-18;
o Copies of EFRI's current radioactive material license;
o EFRI operating procedures; and
o Notices of Violation issued by DWMRC to EFRI.
Deficiencies: None
Closeout Meeting
Energy Fuels:
Wayne Palmer
UtahDWMRC:
Ryan Johnson (Health Physics Inspector)
Findings
None
Recommendations
None
Recommendation for Next Inspection
None
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Print Name) il1W (Signature)
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