DRC-2019-015222 - 0901a06880b72f6b

DRC-2019-015222 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 Interim Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director
November 25, 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 (RML) Number UT 1900479 Dear Ms. Weinel:
On November 12 and 13, 2019, an inspection was conducted at your facility by a representative of the
Division of Waste Management and Radiation Control (DWMRC). 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 Number 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, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control
(Over)

PRG/RMJ/kb
Enclosure: RADMOD-SSS: Surveys, Sources and Security 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 Logan Shumway, Manager, Energy Fuels White Mesa Uranium Mill
INSPECTION REPORT
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: November 12 & 13, 2019
Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control
(DWMRC)
Personnel Contacted: Terry Slade, Radiation Safety Office (RSO)
Garrin Palmer, Radiation Safety Technician (RST)
Tanner Haliday, Environmental Technician
Justin Perkins, RST
Deen Lyman, Environmental Technician
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
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 processing vanadium from tailing solution.
DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Ludlum 19 101673 5/1 3/2020
Contamination Ludlum 3002 25017719 10/1/2020
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Inspection Summary
The inspection consisted of reviewing documentation, interviewing the RSO and RS Ts 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 alternate feed truck being surveyed for release from the restricted area
by an RST. The inspector was able to see verify:
• 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 alternate feed truck and found them to 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 criteria! for NRC Regulatory Guide 8.30 Table 2;
o Used the Mill's release limits 0.2 mR/hr @l cm 1.0 mR/hr max for p!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 Equipment Unrestricted surveys documented:
o The Mill uses the release criteria! 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 ~/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;
• The Ore truck restricted surveys documented:
o The Mill uses the release criteria! for 49 CFR 173.443 for exterior of truck;
o Used the Mill's release limits 0.2 mR/hr@l cm and 1.0 mR/hr max for ~/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;
• The Yellowcake (Product) surveys documented:
o The Mill uses the release criteria! for NRC Regulatory Guide 8.30 Table 2 for the drums;
o The Mill uses U.S. Department for Transportation criteria found in 49 CFR 173.441(b)(l);
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 In the comment section of each survey it is noted that the transport trailers were surveyed
prior to loading.
• 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;
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Recommendations: Collect more wipe samples and put more detail about what is being surveyed.
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.ll(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 Inspector 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;
R d. 1 . 1 d. a 10 og1ca rea mgs o serve b urmg 1 d d . M"ll tour
Location Dose Rate (µR/hr)
Mill 100 -125
Ore Pad 200-400
Solvent Extraction Building 40-50
Yellowcake storage area 40
Deficiencies: None
Item 5. Vegetation Sampling: As a follow-up to the RADMOD-SEM-ENVIRO inspection done in
August of 2019, the inspector observed the Mill's Environmental Technicians collect vegetation samples.
Note: Vegetation samples are collected twice a year; once in the Spring and once in the Fall.
Observations: The DWMRC inspector observed:
• Collect vegetation from 3 different areas on the Mill property;
• Collected more than 3,000 grams of vegetation material from each area;
• The sampled material was placed in large plastic bag; and
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• Each bag was marked with location, date and time of sampling.
Deficiencies: None
Closeout Meeting
Energy Fuels:
Logan Shumway, Mill Manager
Terry Slade, RSO
Garrin Palmer, RST
UtahDWMRC:
Ryan Johnson, Health Physics Inspector
Findings: None
Recommendations
Conduct refresher training on doing and documenting release surveys.
Recommendation for Next Years RADMOD-SSS Inspection
1. Review survey forms to see if wipe samples are being collected; and
2. Review surveys to see if more detail on is being surveyed is being document.
Prepared By:
Reviewed By:
Ryan Johnson
(Print Name)
Phil Goble
(Print Name)
/l-,;r~;?oltf
(Signature)
~~
(Date)
I IA, J /4o IC(
(Signature) (Date)
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