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HomeMy WebLinkAboutDRC-2022-023705 - 0901a0688113452d 1 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-RPP 3-4-2022.docx INSPECTION REPORT Inspection Module: RADMOD-RPP: Respiratory Protection Program (RPP) Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah. Inspection Items: Respiratory Protection Inspection Dates: March 4 & 5, 2022 Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control (DWMRC) Larry Kellum, DWMRC Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RS0) Abel Mendoza Jr., Safety Technician Governing Documents: • UAC R313-15 • Radioactive Materials License (RML) UT1900479 • Applicable Mill procedures and manuals • NRC Regulatory Guide 8.15 Opening Meeting Energy Fuels Resources: Garrin Palmer, RSO Utah DWMRC: Ryan Johnson (Health Physics Inspector) Larry Kellum (Health Physics Inspector) During the opening meeting, the inspectors discussed the inspection items and documents to be reviewed during the inspection. The Mill was not processing ore or feed material at the time of the inspection. The Mill staff reminded the inspectors of the safety requirements for the Mill. DRC Meters Used Model Serial Number Calibration Due Date Dose Rate Bicron 318 8/5/2022 Inspection Summary The inspection consisted of a RSO interview, reviewing applicable documentation and a mill tour. The following discussion provides more detail of the specific items reviewed. 2 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-RPP 3-4-2022.docx Item 1. Documentation Review: The Inspector reviewed applicable documentation. Observations: The DWMRC inspectors reviewed the following documents: • The current Respiratory Protection Manual and confirmed all required respirator protection procedures from R313-15-703 and NRC Reg. Guide 8.15 are covered in the manual; • The respirator issuance log; • Respirator Damage Sheet; • Fit testing and respirator training documentation; • Respirator survey forms; and • The Medical Clearance form. Deficiencies: None Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour included ore pad, the mill, the solvent extraction building, the alternate feed circuit, the tailing impoundments, and the respirator room. Observations: The DWMRC inspectors also observed: • OSL badges were appropriately being used by all observed employees at the Mill; • Native ore and Alternate feeds are being stored on the ore pad. There currently is no Chemours ore onsite. All of the Chemours ore that has been at the Mill has been processed. • Tank #7 was properly posted as a “Radiation Area”; • Respirator room was clean and well organized; • Respirators were clean and in good repair; and • Meters used to survey respirators were calibrated and in good repair. The Inspectors spoke with the Safety Technician that performs the fit testing at the Mill. The Mill is using the same equipment and procedures as they have in previous years. Radiological readings observed during Mill tour Location Dose Rate (µR/hr) Mill 20-60 Tank #7 2,500-8,000 Product Storage Yard 40 Solvent Extraction Building 30 Ore Pad 600-900 Alternate Feed Circuit 30 Respirator room 20 Deficiencies: None 3 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-RPP 3-4-2022.docx Item 3. Other: Observations: Tailing Impoundment 4B On January 13, 2022, representatives from the U.S. Environmental Protection Agency (EPA) came to the Mill to discuss a potential Notice of Violation that the EPA may issue and to observe solution elevation in tailing impoundment 4B. Which is used as an evaporation pond (non- conventional impoundment). The issue tailing impoundment 4B has very little to no liquid in the bottom of it. At the bottom impoundment 4B evaporite crystals have formed across the entire bottom of the 40-acre impoundment. The EPA using their off-site Rule, came to investigate whether or not tailing impoundment 4B violated NESHAP subpart W requirements for Radon emission from a uranium mill. On March 3, 2022, the EPA Region 8’s office sent a “Final CERCLA Offsite Rule Determination”. This letter reaffirmed the EPA Region 8’s office of their business decision not to allow White Mesa to accept CERCLA (i.e., Dawn Mining alternate feed) waste until the facility returns to physical compliance with the requirement of 40 C.F.R. Part 61, Subpart W, in accordance with the CERCLA OSR at 40 C.F.R. § 300.440. In short, the EPA Region 8’s requirement that the Mill must maintain a minimum of 1 foot liquid across the entire bottom of tailing impoundment 4B. Deficiencies: The inspector observed that EFRI has not put a minimum of 1 foot of liquid across the bottom of 4B. However, this issue is regulated by the Utah Division of Air Quality, not the DWMRC. Closeout Meeting Energy Fuels: Garrin Palmer, RSO Kathy Weinel, EFRI Director of Regulatory Compliance Utah DWMRC: Ryan Johnson (Health Physics Inspector) Larry Kellum (Health Physics Inspector) Findings None Recommendations None Recommendation for Next Inspection Continued observation of tailing impoundment 4B 4 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2022\2022 Inspection Reports\Inspection Report RADMOD-RPP 3-4-2022.docx Prepared By: Ryan Johnson 3/6/2022 (Print Name) (Signature) (Date) Reviewed By: Phil Goble 3/6/2022 (Print Name) (Signature) (Date)