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Home My WebLink AboutDRC-2023-002349 - 0901a068811b13c9 1 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2023\2023 Inspection Reports\Inspection Report RADMOD-DOT_Emergency 3-15-2023.docx 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, 11e.(2), Equivalent Feed and Yellowcake Shipments and the White Mesa Mill’s Emergency Response Plan Inspection Dates: March 13 & 14, 2023 Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control (DWMRC) Personnel Contacted: Garrin Palmer - Radiation Safety Officer (RSO) Terry Slade - Radiation Safety Technician (RST) Able Mendoza Jr.- Safety Technician Governing Documents: • UAC R313-15 • Radioactive Materials License (RML) UT1900479 • Applicable Mill procedures and manuals Opening Meeting Energy Fuels Resources: Garrin Palmer, RSO Utah DWMRC: Ryan Johnson (Health Physics Inspector) During the opening meeting, the inspectors discussed the inspection items and documents to be reviewed during the inspection. The Mill staff reminded the inspectors of the safety requirements for the Mill. Restricted area was very wet and muddy during this inspection. DWMRC Meters Used Model Serial Number Calibration Due Date Dose Rate Bicron B288K 8/8/2023 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. 2 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2023\2023 Inspection Reports\Inspection Report RADMOD-DOT_Emergency 3-15-2023.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; • 11e.(2) disposal shipments; and • Yellowcake shipments. Note: There were no yellowcake shipments in 2020 Item 1 Deficiencies: According to 49 CFR 172, Subpart C Shipping Papers (incorporated by reference in Utah Administrative Code R313-19-100), the following information is required on all shipping paperwork with the associated 49 CFR reference: • UN Identification Number §172.202(a)(1) • Proper shipping Name as per §172.101 table §172.202(a)(2) • Hazard Class §172.202(a)(3) • Total Activity of each package §172.203(d)(3) • Number and types of packages §172.202(a)(7) • Name of each radionuclide §172.203(d)(1) • Description of Physical form §172.203(d)(2) • Description of Chemical form §172.203(d)(2) • Category of label used §172.203(d)(4) • Transportation Index §172.203(d)(5) • 24 hour Emergency Telephone number §172.604 • Shipper Certification §172.204 The following is required on shipping paperwork for Exclusive use Shipments: • Specify “exclusive use shipment” §172.203(d)(9) • Specify instructions for maintaining exclusive use controls §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: (Rio Grande and Chemours) o Rio Grande  Chemical Form; and  Category Label. o Chemours  Specify “Exclusive Use” Shipment;  Certification Signatures • Alternate Feed Shipments: (Honeywell, Calcine, KF, Regen, Silmet and Moffat o Honeywell  Total Activity o Cameco (Calcine, KF and Regen)  Improper Chemical form o Silmet  Improper Chemical Form (listed NORM) o Moffat  Proper Shipping Name  Hazard Class  Total Activity 3 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2023\2023 Inspection Reports\Inspection Report RADMOD-DOT_Emergency 3-15-2023.docx  Name of Radionuclide  Physical Form  Chemical Form  Category Label  Transportation Index  Emergency Contact • Equivalent Feed (Empire Trust) o Specify “Exclusive Use” Shipments • 11e.(2) Shipments o No findings • Yellowcake Shipments o No findings 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 Chemours and Silmet storage areas, tailing impoundment 4B and the Product Yard. 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. • Tailing Impoundment 4B approximately 95% full. Radiological readings observed during Mill tour Location Dose Rate (µrem/hr) Product Yard 140 Mill 300-400 Solvent Extraction Building 120 Chemours Storage 2,000-3,000 Silmet 2,000-4,000 Tank #7 4,000-5,000 Packaging Room 40 Ore Pad 50 Item 2 Deficiencies: None Item 3. Emergency Preparedness Plan: Observations: The Inspectors reviewed the Emergency Response Plan. The Mill’s Emergency Response Plan meets all of the requirements for an Emergency Response Plan found in R313-22-32. The Inspector also interviewed the Safety Technician. During the interview, the Safety Technician discussed with the Inspector how the Mill conducts 1/4ly drills. The 1/4ly drills consisted of turning on the emergency siren and timing how long it would take for Mill personnel to meet at the designated assembly areas. The drills were evaluated by the Safety Manager and technicians and a brief report was written. During the 1/4ly drill on June 26, 2022 the siren did not work but it was repaired a day later. 4 of Page 4 \\Cbwfp2\shw\Shared\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2023\2023 Inspection Reports\Inspection Report RADMOD-DOT_Emergency 3-15-2023.docx The Inspector, Safety Technician and the RSO discussed that during these drills the Mill should try to use scenarios that could happen at the Mill (i.e. fire or confined space) to give their emergency response team realistic training. The Safety Technican also discussed how they try to meet with the local fire department and other local emergency response personnel to discuss possible emergency scenarios. The Mill met with local volunteer fire department on May 19, 2022 but have not scheduled future meetings and drills. The Inspector also reviewed incident reports at the Mill and determined: • That they were mostly minor injuries • The incidents were documented and • The incidents were resolved appropriately. The inspector also reviewed fire hydrant and fire equipment checks documentation. Item 3 Deficiencies: None. Closeout Meeting Energy Fuels: Terry Slade (RST) Able Mendoza Jr. (Safety Technican) Utah DWMRC: Ryan Johnson (Health Physics Inspector) Dean Henderson (Hydrogeologist) During the closeout meeting, the inspector discussed the deficiencies observed on the shipping paperwork for the different shipments coming to the White Mesa Mill site. The inspector concluded that an enforcement action was not warranted at this time because the DWMRC does not have regulative authority of companies that ship to the Mill. However, the Inspector did indicate that he would ask EFRI to work with those companies of the deficiencies observed. Recommendations • EFRI work with companies that send shipments to their facility to make improvements on their Bill of Ladings. • Create emergency scenarios and practice responding to them. • Continue to reach out to local emergency responders and include them in emergency response drills. Follow-up Items for Next Inspection Continue to document tailing impoundment 4B liquid levels. Prepared By: Ryan Johnson 3/15/2023 (Print Name) (Signature) (Date) Reviewed By: Phil Goble 3/15/2023 (Print Name) (Signature) (Date)