DRC-2023-003070 - 0901a068811d2cd7

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-RWP 4-5-2023.docx
INSPECTION REPORT
Inspection Module: RADMOD-RWP: Radiation Work Permits
Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah. Inspection Items: Radiation Work Permits and Supporting Documentation

Inspection Dates: April 5, 2023 Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control (DWMRC)

Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RSO) Terry Slade, Radiation Safety Technician (RST) Logan Shumway, Mill Manager Tanner Holiday, Environmental 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 inspector discussed the inspection items and documentation to be reviewed during the inspection. The Mill is processing Chemours ore 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 Fluke RaySafe 452 294298 7/7/2023

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-RWP 4-5-2023.docx
Inspection Summary The inspection consisted of reviewing documentation, a mill tour and interviewing Mill staff. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The inspector reviewed radiation work permits (RWPs) from the beginning of 2022 to present.
Observations: The DWMRC inspector observed:
• 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 of the work to be done;
o The location where the work is to be done;
o Identified the personnel 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 requirements for the job;
o The radiation technician observations and surveillance of the job (when applicable); and o The RSO’s signature indicated that he reviewed everything associated with the work
that was done under the RWP.
• Other documents attached to the RWPs included: o The Mill’s Safe Work permits (SWPs), which document occupational safety concerns; o The Mill’s Confined Space Work permits (when applicable); o Lock out/tag out information (when applicable);
o Breathing Zone air sample results (when applicable); and
o Bioassay results of personnel working on the RWP (when applicable).
• The Mill’s dosimetry documentation for the calendar year of 2021 included:
o The dosimetry logbook that is used to document what happened to the missing OSL badges (i.e. The employee took the OSL badge home, left the OSL badge in their office or locker, or lost their OSL badge).
• Other documentation associated with dosimetry included;
o The computer spreadsheet that is used to calculate the annual TEDE for each employee.

• All forms that were observed were legible and complete. Deficiencies: None Item 2. Mill Tour: The Inspectors walked through the restricted area on a general site tour. The tour included the ore pad, the mill, the tailing impoundments, the cover test pads, and the solvent extraction building.
Observations: The DWMRC inspector also observed:

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-RWP 4-5-2023.docx
• The product yard containing full yellowcake (uranium) and black-flake (vanadium) drums;
• Rare Earth Element (REE) shipments be prepped for shipment;
• Alternate feed and ore being stockpiled on the ore pad;
• OSL badges were appropriately being worn and used by all observed employees at the Mill;
• OSL badges are properly being stored; and
• Mill personnel were wearing appropriate PPE.
Radiological readings observed during Mill tour
Location Dose Rate (µrem/hr)
Ore Pad 50-1,300
Mill 120
Tank #7 5,300
Product Yard (at fence line) 60
Solvent Extraction Building 40
Packaging Room 258
Chemours 2,000 Silmet 4,300
Deficiencies: None Item 3. Radon Flux Sampling: During the inspection, the Mill was performing its 1/4ly radon flux (NESHAP) sampling of tailing impoundment 2 and 3.
Observations: The DWMRC inspector observed:
• The sampling canisters had been placed on tailing impoundment #2 the day before
o The canisters were placed in a grid pattern; o Grid locations are marked on the tailing impoundment #2 with labeled t-posts;
o Soil was placed around the edge of the canisters to seal the canisters; o The date and time of placement was recorded on each canister.
• Canisters were picked up from tailing impoundment #2
o The activated carbon was removed from each canister and put into a sample container; o Sample containers were labeled with date and time and canister number; o New activated carbon was put back into the canisters to be placed on tailing impoundment #3 for radon flux sampling.
The canisters will be taken back to Tellco Environmental in Grand Junction, Colorado for analysis. Deficiencies: None Observations: Deficiencies: None
Item 3. Other: Observations: Tailing impoundment 4B has liquid almost across the entire bottom. The Mill’s engineer estimates that it will be covered by the end of the week. Currently they receiving water

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-RWP 4-5-2023.docx
from recapture reservoir and they are putting the water from the reservoir into 4B.
Closeout Meeting Energy Fuels: Terry Slade (RST)
Garrin Palmer (RSO)
Utah DWMRC: Ryan Johnson (Health Physics Inspector)
Findings
Licensee operations observed and records reviewed as part of the inspection module showed the licensee was found to be in compliance with their license and applicable rules and regulations.
Recommendations
None Recommendation for Next Inspection None

Prepared By: Ryan Johnson 4/11/2023
(Print Name) (Signature) (Date) Reviewed By: Phil Goble 4/11/2023
(Print Name) (Signature) (Date)