DRC-2023-066372 - 0901a0688121d737

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RMINSPECTION REPORT
Inspection Module: RADMOD-PEM: Surveys/Posting/Exit Monitoring Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiological Postings, Routine Surveys, Employee Exit Monitoring and
General License Inspection Date: June 7, 2023
Inspectors: Ryan Johnson, Utah Division of Waste Management and Radiation Control
(DWMRC) Phil Goble, DWMRC Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RSO)
Justin Perkins, Radiation Safety Technician (RST) Tanner Holliday, Environmental Technician Deen Lyman, Environmental Technician Ryan Young, Electrical Foreman
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) Phil Goble (U-Mill Section Manager)

During the opening meeting, the inspectors discussed the inspection items for the inspection. The Mill staff reminded the inspector of the safety requirements for the Mill. Mill is processing Calcine alternate feed material. DWMRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Bicron B288K 8/8/2023
Contamination Ludlum 3002 25017719 2/9/2024
Inspection Summary
The inspection consisted of:
• Observing radiological postings around the Mill;

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• Observing Mill personnel perform exit surveys:
• Reviewing documentation of:
o Weekly Alpha surveys; o Exit Monitoring; and
• Taking dose rate and contamination measurements around the Mill.

The following discussion provides more detail of each inspection items. Item 1. Radiological Postings:
Observations: During the Mill Tour the inspector observed the following posted areas:

Posting Locations Observed Postings Observed Dose Rates
(µrem/hr)
Yellowcake Storage Area Caution Radiation Area 30
Laboratory Metallurgic Caution Radioactive Materials 40
Laboratory Chem Caution Radiation Area 30
Doors leading to the restricted
area from the Administration building
Any Area within this Mill
May Contain Radioactive Material
Not Measured
Bucking Room Caution Airborne Area 100
Yellowcake Packaging Room Caution Radiation Area
Caution Airborne Area
120
South Dryer Caution Radiation Area Caution Airborne Area 300
North Dryer Caution Radiation Area Caution Airborne Area 200
Silmet Storage Location Caution Radiation Area 4,500
Chemours Storage Location Caution Radiation Area 3,000
Tank #7 Caution Radiation Area 6,000
CCD Fixed Gauges Caution Radioactive Materials 1,100
Perimeter fence Caution Radiation Area Not Measured
Perimeter gates Any Area within this Mill
May Contain Radioactive Material
Not Measured
Ore Pad No Postings 50-300
Solvent Extraction Building No Postings 40
Mill Building No Postings 100-1,000
Scale House No Postings 80
Locker Room No Postings 30
Lunch Room No Postings 30
Note: Due to no uranium production at the time of the inspection there are fewer posted areas in the Mill.

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The Inspector also collected large area swipe samples in eleven areas within the restricted area.

Location Alpha (dpm/100cm2) Beta (dpm/100cm2) Scale House 17 Below Background
Lunch Room 17 Below Background
Lunch Room #2 Below Background Below Background
Locker Room 17 Below Background
Control Room 34 Below Background
Laboratory Metallurgic 34 Below Background
Laboratory Chem Below Background Below Background Warehouse 17 Below Background
Warehouse Office 17 Below Background
Maintenance Shop 17 Below Background Maintenance Office Below Background Below Background Deficiencies: None Item 2. Exit Surveys: The Inspector observed employees survey themselves out of the restricted
area and checked the alpha meter used. Observations: The Mill uses Alpha scintillators for exit surveys. The Inspector checked the settings of the survey instruments and found that they were set properly. Meters are calibrated annually. The Mill personnel that were observed performing exit surveys, did the surveys
appropriately. The Mill’s RSTs also perform random checks on exit surveys.
Meter Location Model Meter Serial # Probe Serial # Cal. Due Alarm Setting
West Admin. Door Ludlum 177 264740 PR191566 11/2/2023 80
East Admin. Door Ludlum 177 116481 PR16949 8/24/2023 100 Lab Admin. Door Ludlum 177 264743 RN16489 10/23/2023 80
Lunch Room Ludlum 177 264871 RN19527 1/24/2024 80
Lunch Room #2 Ludlum 177 159117 RN25289 8/16/2023 80 East Decon Gate Ludlum 177 189581 RN19024 10/24/2023 80
Deficiencies: None Item 3. Radiological Surveys and Monitoring: The Inspector reviewed the weekly surveys done
around the Mill.
Observations: The Inspector reviewed the radiological monitoring documentation performed at the Mill site. The documentation indicated that:
• All areas of the Mill are being survey for radiological conditions;
• Surveys indicate that the Mill is being maintained within regulatory radiological parameters

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• Documentation is legible, complete and using appropriate units; and
• “Clean” areas are being maintained. Meter Type Model Meter Serial # Probe Serial # Cal. Due Meter Condition
Alpha Scintillator Ludlum 3 235288 PR281511 11/2/2023 Good
Alpha Scintillator Ludlum 3 158588 PR14723 7/22/2023 Good
Alpha Scintillator Ludlum 3030 247394 NA 8/25/2023 Good
Item 3.Vegetation Sampling: As a part of the RADMOD-SEM-ENVIRO inspection to be done in August 2023, the inspector
observed the Mill’s Environmental Technicians collect vegetation samples. Note: Vegetation
samples are collected three times a year; once in the Spring, once in early summer and once in the Fall. Observations: The DWMRC inspector observed:
• Collect vegetation from 3 different areas vegetation sampling is collected 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
• Each bag was marked with location, date and time of sampling. Item 4.Cell 4B:
Tailing impoundment 4B has liquid across the entire bottom. Currently the Mill is receiving water from recapture reservoir and they are putting the water from the reservoir into 4B to build up a reserve of water. Item 5.Test Cover Cell:
During this inspection, the inspectors followed up with the cover test cell and the supplemental cover test pad by going to the pad and observing its current condition. Due to the wetter than average winter there is more vegetation growth at both locations. Some of the vegetation growth is from seeds that were planted as part of the test and some vegetation is native species that have
grown in. Item 6.Yellowcake Dryer: The Nuclear Regulatory Commission (NRC) has a proposed Inspection Procedure (IP) 89025
Assessment of Dryer and Yellowcaking Packaging Operations, out for Agreement State Comment and the Inspectors in preparation for providing comments to the NRC toured the dryer areas with the Mill’s Electrical Foreman. The Inspectors looked at the Vanadium dryer because it is similar to the Yellowcake dryers. The Yellowcake dryers (North and South) are in an enclosed area that
requires respirator protection to enter. The mill uses an ammonia and calciner process to

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precipitate and dry the yellowcake.
Take aways from this tour are:
• The NRC definition of an interlock is different from the Mill’s definition of an interlock o NRC definition of an interlock is a door that if opened causes the operation of the dryer/packaging areas to shut down the system;
o Mill has two different interlocks:
 A process interlock is when something happens in the process (i.e. the auger becomes clogged) an alarm is signaled to the control room and the system shuts down.
 An equipment interlock is when a piece of equipment breaks down or is not
operating within set parameters an alarm is signaled to the control room and
the system shuts down.
• Alarms are visual alarms that show up on the computer screen in the control room of the mill. A Mill operator will notify maintenance personnel of the alarm and a visual inspection will be performed to identify the problem behind the alarm.
• The NRC’s IP views precipitation, drying, and packaging of yellowcake and effluent controls as one system in the process of making yellowcake.
• The Mill considers these as separate systems (i.e. SX, Precip, drying, packaging).
Inspectors need to be aware that the licensee will have different perspectives and
terminologies. Inspectors need to be able to identify these differences and adapt accordingly. Closeout Meeting
Energy Fuels:
Garrin Palmer (RSO) Logan Shumway (Mill Manager) Utah DWMRC:
Ryan Johnson (Health Physics Inspector)
Phil Goble (U-Mill Section Manager) Recommendations Refresher training on Exit monitoring
Recommendation for Next Inspection None
Prepared By: Ryan Johnson 6/14/2023
(Print Name) (Signature) (Date)
Reviewed By: Phil Goble 6/14/2023
(Print Name) (Signature) (Date)