DRC-2023-076662 - 0901a068812be772

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U:\RAD\COMMON\Uranium mills\UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2023\2023 Inspection Reports\Inspection Report RADMOD-IM 9-13 & 14, 2023.docx
INSPECTION REPORT
Inspection Module: RADMOD-IM: Internal Monitoring Inspection Location: Energy Fuels - White Mesa Uranium Mill, Blanding Utah. Inspection Items: Occupational Air Sampling and Bioassay Monitoring Inspection Dates: September 13 & 14, 2023 Inspectors: Ryan Johnson, Utah Division Waste Management and Radiation Control (DWMRC) Phil Goble, DWMRC
Personnel Contacted: Garrin Palmer, Radiation Safety Officer (RSO)
Justin Perkins, Radiation Safety Technician (RST) 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 staff reminded the inspector of the safety requirements for the Mill. During the opening meeting the RSO self-identified that the documentation for the bioassay prep room surveys for 2022 was missing.

DRC Meters Used Model Serial Number Calibration Due Date
Dose Rate Bicron B789W 6/11/2024

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Inspection Summary The inspection consisted of an RSO interview, reviewing applicable documentation and a mill tour. The
following discussion provides more detail of the specific items reviewed.
Item 1. Documentation Review: The Inspector reviewed applicable documentation.
Observations: The DWMRC inspector reviewed the following documents:
•Calibration sheets for general area and breathing zone sample pumps;
•General area air sampling worksheets;
•Breathing zone sampling worksheets; and
•Bioassay analytical results and chain of custody forms.
While reviewing the paperwork for breathing zone sampling, the inspector noticed that the derived air concentration (DAC) values being recorded were lower than in previous years. The DAC values observed in 2022 ranged between 0 and 1,577% DAC. These DAC values are higher than last year but lower than years when the Mill is processing ore. The Mill did not processed a lot of ore (natural and alternate feed) in 2022.
The work (i.e. cleaning out tanks) at the Mill has been done under Radiation Work Permits (RWPs) or according to Standard Operating Procedures (SOPs). The inspector verified that:
•Respirator protection was being used by the mill personnel performing the work;
•Bioassay samples were being collected from the mill personnel performing the work;
•Bioassay results indicated that the mill personnel were not inhaling uranium; and
•Bioassay sampling and analysis standard operating procedure (SOP) was being followed.
The Mill analyzes its bioassay samples in its own lab. While reviewing the paperwork for the bioassay
results the inspector noticed that only one or two bioassay samples were above the Mill’s action level in 2022. Most samples were non-detect during this time. The Inspector verified:
•The Laboratory follows a procedure that uses ANSI/HPS N1330-2011 Performance Criteria for
Radiobioassay as a guide (which is referenced in NRC Regulatory Guide 8.22 Bioassay at UraniumMills);
•Results are reviewed by the Laboratory Technician and given to the RSO;
•25% of the samples are sent to an offsite laboratory as a quality control check;
•The sample preparation area is regularly surveyed for Alpha to prevent contamination of thesamples. Documentation for this survey was missing for 2022; and
•There was one bioassay sample above the Mill’s action level. The Mill appropriately documentedthe incident that resulted in the higher bioassay result, resampled and followed their procedures.
Deficiencies: During the opening meeting the RSO self-identified that the documentation for the bioassay sample preparation area alpha surveys were missing. However, most of the bioassay sample results were very low to non-detect. So possible cross contamination from the bioassay prep area is unlikely.
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 alternate feed circuit, solvent extraction building and the tailing impoundments.
Observations: The DWMRC inspector also observed:
•Ore and Alternate feed material being stored on the ore pad; and
•OSL badges were appropriately being used by all observed employees at the Mill.
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Radiological readings observed during Mill tour. Location Dose Rate (µrem/hr) Product Yard 30
Ore Pad 150
Silmet Alternate Feed 3,000-4,000
Chemours 3,000-4,000
Mill 200 Solvent Extraction Building 30 Alternate Feed Circuit 10-15Tank #7 5,000
Tank #5 5,000-11,000
Deficiencies: None
Item 3. RAM License
Equipment on back order and so they are not set up.
Deficiencies: None
Closeout Meeting Energy Fuels: Garrin Palmer (RSO)
Utah DWMRC: Ryan Johnson (Health Physics Inspector)
Findings
Missing documentation for the bioassay sample preparation area Alpha surveys. As per R313-14-15, the Mill provided corrective actions in a letter submitted September 29, 2023 (see Attached). The Inspector reviewed the and found them to be adequate to address the deficiency.
Recommendations None
Recommendation for Next Inspection
During the next time this inspection is done in 2024 confirm that the corrective actions are being done.
Prepared By: Ryan Johnson
(Print Name) (Signature) (Date)
Reviewed By: Phil Goble
(Print Name) (Signature) (Date)
10/2/2023
10/2/2023
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
September 29, 2023
Sent VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Re: White Mesa Uranium Mill – Notice of Self-Identified Violation
Dear Mr. Hansen:
Pursuant to Utah Administrative Code R313-14-15, Energy Fuels Resources (USA) Inc.
(“EFRI”), as operator of the White Mesa Mill (the “Mill”), is hereby providing written
documentation of a Self-Identified Violation (“SIV”).
1.Summary of the Incident
a)The Mill’s Radioactive Materials License (“RML”) Number UT1900479, Section 9.6
requires that “Standard operating procedures (SOPs) shall be established and followed for
all operational and non-operational activities involving radioactive material.”
b)The Mill’s Radiation Protection Manual is an SOP as contemplated by RML Section 9.6.
Section 1, part 1.4.3 of the Mill’s Radiation Protection Manual (“RPM”) requires that
“Sample preparation [of bioassay samples] will be done in an area decontaminated to less
than 25 dpm alpha (removable) per 100 cm2 prior to preparation of samples.”
c)The Mill’s RML, Section 11.1 requires that “The results of sampling, analyses, surveys
and monitoring, the results of calibration of equipment, reports on audits and inspections,
all meetings and training courses required by this license and any subsequent reviews,
investigations, and corrective actions, shall be documented. Unless otherwise specified in
the State of Utah regulations all such documentation shall be maintained for a period of at
least five (5) years.”
d)The bioassay preparation areas at the Mill were scanned in 2022 as required by Section 1,
part 1.4.3 of the Mill’s RPM and the scans were documented in accordance with Section
11.1 of the Mill’s RML and maintained at least through April 2023.
Letter To Doug Hansen
September 29, 2023
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e) The State of Utah Division of Waste Management and Radiation Control (“DWMRC”)
reviewed the 2022 alpha scans of the bioassay preparation areas in April 2023. All
documentation was present at the time of the DWMRC inspection.

f) EFRI Corporate staff performed the Mill site visit for its annual calendar year (“cy”) 2022
Mill ALARA Audit during the week of April 11, 2023, with the audit finalized in
September 2023. In connection with this ALARA Audit the Mill’s Radiation Safety Officer
(“RSO”) noted that the 2022 alpha scan documentation for the bioassay preparation areas
was misplaced – likely misfiled after the April 2023 DWMRC inspection – thereby
identifying this non-compliance with Section 11.1 of the RML and the need to make this
SIV filing.

g) It is important to note that the alpha scans did not show any contamination or erroneous
results resulting from contamination per the DWMRC inspection and per the RSO periodic
reviews of the scans and data throughout cy 2022.

h) The SIV is the inability to evidence at this time that we have maintained the documentation
of the alpha scan records for five years as required by Section 11.1 of the RML because
the records have apparently been misplaced or lost.

2. Root Cause

The root cause of the missing cy 2022 documentation was likely misfiling of the documents after
the DWMRC inspection. This SIV is not a violation that could reasonably be expected to have
been prevented by the Mill’s corrective action for a previous violation.

3. Steps Taken to Prevent a Recurrence

Upon noting the missing cy 2022 documentation, the RSO took control of the 2023 cy
documentation. The cy 2023 documentation was reviewed and noted as being complete. As noted
above, the ALARA Audit formally documented that the cy 2022 data had been misplaced or lost.
The ALARA Audit (finalized September 12, 2023) recommended scanning hardcopy records to
prevent recurrence. In lieu of scanning hardcopy records, the RSO has directed all Radiation Safety
Staff to record the alpha scans directly into a spreadsheet using a computer in the preparation
laboratory. Hardcopies of documentation will not be maintained. The spreadsheet and associated
data can be printed for inspection purposes and will eliminate the misfiling/loss of paper records.
EFRI is satisfied that the Mill has controls in place to ensure that scanned and digitally recorded
data will be adequately backed up and will not be lost, which will prevent recurrence.

4. Severity Level for the Incident

Based on the definitions of severity levels in Utah Administrative Code R313-14-10, EFRI
believes this incident is severity level V, defined as a minor safety or environmental concern. The
required scans were taken, documented and maintained at least through the April 2023 DWMRC
inspection in accordance with RML Section 9.6, RPM Section 1, part 1.4.3 and RML Section 11.1.
Letter To Doug Hansen
September 29, 2023
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The documentation of the scans provided definitive proof that there were no contamination
concerns related to bioassay results in 2022, as verified by the April 2023 DWMRC inspection.
Had there been a contamination concern and scan results had been higher than the allowable limit
specified in Regulatory Guide 8.31, Radiation Safety Staff would not have proceeded with the
preparation of the bioassay samples. The area would have been decontaminated and the scan
process repeated prior to the preparation of samples. No critical, bioassay results would have been
impacted or contaminated prior to analysis. The misfiled or lost documents represent a document
retention issue, not a data or health and safety issue.

If you should have any questions regarding this notice, please contact me.

Yours very truly,

ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Director, Regulatory Compliance

CC: David Frydenlund
Logan Shumway
Scott Bakken
Garrin Palmer
Tanner Holliday
Jordan App