DRC-2013-003919 - 0901a068803f6dff

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State of Utah
GARY R HERBERT
Governor
SPENCER J COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2013-003919
December 19,2013
Jo Ann S. Tischler, Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Radioactive Material License No. UT1900479 & ^ \ {\\
2013 Radiation Protection Inspection, Module Emergency-Q^ \ll
Dear Ms. Tischler:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on December 4,2013 by a representative of the Division of Radiation Control (DRC), Utah Department of
Environmental Quality.
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Materials License Number UT 1900479. The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector.
The activities and practices reviewed during the inspection with respect to the Emergency Response Plan
were found to be in compliance with relevant requirements. Observations, suggestions, and
recommendations for your consideration are included in the enclosed Inspection Report.
As always, your staff at the mill was very accommodating during the performance of this inspection.
If you have any question, please contact Boyd Imai at [phone].
Sincerely,
Rusty Lundberg, Director
RL/BMI:bi
Enclosure
cc/enc: David Turk, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City, UT
Mailing Address- P.O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone]-TDD (801) 536^414
www deq utah gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module; RADMOD-Emergency-02^
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): December 4, 2013
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Daniel Hillsten, Ronnie Nieves, Wayne Palmer, David Turk
Inspection Summary
The inspection was opened on December 4, 2013 with a meeting with D. Hillsten, R. Nieves, and
Dave Turk. Kevin Carney from the DRC was also in attendance.
Areas inspected included:
• Emergency Response Plan
• Evacuation/Fire Drill
The inspector held a closeout meeting on December 4,2013 to conclude the inspection.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Emergency Response Plan
The objective of this inspection was to ensure that the Licensee's Emergency Response Plan
contained all the elements required by R313-22-32(8).
The Licensee provided the inspector with a copy of the "Emergency Response Plan" Revision
2.4, October 5, 2012.
A review showed that the plan addresses the requirements item by item set forth in the rule.
Items in the plan include:
• Facility Description
• Types of Potential Accidents
• Classification of Accidents
• Accident Detection
• Mitigation of Consequences
Page 1 of 4
U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-Emergency-01\lnspectionReportRevO doc
• Release Assessments
• Responsibilities
• Notification and Coordination
• Training
• Safe Shutdown
• Exercises and Drills
Types of accident scenarios, descriptions, and prescribed responses are contained in the
Appendices (A through I) of the plan.
If an incident occurs, mill personnel inform the corporate office with the details of the incident
who in turn notifies the DRC as required. The DRC confirmed that notifications are made
through the Denver, CO office.
Biennial exercises are conducted. The last one was conducted on November 15,2013 and the
previous one was held on July 28, 2011. Typically, the Licensee is a participant in a multi-
organizational exercise. Exercises may take place on or off the mill site. Critiques are prepared.
The critique of the 2011 exercise was not forwarded to the Licensee and the critique for the 2013
exercise had yet to be completed.
Emergency Evacuation Drill
Emergency evacuations drills are conducted quarterly at the mill. The Licensee proposed to
conduct the drill for the current quarter during the inspection for observation.
To initiate a drill the emergency fire and evacuation alarm is simply activated. However, the
alarm system was inoperable when an attempt was made to activate it. After two attempts
technical personnel were summoned who quickly diagnosed and corrected the problem and the
drill commenced.
Multiple assembly points are designated for efficient evacuation for all workers, e.g. workers
near the scalehouse can evacuate at that location whereas most other workers assemble at the
main front gate. Other assembly points are designated for upwind evacuation purposes.
All personnel on the premises were accounted for and the drill was terminated having noted the
time required (4 minutes, 1031 hr to 1035 hr) to complete the evacuation.
The inspector noted that the alarm was neither visible nor audible in the administration building
training room. When asked, the laboratory personnel indicated that the outside siren was audible
inside the laboratory.
Supervisors ensure all personnel for whom they are responsible have evacuated the area. Color
coded hardhats are a quick method supervisors use to identify and count their employees. They
report to the evacuation coordinator when all their personnel are accounted for.
Page 2 of 4
U \MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\2013\Radmod-Emergency-01\InspectionReportRev0 doc
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, R. Nieves, and D. Turk of Energy Fuels
Resources (USA) on December 4, 2013. Also in attendance was K. Carney of the DRC.
The inspector pointed out that the Emergency Response Plan had two sections numbered "2.1,"
one found on page 14 entitled Description of Postulated Accidents and the second on page 24,
Detection of Accidents.
Multiple appendices with the same letter designations were also contained in the Emergency
Response Plan binder which can cause some confusion when the appendices are referenced in the
text of the plan.
It was suggested that Emergency Response Guide (2008) attachments to the plan be updated to
the most current version of the guide.
The temporarily inoperable alarm during the evacuation drill was discussed. It was determined
that the alarm was deactivated while maintenance was being performed on other systems and
there was a failure to reactivate it when the maintenance work had been completed. It was
estimated that the alarm system was out of service for about two weeks prior to the drill. When it
was suggested that this might be a compliance issue, D. Turk interjected that the purpose of the
drills is to identify such problems and to correct them and is exactly what was accomplished. D.
Hillsten directed D. Turk to implement a means of notification where responsible parties will
receive confirmation whenever the alarm system is reactivated following a period of
deactivation.
The inspector observed that counting different colored hardhats is a quick and efficient way to
get a count of personnel during an evacuation; however, there is a risk of misidentifying
personnel if sole reliance is based on the color of hats being worn resulting in a failure to get a
true accounting of all personnel. A visitor donning a colored hardhat similar to that of a
workgroup could be doubled counted and a regular employee may unknowingly be left
unaccounted for. The Licensee promptly dismissed this concern, stating that the workforce is
small and that the supervisors/foremen know where all their staff is located at all times.
It was recommended that the Licensee obtain the critique from the July 28, 2011 emergency
response exercise and address any problems or issues identified in the report. The Licensee
should do the same for the November 2013 exercise.
The Licensee committed to revise the procedures to clarify that when an incident occurs, the mill
site will notify the corporate office which will make the necessary notifications to the DRC.
Note: The issue with the alarm system was researched following the inspection. It is not
definitive which agency, Mine Safety and Health Administration (MSHA) or Occupational
Safety and Health Administration (OSHA) has jurisdiction over the matter. Nevertheless, both
indicate that an operable system must be in place. However, since the scheduled drill identified
the problem, it was immediately remedied, there was no adverse consequence to the temporarily
Page 3 of4
U \MON_WAST\Bjrnai\vvp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-Ernergency-01\InspectionReportRevO doc
by-passed system, and actions to prevent recurrence were initiated during the inspection, no
action by the DRC should be necessary in this regard.
Recommendations for future Inspections
• Assess the methods implemented by the Licensee to ensure that the emergency alarm
system is returned to operable status following any planned shutoff of the system.
• Verify that planned emergency response exercises are critiqued and that the Licensee is
reviewing the critique and is addressing any relevant issues identified regarding the
Licensee's role in the exercises.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai fSfyJ/Uut'u^~- December 18,2013
(Name) ^(Signature) (Date)
Page 4 of 4
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•
Inspection Report
ana
RADMOD-Emeroency-02 Checklist
INSPECTION REPORT
Inspection Module: RADMOD-Emer]
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): December 4, 2013
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Daniel Hillsten, Ronnie Nieves, Wayne Palmer, David Turk
Inspection Summary
The inspection was opened on December 4, 2013 with a meeting with D. Hillsten, R. Nieves, and
Dave Turk. Kevin Carney from the DRC was also in attendance.
Areas inspected included:
• Emergency Response Plan
• Evacuation/Fire Drill •
The inspector held a closeout meeting on December 4, 2013 to conclude the inspection.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Emergency Response Plan
The objective of this inspection was to ensure that the Licensee's Emergency Response Plan
contained all the elements required by R313-22-32(8).
The Licensee provided the inspector with a copy of the "Emergency Response Plan" Revision
2.4, October 5,2012.
A review showed that the plan addresses the requirements item by item set forth in the rule.
Items in the plan include:
• Facility Description
• Types of Potential Accidents
• Classification of Accidents
• Accident Detection
• Mitigation of Consequences
Page 1 of 4
U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-Emergency-01\InspectionReportRevO doc
• Release Assessments
• Responsibilities
• Notification and Coordination
• Training
• Safe Shutdown
• Exercises and Drills
Types of accident scenarios, descriptions, and prescribed responses are contained in the
Appendices (A through I) of the plan.
If an incident occurs, mill personnel inform the corporate office with the details of the incident
who in turn notifies the DRC as required. The DRC confirmed that notifications are made
through the Denver, CO office.
Biennial exercises are conducted. The last one was conducted on November 15, 2013 and the
previous one was held on July 28, 2011. Typically, the Licensee is a participant in a multi-
organizational exercise. Exercises may take place on or off the mill site. Critiques are prepared.
The critique of the 2011 exercise was not forwarded to the Licensee and the critique for the 2013
exercise had yet to be completed.
Emergency Evacuation Drill
Emergency evacuations drills are conducted quarterly at the mill. The Licensee proposed to
conduct the drill for the current quarter during the inspection for observation.
To initiate a drill the emergency fire and evacuation alarm is simply activated. However, the
alarm system was inoperable when an attempt was made to activate it. After two attempts
technical personnel were summoned who quickly diagnosed and corrected the problem and the
drill commenced.
Multiple assembly points are designated for efficient evacuation for all workers, e.g. workers
near the scalehouse can evacuate at that location whereas most other workers assemble at the
main front gate. Other assembly points are designated for upwind evacuation purposes.
All personnel on the premises were accounted for and the drill was terminated having noted the
time required (4 minutes, 1031 hr to 1035 hr) to complete the evacuation.
The inspector noted that the alarm was neither visible nor audible in the administration building
training room. When asked, the laboratory personnel indicated that the outside siren was audible
inside the laboratory.
Supervisors ensure all personnel for whom they are responsible have evacuated the area. Color
coded hardhats are a quick method supervisors use to identify and count their employees. They
report to the evacuation coordinator when all their personnel are accounted for.
Page 2 of 4
U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-Emergency-01\InspectionReportRevO doc
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten, R. Nieves, and D. Turk of Energy Fuels
Resources (USA) on December 4, 2013. Also in attendance was K. Carney of the DRC.
The inspector pointed out that the Emergency Response Plan had two sections numbered "2.1,"
one found on page 14 entitled Description of Postulated Accidents and the second on page 24,
Detection of Accidents.
Multiple appendices with the same letter designations were also contained in the Emergency
Response Plan binder which can cause some confusion when the appendices are referenced in the
text of the plan.
It was suggested that Emergency Response Guide (2008) attachments to the plan be updated to
the most current version of the guide.
The temporarily inoperable alarm during the evacuation drill was discussed. It was determined
that the alarm was deactivated while maintenance was being performed on other systems and
there was a failure to reactivate it when the maintenance work had been completed. It was
estimated that the alarm system was out of service for about two weeks prior to the drill. When it
was suggested that this might be a compliance issue, D. Turk interjected that the purpose of the
drills is to identify such problems and to correct them and is exactly what was accomplished. D.
Hillsten directed D. Turk to implement a means of notification where responsible parties will
receive confirmation whenever the alarm system is reactivated following a period of
deactivation.
The inspector observed that counting different colored hardhats is a quick and efficient way to
get a count of personnel during an evacuation; however, there is a risk of misidentifying
personnel if sole reliance is based on the color of hats being worn resulting in a failure to get a
true accounting of all personnel. A visitor donning a colored hardhat similar to that of a
workgroup could be doubled counted and a regular employee may unknowingly be left
unaccounted for. The Licensee promptly dismissed this concern, stating that the workforce is
small and that the supervisors/foremen know where all their staff is located at all times.
It was recommended that the Licensee obtain the critique from the July 28,2011 emergency
response exercise and address any problems or issues identified in the report. The Licensee
should do the same for the November 2013 exercise.
The Licensee committed to revise the procedures to clarify that when an incident occurs, the mill
site will notify the corporate office which will make the necessary notifications to the DRC.
Note: The issue with the alarm system was researched following the inspection. It is not
definitive which agency, Mine Safety and Health Administration (MSHA) or Occupational
Safety and Health Administration (OSHA) has jurisdiction over the matter. Nevertheless, both
indicate that an operable system must be in place. However, since the scheduled drill identified
the problem, it was immediately remedied, there was no adverse consequence to the temporarily
Page 3 of 4
U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-Ernergency-01\InspectionReportRevO doc
by-passed system, and actions to prevent recurrence were initiated during the inspection, no
action by the DRC should be necessary in this regard.
Recommendations for future Inspections
• Assess the methods implemented by the Licensee to ensure that the emergency alarm
system is returned to operable status following any planned shutoff of the system.
• Verify that planned emergency response exercises are critiqued and that the Licensee is
reviewing the critique and is addressing any relevant issues identified regarding the
Licensee's role in the exercises.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai
(Name) (Signature)
December 18,2013
(Date)
Page 4 of 4
U \MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2013\Radmod-Emergency-01\InspectionReportRevO doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-Emergency-01
EMERGENCY PLAN
ENERGY FUELS RESOURCES- WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Utah Administrative Code R313-22
DATE btre. *ff 2o/*>
OPENING MEETING
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
U \COMMON\Uranium millsU le(2)UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-Emergency-01rev02 doc
Page 1 of9
WHITE MESA MILL
FIRE/EVACUATION DRILL
Date: D^C H, 2,0<3 Time: jp: 3V
Conducted By:
Did the Sirens work? ^) N How long did it take to evacuate? fee
Department Check-Off
Maintenance: lO^M Operations: \^"hC Labor: [0'^ Office: \0 ; 33
_ Comments
ryy Wo* "Tried bojr du£ i/\gnr lO<?v-U_, iRcjaw k|ou(Af
O-WirKA <L\c^ tAU-fc- g.\^iAtft b^X-txxcu "fr-* i/w*u»i cxlarv^ W&.d pee*
A
fit**, ^IAA^W-I^ ^Ulrwv oVx^lc^ ^ ^ Wvdd. .
DISCUSSION
SITE STAFF COMMENTS
R313-22-32. Filing Application for Specific Licenses.
(8)(a) Applications to possess radioactive materials in unsealed form, on foils or plated sources, or sealed
in glass in excess of the quantities in Section R313-22-90, "Quantities of Radioactive Materials Requiring
Consideration of the Need for an Emergency Plan for Responding to a Release", shall contain either:
(i) An evaluation showing that the maximum dose to an individual off-site due to a release of radioactive
materials would not exceed one rem effective dose equivalent or five rems to the thyroid; or
(ii) An emergency plan for responding to a release of radioactive material.
(c) An emergency plan for responding to a release of radioactive material submitted under Subsection
R313-22-32(8)(a)(ii) shall include the following information:
(i) Facility description. A brief description of the licensee's facility and area near the site.
(ii) Types of accidents. An identification of each type of radioactive materials accident for which
protective actions may be needed.
U \COMMON\Uranium millsU le(2)UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-Emergency-01rev02 doc
Page 2 of9
(iii) Classification of accidents. A classification system for classifying accidents as alerts or site area
emergencies.
(iv) Detection of accidents. Identification of the means of detecting each type of accident in a timely
manner.
(v) Mitigation of consequences. A brief description of the means and equipment for mitigating the
consequences of each type of accident, including those provided to protect workers on-site, and a
description of the program for maintaining equipment.
(vi) Assessment of releases. A brief description of the methods and equipment to assess releases of
radioactive materials.
(vii) Responsibilities. A brief description of the responsibilities of licensee personnel should an accident
occur, including identification of personnel responsible for promptly notifying off-site response
organizations and the Executive Secretary; also responsibilities for developing, maintaining, and updating
the plan.
(viii) Notification and coordination. A commitment to and a brief description of the means to promptly
notify off-site response organizations and request off-site assistance, including medical assistance for the
treatment of contaminated injured on-site workers when appropriate. A control point shall be established.
The notification and coordination shall be planned so that unavailability of some personnel, parts of the
facility, and some equipment will not prevent the notification and coordination. The licensee shall also
commit to notify the Executive Secretary immediately after notification of the appropriate off-site
response organizations and not later than one hour after the licensee declares an emergency.
NOTE: These reporting requirements do not supersede or release licensees of complying with the
requirements under the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Public
Law 99-499 or other state or federal reporting requirements, including 40 CFR 302, 2005 ed.
(ix) Information to be communicated. A brief description of the types of information on facility status,
radioactive releases, and recommended protective actions, if necessary, to be given to off-site response
organizations and to the Executive Secretary.
(x) Training. A brief description of the frequency, performance objectives and plans for the training that
the licensee will provide workers on how to respond to an emergency including special instructions and
orientation tours the licensee would offer to fire, police, medical and other emergency personnel. The
training shall familiarize personnel with site-specific emergency procedures. Also, the training shall
thoroughly prepare site personnel for their responsibilities in the event of accident scenarios postulated as
most probable for the specific site including the use of team training for the scenarios.
(xi) Safe shutdown. A brief description of the means of restoring the facility to a safe condition after an
accident.
(xii) Exercises. Provisions for conducting quarterly communications checks with off-site response
organizations and biennial on-site exercises to test response to simulated emergencies. Quarterly
communications checks with off-site response organizations shall include the check and update of all
necessary telephone numbers. The licensee shall invite off-site response organizations to participate in the
biennial exercises. Participation of off-site response organizations in biennial exercises although
recommended is not required. Exercises shall use accident scenarios postulated as most probable for the
specific site and the scenarios shall not be known to most exercise participants. The licensee shall critique
each exercise using individuals not having direct implementation responsibility for the plan. Critiques of
exercises shall evaluate the appropriateness of the plan, emergency procedures, facilities, equipment,
training of personnel, and overall effectiveness of the response. Deficiencies found by the critiques shall
be corrected.
(xiii) Hazardous chemicals. A certification that the applicant has met its responsibilities under the
Emergency Planning and Community Right-to-Know Act of 1986, Title III, Public Law 99-499, if
applicable to the applicant's activities at the proposed place of use of the radioactive material.
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Page 3 of9
(d) The licensee shall allow the off-site response organizations expected to respond in case of an accident
60 days to comment on the licensee's emergency plan before submitting it to the Executive Secretary. The
licensee shall provide any comments received within the 60 days to the Executive Secretary with the
emergency plan.
1) Does the Licensee have an emergency plan for responding to a release of radioactive material?
Comments: Yes X No
2) Does the emergency plan contain a facility description? (A brief description of the licensee's facility
and area near the site.)
Comments: Yes )C No
3) Type of Accidents—Does the emergency plan identify each type of radioactive materials accident for
which protective actions may be needed?
Comments: Yes )C No
z. -rypc 3 of AccjoeJoTS.
4) Classification of accidents. Does the emergency plan have a classification system for classifying
accidents as alerts or site area emergencies?
Comments: Yes ^- No
5
i - 3JWv
5) Detection of accidents. Does the emergency plan identify the means of detecting each type of accident
in a timely manner?
Comments: f Yes Y No
£2-*-^
6) Mitigation of consequences. Does the emergency plan provide a brief description of the means and
equipment for mitigating the consequences of each type of accident, including those provided to protect
workers on-site, and a description of the program for maintaining equipment?
Comments: Yes yf No
^y^J^ca^ A - 31
U \COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-Emergency-01rev02 doc
Page 4 of 9
7) Assessment of releases. Does the emergency plan provide a brief description of the methods and
equipment to assess releases of radioactive materials?
Comments: Yes yC No
A - r
8) Responsibilities. Does the emergency plan provide a brief description of the responsibilities of licensee
personnel should an accident occur, including identification of personnel responsible for promptly
notifying off-site response organizations and the Executive Secretary; also responsibilities for developing,
maintaining, and updating the plan?
Comments: Yes X No
9) Notification and coordination. Does the emergency plan provide a commitment to and a brief
description of the means to promptly notify off-site response organizations and request off-site assistance,
including medical assistance for the treatment of contaminated injured on-site workers when appropriate.
A control point shall be established. The notification and coordination shall be planned so that
unavailability of some personnel, parts of the facility, and some equipment will not prevent the
notification and coordination. The licensee shall also commit to notify the Director of Radiation Control
immediately after notification of the appropriate off-site response organizations and not later than one
hour after the licensee declares an emergency.
Comments: Yes )c No
10) Information to be communicated. Does the emergency plan contain a brief description of the types of
information on facility status, radioactive releases, and recommended protective actions, if necessary, to
be given to off-site response organizations and to the Director of Radiation Control?
Comments: Yes No
11) Training. Does the emergency plan contain a brief description of the frequency, performance
objectives and plans for the training that the licensee will provide workers on how to respond to an
emergency including special instructions and orientation tours the licensee would offer to fire, police,
U \COMMON\Uranium nullsU le(2)UTl 900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-Emergency-01rev02 doc
Page 5 of9
•
medical and other emergency personnel? Does the training familiarize personnel with site-specific
emergency procedures? Does the training thoroughly prepare site personnel for their responsibilities in
the event of accident scenarios postulated as most probable for the specific site including the use of team
training for the scenarios?
Comments: / . Yes No ommenis: /
12) Safe shutdown. Does the emergency plan contain a brief description of the means of restoring the
facility to a safe condition after an accident?
Comments: Yes No
13a) Exercises. Does the emergency plan contain provisions for conducting quarterly communications
checks with off-site response organizations and biennial on-site exercises to test response to simulated
emergencies?
Comments: Yes No
13b) Exercises. Does the emergency plan provide for quarterly communications checks with off-site
response organizations that include the check and update of all necessary telephone numbers?
Comments: Yes No
13c) Exercises. Does the emergency plan require that the licensee invite off-site response organizations to
participate in the biennial exercises? (Participation of off-site response organizations in biennial eve.rdses
although recommended is not required.)
Comments: Yes No
13d) Exercises. Do exercises use accident scenarios postulated as most probable for the specific site?
Comments: Yes }^ No
1
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Page 6 of9
13e) Exercises. Does the licensee critique each exercise using individuals not having direct
implementation responsibility for the plan?
Comments: Yes No
13f) Exercises. Do critiques of exercises evaluate the appropriateness of the plan, emergency procedures,
facilities, equipment, training of personnel, and overall effectiveness of the response?
Comments: Yes No
13g) Exercises. Are deficiencies found by the critiques corrected?
Cornments: « . Yes No
General Comments and Observations:
1
MX. ^JLo
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Page 7 of9
DATE 4 2^>rx
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
roster'
U \COMMON\Uranium raillsM le(2)UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-Emergency-01rev02 doc
Page 8 of9
v
DISCUSSION of FINDINGS
SITE STAFF COMMENTS
ium<^ , a la,
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Page 9 of9
Biennial
Emergency Response
Exercises
«3 Of* Operation'
MSELDF
Number From To Inject Evaluation Point Comment/Notes
Pre-exercise Oecon shower and staff are dressed out and givenlujst in time training on decon process
Shower and materials will be staged and ready prior to STARTExj
Determine who is responsible for set up
of decon and materials gathering
STARTEX
A traffic accident involving a tanker truck and two passenger vehicles occurs on Highway 191 at (Location).
Blue Mountain Hospital learns of the accident through monitoring emergency dispatch. Limited information
is available immediately. ^ ^^^^ Please choose a location for the "scene".
SimCell -
EMS On-
Scene ED
BMH receives notification to expect multiple victims from the crash Two red (one with a spinal injury), 2
Yellow, and 4 Green All victims are experiencing effects from exposure to sulfuric acid including skin burns
and irritation to respiratory system
Expected action- Charge Nurse
activates EOP Code Orange and
announces over loud speaker
How much lead time do you typically get
for pts inbound? Do you need us to
provide sufunc acid MSDS sheets?
Charge
Nurse/IC Activate Hospital Command Center and Call Tree.
Charge Nurse will serve as IC until
Safety or Admissions takes over
Evaluation Point' How many staff are
able to come in?
Some staff are afraid to into work for fear of exposure What is the policy for staff to be recalled during a
disaster?
Conduct initial HCC situation briefing
Situation report, initial incident
objectives, and staffing assignments
(Exercise artificiality: Technical Decon will
be performed on all patients, set up prior
to StartEx)
Communication from HCC to outside partners and floors about situation status
Evaluate information flow to/from IC
Expected action: patient census report
from each floor, and supply assessment
Security Security to lockdown hospital and request local law enforcement resources as needed.
10
Decon
Team First patient arrives at the ED entrance by ambulance RED1
Evaluate communication between
scene and hospital to determine level
of decon completed on scene. Need to provide patient card
11
Decon
Team Patient is non-ambulatory and hospital performs technical decon.
Appropriate decon procedures are
followed.
12
Admission
Patients associated with the accident should be designated as disaster victims and use paper charting.
Evaluate how this is decided and
communicated
13 IC will need to determine how to gather information from Decon team.
14
Decon
Team RED2 patient arrives by ambulance. Need to provide patient card
15
Hospital
Front
Entrance
Man arrives by personal vehicle with his young daughter to the front entrance of the hospital. He insists that
his daughter be seen immediately and is concerned that he drove by the accident Both father and daughter
are not experiencing any symptoms of exposure. Need to provide patient card
16 HCC Huddle/SitRep - Will surge plan need to be activated? What staffing levels are needed on floors?
Contact Eagle Air Med, nursing home
and other partners to get census data
17
Decon
Team YELLOW1 and YELLOW2 patients arrive by ambulance ** Need to provide patient card
18
Decon
Team GREEN1 patient arrives by personal vehicle to ED entrance Patient has not undergone gross decon
Evaluation point How does procedure
change if not gross deconed on scene? Need to provide patient card
19 Floor staff
YELLOW2 wants to know where her wedding ring is They took it off during decon. She is getting distraught
and asking all the staff when she will get it back How will the staff on the floors answer her questions?
What happens to contaminated belongings7
20
Decon
Team YELLOW3 and YELLOW4 patients arrive by ambulance Patient YELLOW 4 goes into cardiac arrest in ED. Need to provide patient card
Operation Walking Dead
MSEL DRAFT 11-1-13
Number From To Inject Evaluation Point Comment/Notes
Mini Check in with Lab, Radiology, MedSurge, Admissions, Blood Bank, Facilities, Security
Evaluation point: What role/function
does this department have during a
disaster'
*** Create evaluation sheet for each
department
21 ED Additional blood supplies are requested by the ED.
22
Decon
Team
How is monitoring of decon staff taking place? Who is responsible for staff safety? Can additional staff be
used from Fire Department? How would they be requested?
23 Called in staff are arriving at all entrances. How will they be allowed into the building during lockdown?
24 HCC Huddle/SitRep
25
Husband of one of the patients arrives at the main entrance. Will he be allowed in the hospital during the
lockdown? Where can he find his wife?
26 ED
A rumor is heard in the ED that evacuations are being issued near the hospital because of the accident.
What is the shelter in place or evacuation plan for the hospital? What about power outages? Other areas of
the community are experiencing intermittent outages due to the crash near a transformer
Expected action Discussion with the
community partners on scene to gather
additional detail of situation.
27
GREEN2 Arrives by personal vehicle to the hospital parking lot. A staff member arriving from the call down
assists GREEN2 in the parking lot. What is protocol for contaminated staff member? Are there any HR
policies that are activated during this? Need to provide patient card
28
Decon
Team GREEN3 and GREEN4 patients arrive by ambulance Need to provide patient card
29
Decon
Team How does the decon team know the last patient has arrived?
30
Decon
Team Decon staff perform proper doffing of PPE and containment of contaminated materials
31 ENDEX
32 Post-Exercise All staff gather for walk through of decon process and tips and tricks
3
A
55
- J
4 3 ?7T
1
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life*
Blue Mountain Hospital Full-Scale Exercise
Final Planning Meeting Agenda
November 4,2013,3pm MST
I. Updates since Last Meeting
II. Outstanding Questions
a. Will the FD have "scene" set up?
b. Will EMS be transporting patients or will transport be simulated?
c. How will communication occur between the scene and the hospital? Do
we need to set up a separate radio channel? Will dispatch be involved in
the exercise?
III. Draft MSEL Review and Timeline
IV. Exercise Documents
a. Exercise Plan
b. Master Scenario Events List (MSEL)
c. EEGs
d. Participant Handout
e. Participant Feedback Form
f. Patient Cards
g. Communications Plan
V. Next Steps
81 ALL CLEAR
EMERGENCY MANAGEMENT GROUP
Emergencv^Rejoaosej^cercise
2011
Scenario: A tractor trailer carrying uranium oxide concentrate from the Denison Mines' White Mesa
facility, has wrecked on US Hwy 191. It has been reported that there has been diesel spilled from the
tractor and has started on fire. There are several 55-gallon drums that are lying out on the ground with
what appears to be yellowcake on the ground. The driver of the tractor is unresponsive and still inside
the cab.
Response: Deal with fire, injured driver and potential radioactive material spill. Clean up any spilled
material and have the scene cleared for normal traffic conditions.
Critique:
JJ-
1 <pL> \o}
Demson/wmes Blanding City Fire/and/Rescue San Juan County
David Turk
Sent:
To:
Cc:
Subject:
From: David Turk
Thursday, July 28, 2011 9:05 PM
David Frydenlund
Harold Roberts; Dan Hillsten; Jo Ann Tischler; A- Ron Hochstein
Emergency Response Exercise
Mr. Frydenlund,
We have just completed the Emergency Response Exercise with the off site EMS services. The scenario for the incident
was a wrecked tractor trailer carrying uranium concentrate materials. The tractor trailer was also surrounded by fire pits
that contained diesel and then set a blazed. We set up four drums filled with dirt to simulate the YC drums and then
had yellow corn meal spilled in areas to simulate a YC spill.
The exercise was attended by 25 individuals from various agencies around San Juan County and the Mill. Agencies that
responded for the event were: San Juan County Search and Rescue, San Juan County Emergency Response, Monticello
Fire Department, Bluff City Fire Department, Blanding City Fire Department, Blanding City Police Department, San Juan
County Ambulance and Denison Mines radiation and safety department personnel. There were 14 various pieces of
equipment that also arrived at the scene in support. The exercise was conducted on Denison Mines southern property.
The exercise started with a briefing before the event. After the briefing, the exercise started and confusion set in. In any
emergency situation, confusion usually is the first step until an Incident Commander is established. After that was taken
care of, the situation went fairly smoothly. The fires were extinguished, the driver was extracted from the vehicle and the
scene was secured. The contamination area was identified and decontamination was performed to free release standards
for the scene, emergency personnel and their equipment.
After the exercise was completed, a debriefing was held for all participating personnel. During the debriefing, areas of
concern dealing with the radioactive materials was discussed along with equipment that could have been used to
better facilitate the incident. There were several question raised about radiological contamination concerns and those
issued were addressed and I believe we eliminated some potential fear surrounding the Mill's product.
Overall I would have to say that the incident, for such short notice, was a tremendous success. Mr. Rick Bailey from the
San Juan County Emergency Response was very appreciative to Denison Mines for offering the exercise for the county's
response personnel and he stated he looks forwarded to the next exercise. We have been asked by a number of the
responding agencies if we could provide a tour of the facility and go over some of the additional chemical hazards that
may be encountered at the site in the event of an emergency. We have scheduled next Thursday at 1900 hours for any
of those agencies who would like to attend a brief chemical process overview and then tour of the facility and the various
areas where a chemical emergency could potentially occur.
We have asked the various agencies to critique the incident if they want so we can improve on the next exercise. If there
are any questions regarding this exercise just let me know.
Regards,
David
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4'. «I
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i
Training Records
a?
White
Feb-13 Apr-13 Jul-13 Name Jan-13 Mar-13 May-13 Jun-13 Aug-13 Sep-13 Oct-13 Nov-13 ev. 11/4/13 12-Dec
5/17/07 Armstrong, Launa 1/15/13 3/5/13 3/5/13 3/27/13 5/1/13 6/10/13 6/10/13 7/9/13 10/29/13 9076
Atcitty, Leron 8/11/97 1/15/13 1/24/13 3/4/13 3/28/13 5/3/13 6/10/13 6/10/13 7/15/13 8/22/13 10/2/13 10/30/13 0-0447
7/16/12 1/15/13 3/27/13 Atcitty, Roy 2/4/13 2/20/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/28/13 9987 9/26/13
twood, Matt 2/22/12 1/15/13 1/23/13 2/20/13 3/27/13 5/1/13 6/10/13 6/10/13 7/3/13 4814 8/21/13 10/1/13 10/29/13
Bailey, Amanda 6613 2/9/12 1/15/13 1/25/13 2/22/13 3/22/13 5/3/13 5/31/13 5/31/13 7/3/13 8/22/13 9/26/13 10/28/13
Bayles, Joel 9993 9/11/05 1/15/13 2/4/13 3/5/13 3/26/13 4/26/13 5/31/13 5/31/13 7/3/13 9/30/13 10/24/13
Beaver, David 2979 4/14/08 3/6/13 3/7/13 3/27/13 5/1/13 6/10/13 6/10/13 7/3/13 8/21/13 10/1/13 10/29/13
Begay, Tenaya 3419 2/15/10 1/15/13 1/25/13 2/22/13 5/3/13 5/31/13 5/31/13 7/12/13 10/1/13 10/29/13
Begaye, Shawn 6059 9/2/08 6/5/13 7/9/13 9/27/13 10/29/13
Benally, Jaymes 0-0586 10/18/07 1/23/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Benally, Jerome 3157 1/13/06 1/21/13 1/25/13 3/4/13 3/26/13 5/1/13 6,10/13 6/10/13 7/9/13 8/20/13 10/1/13 10/28/13
Benally, Johnson 4468 5/22/06 1/15/13 1/23/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 9/30/13 10/29/13
Bennett, Herschel 0-0918 2/22/06 1/5/13 2/4/13 2/20/13 4/1/13 5/3/13 6/4/13 6/4/13 7/12/13 8/25/13 10/2/13 10/25/13
Blackhorse, Tyrone 2207 6/19/06 1/15/13 1/24/13 2/20/13 3/27/13 5/1/13 6/6/13 6/6/13 7/3/13 8/21/13 10/1/13 10/29/13
Boy, Verdale 5888 6/28/10 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Brown, Ken 3690 4/2/12 3/27/13 4/26/13 5/31/13 5/31/13 7/3/13 8/21/13 10/1/13 10/25/13
Bunting, Tyler 7892 8/11/08 7/9/13 8/21/13 10/2/13 10/30/13
Carr, David 0-0637 11/30/09* 5/20/13 6/6/13 6/6/13 7/3/13 10/1/13 10/29/13
Charley, Marvin 3667 2/15/10 1/15/13 1/28/13 2/22/13 3/26/13 4/26/13 7/12/13 8/20/13 9/26/13 10/28/13
Christensen, Scot 9976 5/26/94 1/15/13 2/4/13 2/22/13 3/28/13 5/8/13 6/10/13 6/10/13 7/9/13 9/30/13 10/24/13
Clinger, Benjamin 0-0261 7/9/12 6/5/13 7/3/13 8/21/13 10/1/13 10/25/13
Cosby, Cody 6565 9/11/12 10/1/13 10/29/13
Dayish, Chuck 0-0910 12/22/11 12/10/12 2/4/13 2/20/13 4/1/13 5/3/13 6/4/13 6/4/13 7/12/13 8/21/13 9/27/13 10/28/13
Frisbie, Nathan 5749 3/8/12 2/28/13 3/26/13 4/26/13 6/6/13 6/6/13 7/3/13 9/26/13 10/28/13
Graf, Michelle 5591 6/7/10 3/27/13 5/3/13 6/4/13 6/4/13 7/3/13 8/20/13 10/2/13 10/29/13
Hancock, Wade 6517 5/26/94 1/15/13 3/6/13 2/20/13 10/30/13 5/1/13 6/5/13 6/5/13 7/3/13 10/30/13 10/30/13 10/29/13
Hathale, Randy 2918 4/14/08 1/16/13 1/25/13 3/4/13 3/28/13 4/26/13 5/31/13 5/31/13 7/12/13 9/27/13 10/30/13
Helquist, Steven 4181 3/8/12 1/23/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Hillsten, Dan 7172 1/5/12 1/15/13 3/5/13 2/22/13 3/27/13 5/8/13 6/4/13 6/4/13 7/12/13 8/21/13 9/27/13 10/29/13
Holliday, Tanner 4158 5/12/08 1/28/13 2/22/13 3/22/13 4/26/13 6/6/13 6/6/13 7/3/13 8/21/13 10/2/13 10/29/13
Holt, Thayne 5242 4/8/02 1/15/13 2/4/13 2/22/13 3/26/13 5/3/13 5/31/13 5/31/13 7/3/13 8/20/13 10/30/13
Imel, Noah 2176 1/11/10 2/20/13 3/27/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Joe, Gerald 0-0293 3/1/10 1/24/13 2/20/13 3/26/13 5/3/13 5/31/13 5/31/13 7/3/13 8/21/13 9/27/13 10/28/13
John, Terry 8364 2/1/10 1/15/13 1/25/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Jones, Christine 5915 3/10/06 1/15/13 1/25/13 3/4/13 3/28/13 5/1/13 5/31/13 5/31/13 7/3/13 8/20/13 10/24/13
Jones, Jeremy 1260 5/5/08 5/1/13 6/5/13 6/5/13 7/3/13 9/30/13 10/29/13
Jones, Kenneth 1419 9/2/08 1/15/13 1/23/13 2/20/13 3/27/13 5/1/13 6/6/13 6/6/13 8/21/13 10/1/13 10/29/13
nes, Sheridan 6650 8/13/12 9/7/13 7/13/01 8/21/13 11/4/13 11/4/13
Jones, Stan 3480 8/4/97 1/15/13 3/5/13 2/20/13 3/27/13 5/1/13 6/6/13 6/6/13 7/3/13 8/21/13 10/1/13 10/29/13
Jones, Sterling 7100 8/16/10 7/9/13 8/21/13 10/7/13 11/11/13
Kemnar, Paul 0-0086 2/28/11 1/25/13 2/20/13 4/1/13 5/3/13 6/6/13 6/6/13 7/12/13 9/26/13 10/28/13
Kreth, Tad 5162 5/14/12 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Lacy, David 2495 10/10/11 8/21/13 9/26/13 10/25/13
Lacy, Karson 7593 6/7/10 2/22/13 3/26/13 4/26/13 5/31/13 5/31/13 7/3/13 8/21/13 9/27/13 10/24/13
Lameman, Tully 8042 7/9/07 1/15/13 1/24/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/28/13
Latham, Heath 3414 12/22/11 11/30/12 1/28/13 2/22/13 3/27/13 5/3/13 5/31/13 5/31/13 7/9/13 8/21/13 9/27/13 10/24/13
Laws, James 3969 1/16/12 2/25/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 10/1/13 10/25/13
Laws, Darin 6531 7/27/07 1/23/13 2/20/13 3/27/13 5/8/13 6/6/13 6/6/13 7/3/13 8/21/13 10/1/13 10/29/13
Little, Tyrone 8175 12/8/11 11/28/12 1/23/13 2/20/13 3/27/13 5/8/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Lyman, David 5100 5/14/12 4/29/13 6/4/13 6/4/13 7/3/13 8/22/13 10/24/13
aryboy, Milfred 4245 10/27/05 3/28/13 4/26/13 5/31/13 5/31/13 7/9/13 8/20/13 9/27/13 10/30/13
endoza, Abel 2277 2/23/07 1/15/13 1/23/13 2/10/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Mendoza, Abel Jr 6328 10/1/13 10/28/13
Mendoza, Billy 2096 5/22/02 1/15/13 1/23/13 2/20/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Montella, Cortney 3702 10/22/07 1/15/13 1/24/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/25/13
Neal, Henry 7432 4/30/07 1/15/13 1/25/13 2/20/13 3/27/13 5/1/13 5/31/13 5/31/13 7/3/13 8/21/13 9/30/13 10/28/13
Nez, Kevin 7676 2/15/10 1/23/13 2/26/13 3/22/13 5/1/13 6/10/13 6/10/13 7/3/13 8/21/13 9/30/13 10/29/13
Nielson, Arden 8558 7/9/07 1/15/13 1/25/13 2/22/13 3/26/13 5/1/13 6/4/13 6/4/13 7/3/13 8/20/13 9/26/13 10/24/13
Nieves, Ronnie
O'Neil, Travis
Oshley, Truitt
8515
1056
6549
2/23/07
2/13/12
6/28/10
1/15/13
2/22/13
6/13/13
1/24/13 2/20/13 3/26/13
3/27/13
5/3/13
5/8/13
5/31/13
6/5/13
5/31/13
6/5/13
7/9/13
7/3/13
7/3/13
8/21/13
8/21/13
8/21/13
9/26/13
9/26/13
10/1/13
10/25/13
10/24/13
10/29/13
Palmer, Garnn 3184 2/15/10 1/15/13 2/5/13 2/22/13 3/22/13 4/26/13 6/10/13 6/10/13 7/3/13 8/21/13 10/2/13 10/29/13
Palmer, Wayne 0-0860 5/1/08 1/23/13 1/24/13 2/20/13 3/22/13 4/26/13 5/31/13 5/31/13 7/3/13 8/20/13 9/26/13 10/24/13
Perkims, Chad 9949 5/17/05 1/15/13 1/23/13 2/20/13 5/1/13 6/6/13 6/6/13 7/3/13 8/21/13 10/1/13 10/29/13
Perkins, Justin 4205 3/8/10 1/25/13 2/20/13 5/3/13 6/4/13 6/4/13 7/12/13 8/21/13 10/29/13
Plott, Travis 0-0088 5/17/11 6/5/13 7/3/13 10/1/13 10/29/13
Reed, Oustin 9544 7/31/12 7/9/13 8/20/13 9/26/13 10/24/13
Rentz, Phillip 0-0226 9/11/00 1/15/13 1/23/13 2/20/13 3/27/13 5/1/13 6/6/13 6/6/13 7/3/13 8/21/13 10/1/13 10/29/13
Shumway, Logan 4018 6/14/10 6/10/13 7/3/13 9/26/13 10/28/13
Singer, Casey 6164 8/15/11? 7/3/13 8/20/13 9/30/13 10/24/13
Slade, Terry 6688 5/26/94 1/15/13 1/24/13 2/20/13 3/27/13 5/1/13 6/4/13 6/4/13 7/3/13 8/22/13 10/1/13
[Snyder, Steve 0-0973 5/26/12 1/15/13 3/6/13 2/20/13 3/27/13 5/1/13 6/10/13 6/10/13 7/3/13 8/21/13 10/29/13
Taylor, Aaron 7356 12/14/09 2/5/13 3/4/13 3/28/13 4/29/13 5/31/13 5/31/13 7/15/13 9/27/13 10/30/13
Taylor, Josh 1764 1/15/13 3/5/13 2/20/13 4/1/13 5/3/13 6/10/13 6/10/13 7/12/13 8/21/13 11/7/13 11/7/13
Turk, David 1047 8/18/97 1/15/13 1/24/13 2/20/13 3/22/13 4/26/13 6/4/13 6/4/13 7/9/13 8/20/13 10/2/13 10/24/13
Walker, Deanna 7732 1/31/08 1/15/13 2/4/13 2/26/13 3/22/13 5/1/13 6/4/13 6/4/13 7/3/13 8/22/13 9/30/13 10/24/13
Warner, Collin 2883 5/7/11 6/5/13 7/3/13 8/21/13 9/26/13 10/29/13
Whitehorse, Nick 0-0976 7/29/08 7/12/13 8/22/13 10/2/13 10/25/13
Yellow, Clarence 0-0919 9/23/07 6/3/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Ryan Young 0-0310 6/15/05 1/15/13 1/23/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
Zohnnie, Wilson 0-0300 12/9/11 11/28/12 1/23/13 2/20/13 3/27/13 5/1/13 6/5/13 6/5/13 7/3/13 8/21/13 10/1/13 10/29/13
gone* layed off
Outline for February 2013 Safety Meeting
Radiation Refresher Training Ronnie Nieves
Green Cards Wayne Palmer
1- An employee slipped on the ice and fell. No immediate injury.
2- While sandblasting the breathing air line got tangled around the sand blaster. While
attempting to untangle the air line his hand slipped past the spray nozzle. The grit
blasted through his glove and ate a Yi" hole in his hand.
Other items:
1) Caustic Hazards pumping caustic solution into totes in just blue coveralls. Hazard
Recognition!
2) Floor grating open and unattended in the SX.
3) Do not go backwards through the old decon. Do Not Enter Sign is in place.
4) Gate to tails can now be left down.
5) What Happens at the mill needs to stay at the mill. Pass around the confidentiality
paper.
6) Leave people lunch alone.
2013 Radiation Refresher
1. Relevant information that has become available during the past year.
(A) Process changes that may affect exposures- The Alternate Feed Circuit processed
CaF2 material this year as well as Regen material. The exposures we have remained
ALARA. This year we will be processing UF4 which does change our DAC values. UF4
is gamma emitter, so remember last time we processed this material we protected
ourselves by wearing a lead apron.
(B) Posting changes, if any - The following areas are still Airborne Radioactivity: Sag Mill
when operating, Yellowcake Packaging Enclosure, Yellowcake Dryers, CaF2 dump
station, Bucking Room during grinding period. Radiation Area postings areas:
Yellowcake Packaging Enclosure, Yellowcake Dryers, Product Storage Yard, UF4 and
Caf2 Storage tailings area, and UF4 dump station. Pay attention to those signs,
posting can change. This can depend on how clean we are keeping our circuits.
(C) biscussion of air, radon and beta-gamma survey results - One reason we constantly
are asking people to clean up, wash down circuits and so on, is because this really
can affect your Radon levels, Beta-Gamma levels, and Gross Alpha levels. If we
make it a priority to keep our circuits clean and washed down, and Maintenance
clean up after work is finished then we see those levels ALARA. We do have a shovel
crew that was recently hired (January 14th) So we should see our levels drop having
this cleanup crew available.
(D) Changes to SOP's that affect Radiation Safety - No changes that would affect or
impact you.
2. Review of safety problems that have arisen during the year.
(A) Discuss issues that have been raised through daily and weekly inspection - We have
added on the Operating Foreman's Daily Inspection sheet seven areas that have
been mandated once a shift to be washed down. (Grind, Leach, Y.C. Precip and
Packaging, North and South Dryer, SX building, Vanadium, Alternate Feed Circuit).
This is another way we can keep radiation exposures ALARA. Housekeeping is really
a concern when performing the weekly inspections. Let's make it a higher priority to
clean up after ourselves.
(B) Housekeeping issues - Like I just mentioned above, if we can make housekeeping a
priority and take some pride in our work, life will be a lot easier on us. The State of
Utah looks at housekeeping, MSHA looks at housekeeping. They comment on every
inspection that our housekeeping needs to improve.
(C) RWP's - We issued out a lot of RWP's in 2012, the most I have seen in several years.
Remember to fill out your portion of the paper. Name; log your time in and time
out. The Radiation department will make a greater effort in checking up on RWP's
that were issued to make sure proper PPE is being worn, and if you have any
concerns or suggestions. We are always open to suggestions.
3. Changes in regulations and license conditions.
(A) Discuss changes that affect the operation or other activities in the mill - There have
been no changes this year.
(B) Discuss NOV's or recommendation from the DRC - We received a violation on Nov
15-16th, for improper posting at the lower sags mill area of the facility. If any signs v
that say respiratory protection or a Rad get taken down because of maintenance
work or for whatever reason please alert the Rad/safety department.
4. Exposure Trends
(A) Average exposure for the previous year - 0.11 REM
(B) Highest exposure for the previous year- 0.44 REM
(C) Comparison of exposures versus background -150 mrem or 0.15 rem
(D) Discussion on the exposures rates received and how those results compare with the
ALARA goals.
5. Other Current Topics
(A) Discuss any problems areas that may have arisen - Discuss exposure letters with
employees, ask if they have any questions or concerns.
Proper scanning is 20 - 30 seconds whole body. Do not press the probe against any
part of your body because we are having to change out way to many Milars because
of this. Keep the probe M of an inch from your body. Also make sure that when you
are finished scanning your selves that you gently place the probe down to prevent
any damage. We are having to send these meters back for repair a lot more than we
should.
Exposure time sheets are still a concern when filling them out correctly and most
importantly handing them in on time. Make sure at the end of your shift's you sit
down and fill out your sheet as best as you can. Make sure you sign your exposure
sheet. It's not complete until that sheet is signed. If not signed I will hand back the
exposure sheet to your supervisor.
There seems to be some confusion on the three different Radiation signs that we
have. First the sign stating Cautions Radiation Area means that this area is showing
an elevation in beta-gamma that has exceeded 5mrem/hr. So what this sign means
is trying and limit your time working in this area, and if maintenance work is needed
contact the Radiation department for further instructions. Cautions Airborne
Radioactive means that air sample taken show that Uranium concentration exceeds
#
25 % of DAC. What this means to you guys is when working in this area respirators
are required. Sag Mill when running is posted as an Airborne area, Y.C. Dryers, and
Y.C. Enclosure. Cautions Radioactive materials informs us and the public that we
have radioactive materials on site and to stay out if you are the general public, and
for mill employees to make sure you know that we are working with radioactive
materials.
We are still struggling with submitting our bioassay on time. Remember we give a
sample every month usually on the first week. Unless you are a packaging/Precip
operator, Sag Mill Grind operator, Bucking Room, and Scale House worker then its
every two weeks. Do we have any suggestions on how to help you guys remember
that Bioassays are due? I have been really nice this year on not writing up people,
but if this continues were certain employees don't think they have to give a sample
or they are constantly being told, then you leave me with no choice but to Wright
you up. Bioassays are given before you report to your job assignment to avoid any
potential contamination falling into your cup.
•
Safety Meeting Outline
May & June 2013
Hazcom & Quarterly Radiation
Mill Manager: Nothing
Green Cards: What went wrong? Proper 1st aid? How could the injury been prevented?
A vsx operator while tightening a flange on a 2" line on the vanadium loaded strip tank
got sprayed in the face when a valve was accidently turned on. An observer leaned against a
valve that opened allowing the solution to spray out. Perforation with drainage to left ear. Zero
energy/ lockout.
Radiation Training: Ronnie Nieves
Introduction to GHS: Ken Brown, Chemist
Safety watches during unloading activities report problems / safety issues to
supervisors, who will write work orders, and report it on shift log.
Gnats
Heat related illness reminder, Specifically water not energy drinks.
Do not hesitate to call if your ill.
Other:
• cue • •
\M I I %M The Globally Harmonized System of Classification and Labeling of Chemicals GHS Hazard Classification Groupings
Classification is the starting point for hazard communication
Physical Hazards
Physical hazards are the properties of a chemical that could cause damage in a physical way, such as from an explosion or fire.
Chemical can blow up; denotes an unstable explosive.
Hazard Classes: Explosives, Self Reactives & Organic Peroxides
Chemical can
ruptured or leaking,
Hazard Classes: Gases Under Pressure
Oxidizing chemicals can react with other materials causing them to burn
Flammables
Flammable chemicals can catch fire easily and burst into flames.
Convives
i?ji£°iB&> Owmlcal may be wiroslve to meysarul cause severe sWn bums and
kf* AIM riamana
Health Hazards
Health Hazards are determined by the properties of a chemical that can cause
Illness or injury to people.
Exposure to the Is chemical can cause Immediate and possibly serious health problems.
Health Hazard
Chemical may cause allergic reactions; may cause cancer; may damage fertility or the unborn child; may cause genetic defects; may cause damage to organs. Hazard Classes; Carcinogen, Respiratory Sensitizer, ReprodiK^Tbxicity,
l\ Chemical is harmful and can irritate eyes, skin or respiratory system; large • Quantities are fatal.
*>r Hazard Classes: Irritant, Dermal Sensitizer, Acute toxicity (harmful) Narcotic Effects, Respiratory Tracts irritation
Environmental Hazards
environmental Hazards cause an acute or long-term threat to the aquatic environment
Dangerous (or tha Aquatic Environment Chemical ie potentially toxic to fish and other life that live In the water.
GHS Label Requirements
Signal Word Product Identifier Pictogram
ToxiFlam (Contains: XYZ)
I Toxic tf Smttowsd, RasnnaMe Liquid and Vapor
OoiwtM^(Mpfc<rdMM>twirt)»uifeflftfcpTOd^W
Uw«lynoiMpiifctot«li8>pralpooct/*»n wnWitutt
bnmedhMy can a POISON COtffROU r/physician. BJnss mouth. *
use water flog, dry chemical, CO* or "afcohoT of firs,
SnMdMUSria^rMShMlHftrtiwdeWknenlnBsAiMalttbpnKM
Precautionary Statement Hazard Statement
1.
An
2. Product Identifier
Product name which matches product name on tne Safety Data Sheet
3. Signal Word
A single word u
4. Hazard Statement
a chemical
5. Precautionary Statement
A phrase describing the recommended measures to be taken to ntolmte
GHS Safety Data Sheet (SDS)
•SDS's Provide critical informatJon for use in
workplace chemical management
• Source of information about hazard to obtain
workers protection measures
• 16 Section format provides
SDS's shall be dated and contain the
following headings:
16 Section format for SDS
1. Identification of the substance/mbdure
and of the compariyftnrJertaking
2. Hazards identification
3. Comprjsitfon/irtfonnation on Ingredients
4. First-aid measures
5. Hre-flgnOng measures
6. Accidental release measures
7. Handling and storage;
8. Exposure conbols^ersonal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Trndcologlcal information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information
Precautionary Statement Pictograms
Precautionary Statement Pictograms help convey warning inforrnatton and Personal Protective Equipment requirements
mk Ma
FACESH1ELD DUST RESPIRATOR SAFETY MASK
FULL PROTECTION
surr
BOOTS
Safety Meeting Outline
August 2013
Evacuation & Fire Warning
Dan Hillsten: ALARA issue
Green Cards: As we review these think about what went wrong and how to prevent them
from reoccurring.
1) An employee tripped and fell causing minor scrapes and bruises. He was walking
backward and did not see a bracket and tripped over it. Report only.
2) An employee received a caustic burn to his arm. He was cutting an abandoned caustic
line that still contained a small amount of solution. He started the job before the SWP
was written and was not wearing any PPE. Note: I am watching and have instructed
others to closely monitor the SWPs to insure that those on the job are wearing the
proper PPE and that what is written is being followed.
3) An employee received a minor acid burn to his chin. He was unbolting a flange and was
wearing PPE.
Evac and Fire warning system
Talk about the evacuation on 8/16/13. Everything went as it should have.
Evacuation alarm location and gathering locations and procedures.
Fire alarm procedure and location.
Review Fire prevention pg 12 & 13.
Questions and concerns.
Other:
Review incident reporting and written statements as part of Miner's Responsibilities. Also
Safety Manual, under Conduct #8 pg 2.
Tag Lines.
Temporary lines; routing, labeling, removing.
Points of Emphasis
Doing what is written on the SWP
Lock Out / Tag Out
Firewood gathering/' What Hazards do you encounter when cutting fire wood"? think of safety.
Chain saw, fire prevention, PPE & where the tree will fall...
ICE Chest
Omar Supporting Documentation
•MSHM 30 CFR56.4330
»0SHA29CFR1910.165(dJ
•OUier
MSHA - Code of Federal Regulations - 30 CFR 56.4330 Page 1 of 1
30 CFR § 56.4330
Firefighting, evacuation, and rescue procedures.
FIREFIGHTING PROCEDURES/ALARMS/DRILLS
(a) Mine operators shall establish emergency firefighting, evacuation, and rescue procedures. These
procedures shall be coordinated in advance with available firefighting organizations.
(b) Fire alarm procedures or systems shall be established to promptly warn every person who could be
endangered by a fire.
(c) Fire alarm systems shall be maintained in operable condition.
http://www.msha.gov/30cfr/56.4330.htm 12/11/2013
Employee alarm systems. -191^65 Page 2 of 2
The employer shall assure that all devices, components, combinations of devices or systems constructed and installed to comply with this
standard are approved. Steam whistles, air horns, strobe lights or similar lighting devices, or tactile devices meeting the requirements of this
section are considered to meet this requirement for approval.
1910.165(c)(2)
The employer shall assure that all employee alarm systems are restored to normal operating condition as promptly as possible after each test
or alarm. Spare alarm devices and components subject to wear or destruction shall be available in sufficient quantities and locations for
prompt restoration of the system.
1910.165(d)
Maintenance and testing.
..1910.165(d)(1)
1910.165(d)(1)
The employer shall assure .that all employee alarm systems are maintained in operating condition "except when undergoing repairs or ^
maintenance,
1910.165(d)(2)
The employer shall assure that a test of the reliability and adequacy of non-supervised employee alarm systems is made every two months.
A different actuation device shall be used in each test of a multi-actuation device system so that no individual device is used for two
consecutive tests. >
1910.165(d)(3)
The employer shall maintain or replace power supplies as often as is necessary to assure a fully operational condition. Back-up means of
alarm, such as employee runners or telephones, shall be provided when systems are out of service.
1910.165(d)(4)
The employer shall assure that employee alarm circuitry installed after January 1,1981, which is capable of being supervised is supervised
and that it will provide positive notification to assigned personnel whenever a deficiency exists in the system. The employer shall assure that
all supervised employee alarm systems are tested at least annually for reliability and adequacy.
1910.165(d)(5)
The employer shall assure that the servicing, maintenance and testing of employee alarms are done by persons trained in the designed
operation and functions necessary for reliable and safe operation of the system.
1910.165(e)
Manual operation. The employer shall assure that manually operated actuation devices for use in conjunction with employee alarms are
unobstructed, conspicuous and readily accessible.
[45 FR 60713, Sept. 12,1980]
Next Standard (1910 Subpart L ADD A)
Regulations (Standards - 29 CFR) - Table of Contents
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Employee alarm systems. - 191^65 Page 1 of2
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Regulations (Standards - 29 CFR) - Table of Contents
• Part Number:
• Part Title:
• Subpart:
• Subpart Tide:
• Standard Number:
• Title:
1910
Occupational Safety and Health Standards
L
Fire Protection
1910.165
Employee alarm systems.
1910.165(a)
Scope and application.
1910.165(a)(1)
This section applies to all emergency employee alarms installed to meet a particular OSHA standard. This section does not apply to those
discharge or supervisory alarms required on various fixed extinguishing systems or to supervisory alarms on fire suppression, alarm or
detection systems unless they are intended to be employee alarm systems.
1910.165(a)(2)
The requirements in this section that pertain to maintenance, testing and inspection shall apply to all local fire alarm signaling systems used
for alerting employees regardless of the other functions of the system.
1910.165(a)(3)
All pre-discharge employee alarms installed to meet a particular OSHA standard shall meet the requirements of paragraphs (b)(1) through
(4), (c), and (d)(1) of this section.
1910.165(b)
General requirements.
1910.165(b)(1)
The employee alarm system shall provide warning for necessary emergency action as called for in the emergency action plan, or for reaction
time for safe escape of employees from the workplace or the immediate work area, or both.
..1910.165(b)(2)
1910.165(b)(2)
The employee alarm shall be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the
workplace. Tactile devices may be used to alert those employees who would not otherwise be able to recognize the audible or visual alarm.
1910.165(b)(3)
The employee alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the
emergency action plan.
1910.165(b)(4)
The employer shall explain to each employee the preferred means of reporting emergencies, such as manual pull box alarms, public address
systems, radio or telephones. The employer shall post emergency telephone numbers near telephones, or employee notice boards, and other
conspicuous locations when telephones serve as a means of reporting emergencies. Where a communication system also serves as the
employee alarm system, all emergency messages shall have priority over all non-emergency messages.
1910.165(b)(5)
The employer shall establish procedures for sounding emergency alarms in the workplace. For those employers with 10 or fewer employees
in a particular workplace, direct voice communication is an acceptable procedure for sounding the alarm provided all employees can hear the
alarm. Such workplaces need not have a back-up system.
1910.165(c)
Installation and restoration.
1910.165(c)(1)
https://www.osha.gov/pls/oshaweb^ 12/12/2013
Maintenance, safeguards, andc^rational features for exit routes. -191^^ Page 1 of 1
1910.37fe)
An employee alarm system must be operable. Employers must install and maintain an operable employee alarm system
that has a distinctive signal to warn employees of fire or other emergencies, unless employees can promptly see or smell a fire
or other hazard in time to provide adequate warning to them. The employee alarm system must comply with § 1910.165.
[39 FR 23502, June 27,1974, as amended at 45 FR 60703, Sept. 12,1980; 67 FR 67963, Nov. 7, 2002]
https://vvrvvw.osha.gov/pls/oshaweb/owadisp.show_d .. 12/12/2013
Book #16
Rev. No.: R-2.4
Date: Oct. 5, 2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
Page 104 of
112
APPENDIX H
EMERGENCY RESPONSE PROCEDURE FOR TAILINGS ACCIDENTS
(See also Sections 2.1.10.1, 2,1.10.2 and 2.1.10.3 of the Emergency Response Plan
The following steps will be followed in the event of a tailings accident (flood water breaching,
structural failure of tailings dike or damage to tailings transport system). The steps should be followed
in the order set out below, unless more than one crew is mobilized, in which case some of the steps
can be taken simultaneously by different crews. The Incident Commander has the authority to vary
from the steps set out below if he deems it necessary in the circumstances to protect public health,
safety or the environment.
1. The person who first witnesses the tailings accident should immediately contact his or her
supervisor, who will initiate the procedures set out below.
2. Evacuate personnel from areas around the impacted area as necessary to prevent possible injury to
those personnel. Access to those areas will be limited to authorized personnel.
3. Turn off all feed of tailings or solutions to the tailings cells and to the tailings transport system.
4. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
5. Notification of Mill Management
The Supervisor will notify one of the following if not already alerted and part of the Emergency
Response crew:
6. To the extent possible, solutions from an impacted tailings cell will be pumped to an un-impacted
tailings cell.
7. Notification of Corporate Management:
• D. Hillsten
• D. Turk
• W. Palmer
435-979-3041
435-678-7802 or 435-459-9786
435-678-2146
The Incident Commander is to call Harold Roberts, Stephen Antony or David Frydenlund
immediately:
Book #16
Rev. No.: R-2.4
Date: Oct. 5, 2012
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
Page 105 of
112
Harold Roberts (Executive Vice President) 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
Stephen Antony (President/CEO) 303.628.7798 (office)
David Frydenlund (Vice President) 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
8. In the event of damage to the transport system, the system will be shut down and repaired. Any
spills will be cleaned up and deposited in the tailings cells.
9. In the case of flood water breaching the retention system or structural failure of the tailings dikes,
mobilize large operating equipment to construct temporary earthen dikes or berms downgradient to
the impacted dike, if appropriate in the circumstances.
10. In the case of flood water breaching the retention system or structural failure of the tailings dikes,
report the incident to the State of Utah Division of Radiation Control (801-536-4250) within 24
hours of the discovery of the incident.
11. Take other measures and perform remediation work as necessary and in accordance with advice
and instructions of the State of Utah Division of Radiation Control.
12. Other reporting
• Report to MSHA
Does not have to be reported.
• Report to State of Utah Department of Natural Resources, Division of Dam Safety
• A written report will be made to the State of Utah Division of Radiation Control within 5
days after the incident.