DRC-2014-007601 - 0901a068804e5f78

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GARY R. HERBERT
Governor DRC 2014-007601
GREG BELL
Lieutenant Governor
October 14, 2014
DRC-2014 006106
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Radioactive Material License No. UT1900479
2014 Radiation Protection Inspection, Module RADMOD-TRAINING-01
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on September 24, 2014 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 Radiation Safety Training were
found to be in compliance with relevant requirements.
A copy of the Inspection Report is enclosed.
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] • T.D.D. [phone]
www.deq. utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-TRAINING-01 (2014)
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): September 24, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dan Hillsten, David Turk
Inspection Summary
The inspection was opened on September 24, 2014 with a meeting between the inspector and D.
Areas/Topics inspected included:
• Radiation Safety Training Outline
• Respiratory Protection Training
• Contractor Training
• Training Records
• Radiation Safety Officer (RSO) Qualifications
The inspector held a closeout meeting September 24, 2014 with D. Hillsten and D. Turk of Energy
Fuels Resources to review the inspection activities, observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Radiation Safety Training Outline
The Licensee provided training outlines for newly hired employees. Radiation training is provided
as part of the initial training given to all new employees. The Licensee makes a distinction between
"Inexperienced" and "Experienced" employees where experienced workers can receive an
abbreviated (1 hour vs 4 hours) training session. Respiratory protection is included in the training.
When relevant the Licensee conducts a "Prenatal Radiation Review" during the initial training.
All employees are required to attend annual radiation safety refresher training. Included in the
refresher training is a review of issues that occurred during the past year. Respiratory protection
refresher training is also included in the annual training.
Turk.
Page 1 of 3
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-TRAINING-01\lnspectionReportRev0.doc
A quarterly Radiation Safety Meeting is also conducted. Coincidentally, the latest one was held the
day of the inspection. Radiation protection issues relevant to current mill activities are presented
and discussed.
Respiratory Protection Training
Respiratory Protection Training is required by the Licensee for newly hired inexperienced workers.
A slightly abbreviated training in this regard may be given to other employees depending upon the
level of experience of the individual. Respirator fit testing is conducted during initial training and
during annual refresher training.
Contractor Training
Contractors performing work at the mill site are required to have radiation safety training. The level
of training may depend upon the length of time the contractor will be on site and the tasks and
locations the work will be performed. Minimum subject matter is prescribed in the Licensee's
Training Manual. Completion of the required training is documented in the Licensee's files.
Training Records
There were approximately 45 personnel currently employed at the mill. A sample (7) was selected
off of the staffs roster and the training records reviewed for those seven individuals.
Documentation for new employee radiation training, radiation protection refresher training, and
respiratory protection refresher training was reviewed.
No current employees were hired during calendar year 2014; therefore, no initial training records
were reviewed for this inspection. Of the seven employees six had documentation indicating that
the annual refresher training for radiation safety and respiratory protection had been received. The
records for the seventh worker indicated that the last refresher training was received on February 20,
2013.
When brought to the attention of the Licensee, it was determined that the individual in question had
an occupational injury just days prior to the scheduled refresher training which kept the employee
from attending. The employee had since returned to work but did not make up the training. The
employee was given the training during the time of the inspection and successful completion was
documented and placed in the employee's training file.
RSO Qualifications
Recently, due to a reduction in force, the sitting radiation safety officer (Ronnie Nieves) was let go.
He was replaced by a former RSO of the site, D. Turk who performed that function from December
2005 to July 2012. Earlier in review of the site's license renewal application the Utah Division of
Radiation Control vetted D. Turk as the RSO and found he possessed the necessary qualifications.
No further investigation in this regard occurred during this inspection.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten and D. Turk of Energy Fuels Resources
(USA) on September 24, 2014. The observations made during the inspection were summarized
during the meeting.
Page 2 of 3
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-TRArNING-01\InspectionReportRev0.doc
Conclusion
The Licensee has a training program as described in its Book #13 Training Manual. The training
program contains all the required elements of such a program. The Licensee was able to provided
documented evidence that the program has been implemented and that training is conducted as
prescribed. Training records are maintained and readily retrievable.
The radiation safety program appears to be given the time and resources necessary to be compliant
and effective.
Recommendations for the Licensee
Since one deficiency was detected and corrected during the inspection regarding a delinquency in
the training of an employee, is recommended that the Licensee review all personnel annual training
records to ensure that no other employee had inadvertently failed to complete any required training.
It is recommended that the Licensee continue to include in its training proceedings current mill
activities as they may pertain to the workers and radiation safety.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai October 7, 2014
(Name) ^(Signature) (Date)
Page 3 of 3
U:\MON_WAST\Bimai\wp\lDspections\Energy Fuel, Blanding, UT\2014\RADMOD-TRAEVENG-01\InspectionReportRev0.doc
Inspection Report,
RADMOD-TRAIMNG-01 Checklist
120141
INSPECTION REPORT
Inspection Module: RADMOD-TRAINING-01 (2014)
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): September 24, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dan Hillsten, David Turk
Inspection Summary
The inspection was opened on September 24, 2014 with a meeting between the inspector and D.
Areas/Topics inspected included:
• Radiation Safety Training Outline
• Respiratory Protection Training
• Contractor Training
• Training Records
• Radiation Safety Officer (RSO) Qualifications
The inspector held a closeout meeting September 24, 2014 with D. Hillsten and D. Turk of Energy
Fuels Resources to review the inspection activities, observations, and conclusions.
Findings
No citable violations or deficiencies were observed during the inspection.
Inspection Items
Radiation Safety Training Outline
The Licensee provided training outlines for newly hired employees. Radiation training is provided
as part of the initial training given to all new employees. The Licensee makes a distinction between
"Inexperienced" and "Experienced" employees where experienced workers can receive an
abbreviated (1 hour vs 4 hours) training session. Respiratory protection is included in the training.
When relevant the Licensee conducts a "Prenatal Radiation Review" during the initial training.
All employees are required to attend annual radiation safety refresher training. Included in the
refresher training is a review of issues that occurred during the past year. Respiratory protection
refresher training is also included in the annual training.
Turk.
Page 1 of3
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-TRAINING-01\lnspectionReportRev0.doc
A quarterly Radiation Safety Meeting is also conducted. Coincidentally, the latest one was held the
day of the inspection. Radiation protection issues relevant to current mill activities are presented
and discussed.
Respiratory Protection Training
Respiratory Protection Training is required by the Licensee for newly hired inexperienced workers.
A slightly abbreviated training in this regard may be given to other employees depending upon the
level of experience of the individual. Respirator fit testing is conducted during initial training and
during annual refresher training.
Contractor Training
Contractors performing work at the mill site are required to have radiation safety training. The level
of training may depend upon the length of time the contractor will be on site and the tasks and
locations the work will be performed. Minimum subject matter is prescribed in the Licensee's
Training Manual. Completion of the required training is documented in the Licensee's files.
Training Records
There were approximately 45 personnel currently employed at the mill. A sample (7) was selected
off of the staffs roster and the training records reviewed for those seven individuals.
Documentation for new employee radiation training, radiation protection refresher training, and
respiratory protection refresher training was reviewed.
No current employees were hired during calendar year 2014; therefore, no initial training records
were reviewed for this inspection. Of the seven employees six had documentation indicating that
the annual refresher training for radiation safety and respiratory protection had been received. The
records for the seventh worker indicated that the last refresher training was received on February 20,
2013.
When brought to the attention of the Licensee, it was determined that the individual in question had
an occupational injury just days prior to the scheduled refresher training which kept the employee
from attending. The employee had since returned to work but did not make up the training. The
employee was given the training during the time of the inspection and successful completion was
documented and placed in the employee's training file.
RSO Qualifications
Recently, due to a reduction in force, the sitting radiation safety officer (Ronnie Nieves) was let go.
He was replaced by a former RSO ofthe site, D. Turk who performed that function from December
2005 to July 2012. Earlier in review of the site's license renewal application the Utah Division of
Radiation Control vetted D. Turk as the RSO and found he possessed the necessary qualifications.
No further investigation in this regard occurred during this inspection.
Closeout Meeting
The inspector held a closeout meeting with D. Hillsten and D. Turk of Energy Fuels Resources
(USA) on September 24, 2014. The observations made during the inspection were summarized
during the meeting.
Page 2 of 3
(J:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-TRAINING-01\InspectionReportRev0.doc
Conclusion
The Licensee has a training program as described in its Book #13 Training Manual. The training
program contains all the required elements of such a program. The Licensee was able to provided
documented evidence that the program has been implemented and that training is conducted as
prescribed. Training records are maintained and readily retrievable.
The radiation safety program appears to be given the time and resources necessary to be compliant
and effective.
Recommendations for the Licensee
Since one deficiency was detected and corrected during the inspection regarding a delinquency in
the training of an employee, is recommended that the Licensee review all personnel annual training
records to ensure that no other employee had inadvertently failed to complete any required training.
It is recommended that the Licensee continue to include in its training proceedings current mill
activities as they may pertain to the workers and radiation safety.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai fy^xi //At- . October 7,2014
(Name) ^(Signature) (Date)
Page 3 of 3
U:\MON WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-TRAINING-01\InspectionReportRev0.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-TRAINING-01
RADIATION PROTECTION & RESPIRATORY PROTECTION TRAINING/
RADIATION SAFETY OFFICER & RADIATION TECHNICIAN TRAINING
ENERGY FUELS (formally DENIS ON MINES) - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT 1900479
References: Radioactive Material License UT1900479, License Renewal Application dated February 28,
2007, Training Manual, addendums 9 and 10, Radiation Protection Manual, Section 1, 10CFR20, NRC
Regulatory Guide 8.30, NRC Regulatory Guide 8.31, Regulatory Guide 8.15, Utah Administrative Code
R313-15.
./ I OPENING MEETING
DATE "I 7 V / / 4
MEETING MEMBERS
NAME DRC/C OMP AN Y CONTACT INFORMATION
H.Xt "/our t
M'MU C
'i2 R c
U:\COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa DMilKHP Inspection modules\2013\Inspection Modules\RADMOD-
Training-01 docx
Dor... I nfK
DISCUSSION
SITE STAFF COMMENTS
U \COMMON\Uranium millsM le(2)UTI900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection ModuIes\RADMOD-
Training-01 docx
R313-15-101. Radiation Protection Programs.
(1) Each licensee or registrant shall develop, document, and implement a radiation protection program
sufficient to ensure compliance with the provisions of Rule R313-15. See Section R313-15-1102 for
recordkeeping requirements relating to these programs.
(2) The licensee or registrant shall use, to the extent practical, procedures and engineering controls based
upon sound radiation protection principles to achieve occupational doses and doses to members of the
public that are as low as is reasonably achievable (ALARA).
(3) The licensee or registrant shall, at intervals not to exceed 12 months, review the radiation protection
program content and implementation.
(4) To implement the ALARA requirements of Subsection R313-15-101 (2), and notwithstanding the
requirements in Section R313-15-301, a constraint on air emissions of radioactive material to the
environment, excluding radon-222 and its decay products, shall be established by licensees or registrants
such that the individual member of the public likely to receive the highest dose will not be expected to
receive a total effective dose equivalent in excess of 0.1 mSv (0.01 rem) per year from these emissions.
If a licensee or registrant subject to this requirement exceeds this dose constraint, the licensee or
registrant shall report the exceedance as provided in Section R313-15-1203 and promptly take
appropriate corrective action to ensure against recurrence.
TRAINING MANUAL (Appendix J, 2007 License Renewal, Revised)
Addendum 9: Radiation Safety Training
In the ALARA program (Appendix I license renewal) 2.5.2 states that the Radiation Training for new
employees will follow NRC Reg. Guide 8.31 section 2.5.
NRC REG. Guide 8.31 Section 2.5 Radiation Safety Training
All new employees should be instructed by means of an established course in the inherent risks of
exposure to radiation and the fundamentals of protection against exposure to uranium and its daughters
before beginning their jobs. Other guidance pertinent to this course is found in Regulatory Guide 8.13,
"Instruction Concerning Prenatal Radiation Exposure" (Ref. 10), and Regulatory Guide 8.29,
"Instruction Concerning Risks from Occupational Radiation Exposure" (Ref. 11). Additionally, the
training should be commensurate with the risks and hazards of the task. This course of instruction
should include the following topics:
1) Fundamentals of Health Protection
• The radiological and toxic hazards of exposure to uranium and its daughters,
• How uranium and its daughters enter the body (inhalation, ingestion, and skin penetration),
• Why exposures to uranium and its daughters should be kept ALARA.
2) Personal Hygiene at UR Facilities
• Wearing protective clothing,
• Using respiratory protective equipment correctly,
• Eating, drinking, and smoking only in designated areas,
• Using proper methods for decontamination (i.e., showers).
3) Facility-Provided Protection
• Ventilation systems and effluent controls,
• Cleanliness of the work place,
• Features designed for radiation safety for process equipment,
• Standard operating procedures,
• Security and access control to designated areas,
• Electronic data gathering and storage,
• Automated processes.
U \COMMON\Uranium mills\l le(2)UT1900479 EnergyFuels Res - White Mesa UMillVHP Inspection modules\2013\Inspection Modules\RADMOD-
Traimng-01 docx
4) Health Protection Measurements
• Measurement of airborne radioactive materials,
• Bioassays to detect uranium (urinalysis and in vivo counting),
• Surveys to detect contamination of personnel and equipment,
• Personnel dosimetry.
5) Radiation Protection Regulations
• Regulatory authority of NRC, MSHA, and State,
• Employee rights in 10 CFR Part 19,
• Radiation protection requirements in 10 CFR Part 20.
6) Emergency Procedures.
A written or oral test with questions directly relevant to the principles of radiation safety and health
protection in UR covered in the training course should be given to each worker. The instructor should
review the test results with each worker. The instructor should discuss any wrong answers to test
questions with the worker until the worker understands the correct answer. Workers who fail the test
should be retested after receiving additional training. These tests and results should be maintained on
file.
Each permanent worker should be provided an abbreviated retraining course annually. Documented
successful completion of the retraining course should also be maintained on file. Retraining should
include relevant information that has become available during the past year, a review of safety problems
that have arisen during the year, changes in regulations and license conditions, exposure trends, and
other current topics.
In addition, all new workers, including supervisors, should be given specialized instruction on the health
and radiation safety aspects and on the non-radiological hazards of the specific jobs they will perform.
This instruction should be in the form of individualized on-the-job training. Supervisors should be
provided additional specialized training on their supervisory responsibilities in the area of worker
radiation protection. Retraining should be conducted annually and documented. All employees should
sign a statement that they received job-specific radiation safety training. The statement should indicate
the dates the training was received and it should be cosigned by the instructor. Radiation safety matters
of concern that arise during plant operation should be discussed with all workers during regular monthly
or bimonthly meetings.
All visitors who have not received training should be escorted by someone properly trained and
knowledgeable about the hazards of the facility. At a minimum, visitors should be instructed specifically
on what they should do to avoid possible radiological and non-radiological hazards in the areas of the
facility they will be visiting.
Contractors that have work assignments in a UR facility should also be given appropriate training and
safety instruction. Contractor workers who will perform work on heavily contaminated equipment
should receive the same training and radiation safety instruction normally required of all permanent
workers. Only job-specific radiation safety instruction is necessary for contract workers who have
previously received full training on prior work assignments at the facility or have evidence of recent and
relevant radiation safety training elsewhere.
U:\COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Res - White Mesa UMillVHP Inspection modules\2013\Inspection Modules\RADMOD-
Training-Ol.docx
Dor... A nf i <
1) Review the Radiation Safety material with the instructor or attend a training class and identify if
each subject is covered. Was the following information covered in the licensee Radiation Safety
training as outlined in NRC Reg. Guide 8.31 Section 2.5.
NRC Reg. Guide 8.31 section 2.5 Yes No
Section l:Fundamentals of Health Protection
The radiological and Toxic hazards of exposure to Uranium and its daughters
-How Uranium and its daughters enter the body (Inhalation, Ingestion and Skin
Penetration)
Section 2:Personal Hygiene at UR Facilities
-Wearing Protective Clothing
-Using Respirator Protective Equipment Correctly
-Eating, Drinking, and Smoking only in designated areas
-Using proper methods for decontamination
Section 3:Facility Provided Protection
-Ventilation Systems and Effluent Controls
-Cleanliness of the work place
-Features designed for Radiation Safety for process equipment
-Standard Operating Procedures
-Security and Access Control to designated areas
-Electronic data gathering and storage
-Automated processes
Section 4:Health Protection Measurements
-Measurements of Airborne radioactive materials
-Bioassays to detect Uranium (Urinalysis and in Vivo Counting)
-Surveys to detect contamination on personnel and equipment
-Personnel Dosimetry
Section 5: Radiation Protection Regulation
-Regulatory Authority ofthe NRC, MSHA and the State
-Employee Rights in 10CFR19 (R313-18)
-Radiation Protection Requirements in 10CFR20 (R313-15)
Section 6: Emergency Procedures
2) Does the Radiation Protection training cover the information sufficiently to enable onsite personnel
to properly implement the Radiation Protection program and the ALARA program? Yes X No
Have the employee's demonstrated sufficient understanding of the material to be able to implement the
Radiation Protection program and the ALARA programs? Yes X No
Has this training been properly documented? Yes x No
Comments:
U:\COMMON\Uranium millsM le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-
Training-Ol.docx
Dor.*. UfK
Section 3.1 Pre-Employment Instruction - Items I and J.
3) Did the licensee provide training to female employees on 'Prenatal Radiation Review'?
Comments: \y,(\t^(^[ 4Y3IH,'«^ Yes_ft N°_
Training Manual Section 2.0 On-Site Contractors.
"New hire training, as outlined in Section 3.1, is included in the training program, as applicable to the
site work specifications, for on-site contractors."
4) Has the licensee documented initial training of on-site contractors?
Comments: /Z/f X£5 No
Training Manual Section 3.1 Pre-employment Instruction.
"Classroom instruction of all new employees is conducted under the supervision of the Radiation Safety
Officer and Safety Coordinator, covering plant and personal safety, including radiation protection."
5) Has the licensee documented initial training of new employees?
Comments: Yes No
6) Did the licensee provide annual refresher training on 'Radiation Protection'?
Comments: Yes yC No
U \COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMiIl\HP Inspection modules\2013\lnspection Modules\RADMOD-
Training-01 docx
7) Does the licensee have employee's take a Radiation Safety Test each year? Yes No
Is the test documented and kept in the employee's training file? Yes No
Comments:
Record Review
8) Look at the training records of the employees who were interviewed.
Radiation Safety
Name Exams Initial/ Refresher
Training Records
Personnel
Monitoring
Prenatal Training/
Pregnancy Form
1.
3.
4.
5.
Additional Comments or Observations ions: ^ ^ '•• ^ A'V : y • -^v -^-i 1-''
(X'•<•<.<;. ••(•.u-hi' 7 0fvf y < ,( v <• •. i- • , -/ v -1
4 ( 1. f. c
Addendum 10: Respirator Protection Training
In the ALARA program (Appendix I license renewal) 2.7.5. states that the Respirator Protection
Program will follow NRC Reg. Guide 8.15
NRC Reg. Guide 8.15 Section 5.2 Training
A training program, including hands-on training, must be established and implemented for respirator
users (see 10 CFR 20.1703(c)(4)). When face-sealing respirators will be used, this training should take
place prior to fit-testing. As a minimum, each trainee should:
• Be informed of the hazard to which the respirator wearer may be exposed, the effects of
contaminants on the wearer if the respirator is not worn properly, and the capabilities and
limitations of each device that may be used.
• Be shown how spectacle adapters, communications equipment, and other equipment that will be
used directly in conjunction with the respirator are to be attached and operated properly.
• Be able to demonstrate competency in donning, using, and removing each type of respiratory
protective device that may be used.
U:\COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-
Training-Ol.docx
• Be instructed in how to inspect each type of respiratory protective device that may be used and
be instructed to perform such an inspection before donning any device.
• Be instructed in how to perform a user seal check on face-sealing devices and be instructed to
perform this user seal check each time this type of device is donned.
• Be informed that any respirator user may leave the work area at any time for relief from
respirator use in the event of equipment malfunction, physical or psychological distress,
procedural or communications failure, significant deterioration of operating conditions, or any
other condition that might necessitate such relief.
• Be advised that in case of respirator malfunction or wearer distress, the respirator may be
removed as the respirator user exits the airborne contamination area.
9) Review the Respirator Protection Training material with the instructor or attend a training class and
identify if each subject is covered. Was the following information covered in the licensee Respirator
Training as outlined in NRC Reg. Guide 8.15 Section 5.2.
NRC Reg. Guide 8.15 Section 5.2 Training Yes No
Be informed of the hazard to which the respirator wearer may be exposed, the effects of the
contaminants on the wearer if the respirator is not worn properly, and the capabilities and limitations
of each device that may be used.
Be shown how spectacle adapters, communications equipment and other equipment that will be used
directly in conjunction with the respirator are to be attached and operated properly.
Be able to demonstrate competency in donning, using, and removing each type of respiratory
protective device that may be used.
Be instructed in how to inspect each type of respiratory protective device that may be used and be
instructed to perform such an inspection before donning any device.
Be instructed in how to perform a user seal check on face-sealing devices and be instructed to
perform this user seal check each time this type of device is donned.
Be informed that any respirator user may leave the work area at any time for relief from respirator use
in the event of equipment malfunction, physical or psychological distress, procedural or
communications failure, significant deterioration of operating conditions, or any other condition that
might necessitate such relief.
Be advised that in case a respirator malfunction or wearer distress, the respirator may be removed as
the respirator user exits the airborne contamination area.
10) Does the licensee provide training on the 'Respirator Protection Program'? Yes A
How did they document that training?
Comments:
No
U \COMMON\Uranium millsM Ie(2)UT 1900479 EnergyFuels Res - White Mesa UMillVHP Inspection modules\2013\lnspection ModulesVRADMOD-
Training-01 docx
11) Does the training cover all of the outlined material? Yes No_
If no what needs to be added or expanded? \ ( t (
Comments: A- ^ >"'<Jl '''-nV ~\ \MP -M «. V? <~. ^
12) Did personnel that were interviewed have a good knowledge of the Respirator Protection Program?
Yes No
If no what areas do they need to be retrained in?
Comments: /J/<^-~
13) Look at the Respirator training records of the employees who were interviewed.
Name Exams Initial/ Refresher
Training Records
Medical Clearance Fit Tests
3.
4.
Additional Comments or Observations
\ *' f C ~y (~ ,1 I
-
5^
U:\COMMON\Uranium mills\l le(2)UT 1900479 EnergyFuels Res - White Mesa UMillVHP Inspection modules\2013\Inspection Modules\RADMOD-
Training-Ol.docx
Appendix I (ALARA Program) section 2.4.1 requires that the RSO should have the education, training
and experience as specified in NRC Regulatory Guide 8.31. Section 2.5 the RSO shall also receive
health and safety refresher training every two years. Section 2.4.2 The Radiation Safety Technician
(RST) shall have the qualifications specified in NRC Regulatory Guide 8.31.
14) Who is the RSO's designee when the RSO is not available?
Does the named designee have the same RSO education, training and experience as outlined in Reg.
Guide 8.31? Yes No
Does the RSOs designee receive additional training in health and safety?
Comments: -'Uc 'f ^iv. £>~J~--S 1 tw» , < , ,•>.. y -\ Yes No
15) Do the RSTs have the required education, training and experience as outlined in Reg. Guide 8.31?
Name of RST Qualified Y/N Time in Position Trained Y/N Assigned Duties
Comments:
U:\COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-
Training-Ol.docx
Employee Interviews ^r-^ff
1) Employee Name V^^^ | I*/'
2) Employee Job Title (°^
3) Length of Employment
4) Did Employee receive training when hired? Yes No_
5) Did that training cover Radiation Safety? Yes No
6) Did that training cover Respiratory Protection? Yes No
7) If employed longer than a year, Have they received any refresher training? Yes No NA
8) Did that training cover Radiation Safety? Yes No NA
9) Did that training cover Respiratory Protection? Yes No NA
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No NA
11) Where do they wear their dosimetry?
12) Where do they store their dosimetry?
13) What are the main types of radiation expected at this facility?
14) What are the health risks associated with the types of radiation found at this facility?
15) What are the main routes of exposure?
16) How do you limit your exposure?
17) Do you use a respirator? Yes No NA
18) How often do you use a respirator?
19) How often do you exchange your respirator?
20) Where do you store your respirator?
21) Have the employee demonstrate the proper method for donning and removing a respirator. Have
them include any inspection of the respirators and positive and negative checks.
Did they do it correctly? Yes No
What do you look for when inspecting your respirator?
What do you look for when you do a positive and negative test of your respirator?
Additional Comments:
U \COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Res
Traimng-01 docx
Radiation Safety/Respirator Trainer Interviews
1) Employee Name
2) Employee Job Title
3) Length of Employment
4) What qualifications do they have to be a trainer?
Comments:
5) What additional training did the trainer receive when they were hired/assigned to be a trainer?
Comments:
6) How often do they receive refresher training so they are kept up to date on any changes to Utah
Rules, Federal Regulations, or changes in company programs, procedures and policies?
Comments:
7) What is a passing grade on a test? (** 70% or Higher)
Comments:
8) How many times is a person allowed to fail a test? (** 3 times)
Comments:
9) How do you document the training you do? (** attendance sheet, test exams)
Comments:
**Denson Mines response to first round Health Physics Interrogatories dated February 5, 2009, question #27.
to/?yV
U \COMMON\Uranium millsM le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\lnspection Modules\RADMOD-
Traimng-OI docx
Radiation Safety Officer Interview (ZS*=> V/e^4-^
1) Employee Name ^^'fjl^-
2) Length of Employment tof^^ 1^
3) Does the named RSO have the required education, training and experience as outlined in Reg. Guide
8.31?
Comments: Yes No
4) Has the RSO received additional training in health and safety every two years? If so, when was the
last training? (ask for copy of certificate)
Comments: Yes No
5) How often do trainers receive refresher training so they are kept up to date on any changes to Utah
Rules, Federal Regulations, or changes in company programs, procedures and policies?
Comments:
6) How often do you review your Radiation Safety Training program and Respiratory Protection
Program to stay current with applicable State Rules and Federal Regulations?
Comments:
7) How often do you review the Mills Standard Operating Procedure so that they are current with
applicable State Rules, Federal Regulations, RML license conditions and the GWQDP?
Comments:
8) How are the Radiation Safety Technicians trained to do their jobs?
Comments:
U \COMMON\Uranmm millsM le(2)UT1900479 EnergyFuels Res - White Mesa UMillVHP Inspection modules\2013\Inspection Modules\RADMOD-
Training-01 docx
DATE
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
U \COMMON\Uranium millsU le(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-
Training-01 docx
Dor.*. 1/1 r.f i c
DISCUSSION of FINDINGS
^tupLpp - "TCA-UM L^UM****^ LzA K4t-f- fe-ca^.^ft (Z^^uSj reJ^sUsr -j-r^,^^
SITE STAFF COMMENTS
U \COMMON\Uranium millsM Ie(2)UT 1900479 EnergyFuels Res - White Mesa UMill\HP Inspection modules\2013\Inspection Modules\RADMOD-
Training-01 docx
Radiation Safety Training
• Program
• Training Outlines
• Personnel Roster
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
3 of 101
Training Program
1.0 Introduction
The purpose of the Energy Fuels Resources (USA) Inc. ("EFR") in-house safety training
program is to place in the proper perspective, for the employee, the potential short and long-
term hazards associated with the job; to acquaint the employee with the practices instituted
by management to minimize occupational exposures and to ensure that the employee has an
understanding (both initially and over the duration of his employment) of the radiation,
health, safety and environmental protection procedures the employee should be following.
Additionally, EFR management is committed to maintaining occupational radiation
exposures to levels as low as reasonably achievable (ALARA).
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
92 of 101
If respiratory protection is required a respirator fitness physical and fit test are
required. Any question regarding this subject shall be directed to the Owners
Representative.
Appropriate fall protection shall be worn at locations where there is a danger of
falling and/or where required by Owner.
III. RADIATION PROTECTION
The White Mesa Mill has a radioactive materials license with the State of Utah
Division of Radiation Control. Under that license, there are certain items that must be
observed by all parties on site. Those are, but not limited to:
a. Eating, drinking and chewing are only authorized in designated areas. These
areas are determined and posted by the Radiation Safety Officer. Potentially
contaminated PPE is not allowed in these areas.
b. All personnel, equipment and vehicles that enter into the restricted area, must be
surveyed for radiological release prior to leaving the restricted area. All mobile
equipment must travel through the decontamination wash station before being
presented for release from the site.
c. Before work assignments commence, the Contractor must present their job
assignment to the Radiation Department. The Radiation Department will
determine exposure potential and will issue a Radiation Work Permit if
applicable.
d. All Contractor personnel must submit to periodic bioassay monitoring for the
determination of potential uptake or ingestion of uranium.
e. Respiratory protection may be needed if there is determined that an area is
contaminated. If respiratory protection is required, the Contractor will provide
medical clearance for their personnel. Respiratory devices will only be issued
upon the successful completion of the medical evaluation and onsite respirator fit
testing.
f. Personnel must monitor him or her with the use of an alpha monitoring device
prior to leaving the restricted area. Monitoring locations are under surveillance to
ensure that proper techniques are being applied. Contractor personnel will be
trained in the proper use of these instruments.
g. Failure to comply with these items and others as deemed necessary by the
Radiation Safety Officer will be grounds for immediate termination of services at
the facility.
IV. HOUSEKEEPING AND STORAGE
Debris will not be allowed to accumulate. Regular removal to designated areas is a
requirement. Tools, equipment and materials will be stored in a safe and orderly
fashion that minimizes interference with operations or traffic. Upon completion of
the job, Contractor shall remove all construction debris and leave the site neat and
orderly.
Training Outline for Newly Hired Employees
Experienced
This outline meets the requirement of the MSHA approved training plan for the White
Mesa Mill, Dated September 1, 2004.
7:00 a.m. Introduction
• Introductions of the instructor and employees.
• Explain who the regulatory agencies are.
• Hand out Rulebook and sign off sheets.
• Hand out urine specimen cups and explain purpose.
• Pass around the Training Attendance Sheet.
• Brief history of the Mill.
• Explain the milling process.
• Discuss Emergency Escape & Fire Evacuation Procedures.
• Fire Safety Training
• Authority and responsibility of supervisors and miners representatives.
9:00 a.m. Break
9:15 a.m. Mill Tour
• Introduce the Alpha Survey and demonstrate the proper frisk.
• Transportation Controls & Communication
• Ground Controls, working near high-walls, water hazards, night work, and elevated
areas
• Electrical Hazards
• Accident Prevention
11.00 a.m. Lunch
11:30 a.m. Class: Radiation Training
• Discuss the types of radiation with meter demonstrations.
• Explain the difference between internal and external dose.
• 5 rem
• Exposure History
• Exposure letter
• Exposure Time Sheets
• Explain what the employee's responsibility is in regards to radiation
protection.
• ALARA principle
• Respirators & Fit Testing
• Postings
• Urine Sampling
• PPE
• Radiation Training Quiz and Review
Class: Health & Mandatory Health Standards
Class: HAZCOM
1:30 p.m. Break
1:45 p.m. Class
• First Aid
• Health Standards
• Special Work Permits
• Accident Reporting
• Intermodal Container Safety
• Ore Pad Safety
• Tails Safety
• 5000-23 Forms
3:00 p.m. Supervisor
Training Outline for Newly Hired Employees
Inexperienced
This outline meets the requirements of the MSHA approved training plan for the White
Mesa Mill, Dated September 1, 2005.
Day One
7:00 A.M. Introduction:
• Introductions of instructor and employees.
• Pass around the course outline.
• Explain who the regulatory agencies are that govern our
activities.
• Hand out Rulebook and sign off Sheet.
• Hand out urine sample cups and explain purpose.
• Pass around the Training Attendance Sheet.
• Brief History ofthe Mill.
• Explain the milling process.
• Discuss Emergency Escape & Fire Evacuation Procedures.
• Instruction in the Statutory Rights of miners
9:00 A.M. Break
9:15 A.M. Mill Tour
• Introduce the Alpha Survey and demonstrate the proper frisk.
• Go to the warehouse and get safety glasses and hard hats.
• Walk through the plant following the flow chart. Point out
hazards, chemical storage, eyewash stations, fire extinguishers,
and revisit the emergency evacuation procedures.
11:00 A.M. Lunch
11:30 Class: Radiation Training and Respiratory Protection
• Show the Video, Practical Radiation Safety
• Have a general discussion about radiation. Including but not
limited to such topics as the health affects of radiation,
benefits of radiation, types of radiation, and explain internal
and external dose.
• 5 rem
• Explain what the radiation department's responsibility is and
how we measure radiation and monitor exposures.
• Annual Exposure letter.
• Previous employment at a radiation regulated site for exposure
history.
• Discuss D.A.C. and radiation postings.
• Importance of Urine samples.
• RWP's
• Define ALARA
• Explain what the employee's responsibility is in regards to
radiation protection.
• Restricted Area and the alpha frisk. Sign the "Training on the
Proper use of Personnel Alpha Monitor form.
• Go over and explain the importance of the exposure time
cards.
1:15 P.M. Break
1:30 P.M. Class
• Respirator Protections Program. Discuss when we wear them,
what limitations they may have and selecting the proper
cartridge, where they are stored, how they are cleaned, and
how to check them out.
• Demonstrate how to properly field inspect, don, and perform
the positive and negative pressure test.
• Explain the importance of using the proper respirator and
cartridge for the job and wearing only the size you are fitted
for.
• Respirator care.
• Fit test employees and fill out the proper documentation. Note
any need for spec kits and explain. Answer any questions,
review, and then give the radiation quiz.
Note: Any women need to have the Radiation Exposure to Pregnant Women
Training.
End of the first day.
Day Two
7:00 A.M. Class: Transportation Controls & Communication Systems.
• Organization Chart
• Foreman's Report of Injury.
• Reporting accidents, near miss incidents, and unsafe
conditions.
• Review direct and indirect costs of accidents.
• MSDS.
• NFPA
• Review pages 1 & 2 of the rulebook.
Break
• Human Resource Director or designated representative: Time
Cards and explanations of benefits.
10:00 A.M. Class: Hazard Recognition
• Discuss the hazards of the mill.
• Discuss the Safe Work Permit
• Video
11:00 A.M. Lunch
11:30 A.M. Class: First Aid
• Pretest #1, Medical Emergencies in the Workplace.
• Video and review.
• Pretest #2, Choking Emergencies
• Video and review
1:15 P.M. Break
1:30 P.M. Class: First Aid continues
• Pretest #3, Control of Bleeding.
• Video, review and practice.
• Pretest #4, Shock- The silent Killer.
• Video and review.
End Second Day
Day Three
7:00 A.M. Class: First Aid-continue
• Pretest #5, Proper Treatment of Fractures.
• Video, review and practice.
• Pretest #6, Burn Emergencies.
• Video and review.
• Go through the ambulance.
9:00 A.M. Break
I.
9:15 A.M. Class: Electrical Hazards & Ground Control, Water Hazards, Night
Work, Elevated Work Areas.
11:00 A.M.
11:30 A.M.
Review rulebook page 29, Electrical Safety Rules.
Review page 3, Electrical Lock out Procedure.
Show one of the Training videos if time allows.
Discuss site traffic rules.
Vehicle pre-shift inspections.
Equipment operator training requirements.
Safety Rules for Tails page 34.
Ladder & Scaffolding rules page 9.
Lunch
Class: Industrial Hygiene, Health and Safety Aspects of Task to which
new miner will be assigned.
Show the Training Video 'Nurse Vera knows it all."
Discuss PPE
Housekeeping page 13
Sound Levels
Dust Sampling
Chemical Hazards and monitoring.
1:15 P.M.
1:30 P.M.
Break
Class:
Review
Questions & Answers.
Collect all paper work and complete the 5000-23 form.
Introduce employees to their supervisors. Let the employees ask
specific questions about their job assignments, go get PPE,
lockers, get lockers and prepare for the first day of work.
On the job Training.
September 2014 Quarterly Radiation Safety Meeting
• Signage changes
o SAG Mill
o Alternate Feed
• Respirator usage
o During work activities in the CaF2 Dump Station
o YC Dryers-all the time
o YC Packaging Enclosure - all the time
• SOP
o Who can create?
• SERP or Safety
o Why it is created?
• When identified as a deficiency
• Meet regulation standards
• Procedures vs. Regulations
o The regulations or standards are the procedure until a written and usually more
restrictive one is established by the Company
o Regulators can and will inspect to Company procedures if they are established
o Go over new Company Safety SOP list
West Door PERSONNEL TO BE ALPHA SCANNED Date:
Your initials will be placed in the box with the corresponding name if the survey indicates no contamination.
If the alarm sounds, resurvey. It the alarm sounds again, contact shift foreman, RSO, or radiation staff.
There must be an entry for each and every survey conducted. The person assigned to observe the
monitoring of personnel shall sign and date this form.
f
St«"» tntnny
Launa Armstrong
Leron Atcitty
Matt Atwood
Amanda Bailey
Joel Bayles
•fl-David Beaver
Shawn Begaye
Jaymes Benally
Tyrone Blackhorse
Verdale Boy
Benjamin dinger
f Michelle Graf
Wade Hancock
•— Steven Helquist
Dan Hillsten
Wayne Holiday
Tanner Holliday
, Thayne Holt
Jeremy Jones
Paul Kemner
Tad Kreth
" * ' David Lacy
Karson Lacy
I Tully Lameman
Heath Lathem
Tyrone Little
Abel Mendoza Jr.
Billy Mendoza
Cortney Montella
f Arden Nielson
Garrin Palmer
Mike Palmer
Wayne Palmer
Justin Perkins
Dustin Reed
JdafskWWTSeTTT*
• Logan Shumway
Casey Singer
Terry Slade
Steve Snyder
Josh Taylor
David Turk
9 Deanna Walker
Nick Whitehorse
Ryan Young
Wilson Zohnnie
W4L
1 i.
Supervisor's Signature
Contractor Training
information
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
4 of 101
2.0 On-Site Contractors
The employees of on-site contractors receive instructions and training prior to
performing site work. New hire training, as outlined in section 1.2 is included in the
training program, as applicable to the site work specifications, for on-site contractors.
Contracted employees receive a review of the radiation awareness training program
including definitions of types of radiation present, the monitoring program in place,
levels of predicted exposures, restricted access areas, and special job hygiene and
personal protection requirements involved with the site work specifications. The
contractor and employees thereof are required to obey all facility safety and radiation
protection requirements.
The following covers the overall on-site contractor training review:
A. MSHA approved hard hats, safety glasses, and steel-toed shoes
will be worn by all personnel on the property.
B. MSHA approved respirators will be worn in designated areas.
C. Hearing protection will be worn in designated areas.
D. The mill uses many acids and chemicals; protective clothing will
be worn in designated areas.
E. Eating and drinking is only allowed in designated areas.
F. Smoking in the restricted area is not permitted.
G. Observe all safety signs and warnings.
H. Obey the posted speed limit of 15 mph.
2.1 Personal Protection
(
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
91 of 101
? M ENE ENERGYFUELS
CONTRACTOR SAFETY RULES
Contractor shall be responsible for compliance with all local, State, Federal and Company safety,
health and environmental laws and regulations in effect. Contractor shall also be held to
understand that this site is a State of Utah Division of Radiation Control licensed facility and is
governed by the rules and regulations of the Owner, State of Utah DRC and MSHA. Owner
requires that all work conducted by Contractor and its employees be performed in a responsible
manner with special attention and mutual cooperation on the part of everyone involved including
Contractor, its employees and the employees of the Owner.
As part of its Contractual obligation, Contractor and its employees are expected to abide by all
applicable safety rules. Mandatory, (MSHA, OSHA, State or Company, etc.) safety and health
training must be received by all workers prior to starting any work on site. The rules listed
below are minimum basic Owner Safety Rules and Regulations; they do not in any way contain
every necessary rule. If the Contractor has questions concerning Safety Rules and Regulations,
Contractor shall consult with Owner's Representative before starting work.
The fact that other applicable rules, regulations or requirements (Federal, State or local) are not
printed herein will not be an excuse for any violation. Any violations of these rules and
regulations be it accidental or intentional may be cause for termination of this contract.
OWNER SAFETY RULES AND REGULATIONS
I. TRAINING
All contract employees must receive the training required by Owner prior to starting
work on site.
II. PERSONNEL PROTECTION
Hardhats, safety glasses, identification badges and steel toe shoes will be required
when entering the mill area. Whenever, work is performed in an environment, which
requires special protection, such as respirators, hearing protection, goggles or face
shield, wet suits, etc. this protection must be worn. If there is a question as to
whether this special equipment is required, contact the Owner's Representative.
Persons with hair that extends longer than two (2) inches below the tee shirt collar
must confine the hair.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
99 of 101
By signing this acknowledgement, each Contractor denotes acceptance of all of the above safety
requirements of this Contract and agreement to abide by all federal, state and local laws and
regulations.
Name: Date:
(Print)
Contractor:
Brief Job Description:
Signature:
Prenatal Radiation Review
Information
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
7 of 101
All female employees are given a verbal presentation regarding prenatal
radiation exposure along with a copy of the Appendix to NRC Reg. Guide
8.13 for their review. Both the female employee and the Radiation Safety
Officer certify in writing as to the employee's understanding of these
regulations, and the alternatives afforded the employee. A copy of this
form is presented in Addendum 9, Section A.
3.2Radiation Protection Review
On an annual basis, a one hour safety meeting is scheduled specifically for
radiation awareness, protection and review of policies. These meetings
are used to reiterate safety precautions, and to demonstrate personal safety
equipment. A copy of the safety meeting program review is included as
Addendum 9, Section B. During monthly safety meetings, time is
specifically allotted to discuss radiation protection practices and policies
in addition to receiving measured radiological parameters.
Subject: Radiation Exposure to Pregnant Women Employees
On this date, I was advised by my employer, Energy Fuels Resources (USA) Inc. of the
White Mesa Mill, Utah, of the possible risks associated with prenatal radiation exposure
and ofthe precautions that I should I become pregnant and continue to work. I was also
advised of the alternatives that I might consider in this regard.
I discussed this subject with my employer and understand the possible risks to children of
women who are exposed to radiation during pregnancy and the alternatives that I might
consider as explained by my employer as contained in the appendix to Regulatory Guide
8.13 from the United States Nuclear Regulatory Commission, a copy of which was given
to me for reference.
Employee Date
Employer Representative Date
Hire Date:
SSN:
Employee Number:
Radiations Safety Officer IRSOl
Qualifications
Supplemental Information
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.enepjyfuels.com
September 24, 2014
Sent VIA E-MAIL AND EXPRESS DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Notification of Reassignment of the Radiation Safety Officer Position, and Notification of
Modified Work Schedule, White Mesa Mill, Blanding Utah
Dear Mr. Lundberg:
This letter serves as the Energy Fuels Resources (USA) Inc. ("EFRI") notification of the reassignment
of the Radiation Safety Officer ("RSO") position at the White Mesa Mill (the "Mill"). As the result of
a reduction in force ("RIF"), effective September 5, 2014, Mr. Ronnie Nieves is no longer the Mill
RSO, and Mr. David Turk has been reassigned to the Mill RSO position.
EFRI is satisfied that Mr. Turk's technical qualifications satisfy the criteria in Reg, Guide 8.31,
paragraph 2.4.1. Mr. Turk has taken specialized classroom training in health physics specifically
applicable to uranium milling during his career, and attends refresher training on uranium mill health
physics as required. Specifically, Mr. Turk has a Bachelors' degree and had been a Radiation
Technician at the Mill for approximately 7 1/2 years during the period May 1997 to December 2005,
interim RSO at the Mill from December, 2005 to March 2006 and RSO at the Mill for over six years
from March, 2006 to July 1, 2012. From July 1, 2012 to present, Mr. Turk has served as the Corporate
Environmental Health and Safety Manager.
Please note that this letter also serves as EFRI's notification that the Mill will begin a modified work
schedule beginning the week of September 29, 2014. The modified work schedule will be Monday
through Thursday of each week with no production operations on Friday. Daily Mill inspections will
continue to be completed on non-production days as required; however, on-site staff will be reduced.
The staff schedules can be changed, as needed, for Division of Radiation Control ("DRC") inspections
or DRC Mill visits with prior notice to Mr. Turk.
Letter to Mr. Rusty Lundberg
September 24, 2014
Page 2
If you should have any questions regarding this notification please contact me.
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
Scott A. Bakken
Phil Goble
John Hultquist
Yours very truly,
2