DRC-2015-003084 - 0901a06880540432

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director GARYR HERBERT
Governor DRC-2015-003084
SPENCER J COX
Lieulenani Governor
March 30, 2015 DRC-2015-001943
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Radioactive Material License No. UT 1900479
lsl Quarter 2015 Radiation Protection Inspection, Module RADMOD-Emergency-2015
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on March 12, 2015 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.
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. HT
Mailing Address: P O Box 144850 • Salt Lake City. UT 84114-48 50
Telephone [phone] • Fax [phone] • TDD (801) 536^414
www deq Utah gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-Emergency-2015
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 12,2015
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: David Turk, Energy Fuels Resources (EFR)
Inspection Summary
The inspection was opened on March 12, 2015 with a meeting with D. Turk.
Areas/Topics inspected included:
• Follow-up to Prior Inspection
• Review of Emergency Response Plan
• Site Evacuation Drill
• Conversion from Material Safety Data Sheet (MSDS) to Safety Data Sheets (SDS)
The inspector held a closeout meeting on March 12, 2015 with D. Turk of EFR to review the
inspection activities, observations, and conclusions.
No infractions or violations were detected or encountered during the course of the inspection.
Inspection Items
Follow-up to Prior Inspection
• During the December 4, 2013 inspection the emergency fire/evacuation alarm system failed
to function when initiated for a routine evacuation drill. It was determined at the time that
the alarm system had been bypassed while maintenance was performed on other systems and
that when the maintenance work was completed the workers failed to reactivate the alarm
system. In order to prevent recurrence the control of the access to the alarm system has been
delegated solely to the Radiation Safety Officer (RSO). If the alarm system has to be shut
down for any reason the RSO, or designee, must be the one to provide access to the system.
The access is secured with a lock with the RSO in sole possession of the key. In this
manner, the RSO will always be aware of when the system is in a shutdown status.
• The critique for the biennial emergency response exercise conducted in November 2013 had
not yet been published at the time of the previous inspection. Once issued, the Licensee was
Page 1 of 4
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2015\InspectionReportRev0.doc
Findings
requested to review the report and address any relevant issues that were identified in the
critique. The Licensee obtained a copy of the "Blue Mountain Hospital Operation Walking
Dead" After-Action Report/Improvement Plan which was a summary and critique of the
November 15, 2013 Full-Scale Exercise. The main focus of the exercise was the hospital's
handling of an emergency associated with a surge of patients from a transportation accident
involving hazardous materials. The Licensee participated in an ancillary capacity.
There were no criticisms or recommendations directed towards the Licensee's involvement
that needed to be addressed.
The Licensee will conduct its biennial exercise in 2015. Planning for this event was in its
infancy at the time of the inspection.
• Corrections and edits to the Emergency Response Plan were suggested in the course of last
inspection. The items were addressed in the revision of the plan.
Review of Emergency Response Plan
The plan (White Mesa Mill Emergency Response Plan, Book #16, Rev. No. R-3.0, December 2014)
had been revised since the last inspection and was reviewed to ensure that all the required elements
were retained in the revision.
Each element for an emergency response plan specified in Radiation Control Rules R313-22-32(c)
was identified in the Licensee's current plan.
The plan was significantly improved when revised. Emergency Response Guide excerpts were
updated as recommended during the last inspection. Duplicated Appendix designations were also
corrected. Other minor corrections had been made as suggested. The plan is a much "cleaner"
document than what was in place at the last inspection. It is better organized and easier to read and
follow, all around, a better document.
Minor corrections that should be addressed in the revised plan include changing the references to
Section 3.1.6 which should read Section 3.1.7. This reference occurs in two places: Section 6.4.1.3
and Appendix E of the plan. Also in Appendix E 14 a reference is made to exposure to "high
radiation" with respect to contamination when the intent is "high radiological contamination."
Site Evacuation Drill
The RSO was very accommodating for conducting the quarterly site evacuation drill during the
inspection where it could be directly observed. The alarm sounded without delay, the employees
evacuated in an orderly and timely manner, and there was an accounting for all personnel on sight.
It was noted that the majority ofthe personnel assembled outside the gate to the restricted area in the
parking lot of the administration building which raised the question of controlling potential
personnel contamination situations. It was apparent that the employees would return to the
restricted area and would be scanned out under routine area exit procedures. In the event the
workers could not be allowed back into the restricted area, the RSO indicated that radiation
technicians would be present to frisk the workers prior to allowing them to leave the site. The
Page 2 of 4
U:\MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UTV2015\RADMOD Emergency
2015\lnspectionReportRev0.doc
emergency response plan indicates in general terms that employees will be surveyed following an
evacuation but does not describe in detail how this would be accomplished under differing
circumstances, i.e. workers returning to the restricted area vs workers leaving the site from the
parking lot.
The drill demonstrated that an evacuation from the site can be quick, efficient, and thorough. It was
obvious that all were familiar with the exercise and executed it with no hesitation or question.
Conversion from MSDS to SDS
The deadlines for converting to the new SDS format are set by the Occupational Safety and Health
Administration. Employees were to be trained on the new SDS format by December 1,2013 and
compliance with all the new requirements will be effective June 1, 2015.
The Licensee conducted the training on the Globally Harmonized System (GHS) of classification
and labeling of chemicals during the May and June (2013) quarterly safety meetings covering
Hazcom and radiation safety. All employees were required to attend and the attendance is
documented on the Training Attendance Record.
The Licensee is in the process of updating all of the data sheets associated with the chemicals on
site. Binders for the new SDSs have been established which will mirror the binders for the MSDSs.
As the SDSs are received from the manufacturers of the products they are filed in the SDS binders.
Licensee compliance is dependent upon the manufacturers providing the updated data sheets. Since
the Licensee has an extensive library of MSDSs, ensuring that corresponding SDSs are on file in the
binders as well is challenging and cumbersome. It was suggested that a spreadsheet be devised
which would indicate the status of the each chemical with respect to the data sheet on hand. This
would facilitate looking up specific products without having to thumb through the binders.
The Licensee appears to be "on top" of this matter and is committed to comply with prescribed
changes. The Licensee has been proactive in striving for compliance in this regard. The Licensee
has generated the SDS for the Uranium Oxide product produced at the mill for distribution as
mandated. The Licensee still has to rely on the manufacturers to provide the SDSs of the materials
at the mill in order to achieve full compliance.
Exit Meeting
The inspector held an exit meeting with D. Turk of Energy Fuels Resources (USA) on March 12,
2015. The observations made during the inspection were summarized and discussed during the
meeting.
Conclusion
Based on the items inspected, it is concluded that the Licensee is in compliance with the
requirements of an Emergency Response Plan.
Page 3 of 4
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2015\lnspectionReportRev0.doc
Recommendations for the Licensee
In subsequent site evacuation drills, it should be emphasized to the workforce that if they are not
allowed to return to work in the restricted area or choose not to return that they must be screened for
radioactive contamination by a radiation safety technician prior to departing the site. This should be
stressed and discussed prior to terminating the drill. The Licensee may choose to expand in greater
detail in the plan the manner in which contamination is controlled during an evacuation of the site.
With regards to third party emergency responders the plan (Section 8.2) indicates thatthereis no
neecHo provide perirxhcTfrierrtatiorrt^ emergency response personnel sinceupon"
arrival during an emergency they will be met by mill staff who will escort them wherever they are
needed. The RSO indicated that the offsite emergency response community is relatively small and
that all have had opportunities to visit the site and have become familiar with the facility. There is
documentation that these visits have taken place. It is suggested that the plan describes how offsite
responders are or become familiar with the mill site rather than dismiss the need for them to be
given orientation tours prior to an event that requires their services.
In order to track the status of the safety data sheets for the various materials on site it is suggested
that a tool like a spreadsheet be created to readily identify the materials and to confirm the site has
the corresponding SDSs. If the capability exists, the Licensee may consider scanning the SDSs and
storing them in an electronic database to facilitate tracking and retrieval.
The minor changes to the Emergency Response Plan as noted by the RSO should be effected.
Recommendation for the DRC Director
It is recommended that no enforcement action in this regard be taken at this time.
Prepared By: Boyd M. Imai
(Name)
March 27, 2015
(Date)
Page 4 of 4
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2015\lnspectionReportRev0.doc
Inspection Report
ana
Inspection Checklist
RADMOD-Enwrgency-2015
INSPECTION REPORT
Inspection Module: RADMOD-Emergency-2015
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): March 12,2015
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: David Turk, Energy Fuels Resources (EFR)
Inspection Summary
The inspection was opened on March 12, 2015 with a meeting with D. Turk.
Areas/Topics inspected included:
• Follow-up to Prior Inspection
• Review of Emergency Response Plan
• Site Evacuation Drill
• Conversion from Material Safety Data Sheet (MSDS) to Safety Data Sheets (SDS)
The inspector held a closeout meeting on March 12, 2015 with D. Turk of EFR to review the
inspection activities, observations, and conclusions.
No infractions or violations were detected or encountered during the course of the inspection.
Inspection Items
Follow-up to Prior Inspection
• During the December 4, 2013 inspection the emergency fire/evacuation alarm system failed
to function when initiated for a routine evacuation drill. It was determined at the time that
the alarm system had been bypassed while maintenance was performed on other systems and
that when the maintenance work was completed the workers failed to reactivate the alarm
system. In order to prevent recurrence the control of the access to the alarm system has been
delegated solely to the Radiation Safety Officer (RSO). If the alarm system has to be shut
down for any reason the RSO, or designee, must be the one to provide access to the system.
The access is secured with a lock with the RSO in sole possession of the key. In this
manner, the RSO will always be aware of when the system is in a shutdown status.
• The critique for the biennial emergency response exercise conducted in November 2013 had
not yet been published at the time ofthe previous inspection. Once issued, the Licensee was
Page 1 of 4
U:\MON_WAST\Bimai\wp\InspectionsVEnergy Fuel, Blanding, UT\2015\RADMOD Emergency
2015\InspectionReportRev0.doc
Findings
requested to review the report and address any relevant issues that were identified in the
critique. The Licensee obtained a copy of the "Blue Mountain Hospital Operation Walking
Dead" After-Action Report/Improvement Plan which was a summary and critique of the
November 15, 2013 Full-Scale Exercise. The main focus of the exercise was the hospital's
handling of an emergency associated with a surge of patients from a transportation accident
involving hazardous materials. The Licensee participated in an ancillary capacity.
There were no criticisms or recommendations directed towards the Licensee's involvement
that needed to be addressed.
The Licensee will conduct its biennial exercise in 2015. Planning for this event was in its
infancy at the time of the inspection.
• Corrections and edits to the Emergency Response Plan were suggested in the course of last
inspection. The items were addressed in the revision of the plan.
Review of Emergency Response Plan
The plan (White Mesa Mill Emergency Response Plan, Book #16, Rev. No. R-3.0, December 2014)
had been revised since the last inspection and was reviewed to ensure that all the required elements
were retained in the revision.
Each element for an emergency response plan specified in Radiation Control Rules R313-22-32(c)
was identified in the Licensee's current plan.
The plan was significantly improved when revised. Emergency Response Guide excerpts were
updated as recommended during the last inspection. Duplicated Appendix designations were also
corrected. Other minor corrections had been made as suggested. The plan is a much "cleaner"
document than what was in place at the last inspection. It is better organized and easier to read and
follow, all around, a better document.
Minor corrections that should be addressed in the revised plan include changing the references to
Section 3.1.6 which should read Section 3.1.7. This reference occurs in two places: Section 6.4.1.3
and Appendix E of the plan. Also in Appendix E 14 a reference is made to exposure to "high
radiation" with respect to contamination when the intent is "high radiological contamination."
Site Evacuation Drill
The RSO was very accommodating for conducting the quarterly site evacuation drill during the
inspection where it could be directly observed. The alarm sounded without delay, the employees
evacuated in an orderly and timely manner, and there was an accounting for all personnel on sight.
It was noted that the majority of the personnel assembled outside the gate to the restricted area in the
parking lot of the administration building which raised the question of controlling potential
personnel contamination situations. It was apparent that the employees would return to the
restricted area and would be scanned out under routine area exit procedures. In the event the
workers could not be allowed back into the restricted area, the RSO indicated that radiation
technicians would be present to frisk the workers prior to allowing them to leave the site. The
Page 2 of 4
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\20I5RADMOD Emergency
2015\lnspectionReportRev0.doc
emergency response plan indicates in general terms that employees will be surveyed following an
evacuation but does not describe in detail how this would be accomplished under differing
circumstances, i.e. workers returning to the restricted area vs workers leaving the site from the
parking lot.
The drill demonstrated that an evacuation from the site can be quick, efficient, and thorough. It was
obvious that all were familiar with the exercise and executed it with no hesitation or question.
Conversion from MSDS to SDS
The deadlines for converting to the new SDS format are set by the Occupational Safety and Health
Administration. Employees were to be trained on the new SDS format by December 1, 2013 and
compliance with all the new requirements will be effective June 1, 2015.
The Licensee conducted the training on the Globally Harmonized System (GHS) of classification
and labeling of chemicals during the May and June (2013) quarterly safety meetings covering
Hazcom and radiation safety. All employees were required to attend and the attendance is
documented on the Training Attendance Record.
The Licensee is in the process of updating all of the data sheets associated with the chemicals on
site. Binders for the new SDSs have been established which will mirror the binders for the MSDSs.
As the SDSs are received from the manufacturers of the products they are filed in the SDS binders.
Licensee compliance is dependent upon the manufacturers providing the updated data sheets. Since
the Licensee has an extensive library of MSDSs, ensuring that corresponding SDSs are on file in the
binders as well is challenging and cumbersome. It was suggested that a spreadsheet be devised
which would indicate the status of the each chemical with respect to the data sheet on hand. This
would facilitate looking up specific products without having to thumb through the binders.
The Licensee appears to be "on top" of this matter and is committed to comply with prescribed
changes. The Licensee has been proactive in striving for compliance in this regard. The Licensee
has generated the SDS for the Uranium Oxide product produced at the mill for distribution as
mandated. The Licensee still has to rely on the manufacturers to provide the SDSs of the materials
at the mill in order to achieve full compliance.
Exit Meeting
The inspector held an exit meeting with D. Turk of Energy Fuels Resources (USA) on March 12,
2015. The observations made during the inspection were summarized and discussed during the
meeting.
Conclusion
Based on the items inspected, it is concluded that the Licensee is in compliance with the
requirements of an Emergency Response Plan.
Page 3 of 4
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\20I5\RADMOD Emergency
2015\InspectionReportRev0.doc
Recommendations for the Licensee
In subsequent site evacuation drills, it should be emphasized to the workforce that if they are not
allowed to return to work in the restricted area or choose not to return that they must be screened for
radioactive contamination by a radiation safety technician prior to departing the site. This should be
stressed and discussed prior to terminating the drill. The Licensee may choose to expand in greater
detail in the plan the manner in which contamination is controlled during an evacuation of the site.
With regards to third party emergency responders the plan (Section 8.2) indicates that there is no
need to provide periodic orientation tours for offsite emergency response personnel since upon
arrival during an emergency they will be met by mill staff who will escort them wherever they are
needed. The RSO indicated that the offsite emergency response community is relatively small and
that all have had opportunities to visit the site and have become familiar with the facility. There is
documentation that these visits have taken place. It is suggested that the plan describes how offsite
responders are or become familiar with the mill site rather than dismiss the need for them to be
given orientation tours prior to an event that requires their services.
In order to track the status of the safety data sheets for the various materials on site it is suggested
that a tool like a spreadsheet be created to readily identify the materials and to confirm the site has
the corresponding SDSs. If the capability exists, the Licensee may consider scanning the SDSs and
storing them in an electronic database to facilitate tracking and retrieval.
The minor changes to the Emergency Response Plan as noted by the RSO should be effected.
Recommendation for the DRC Director
It is recommended that no enforcement action in this regard be taken at this time.
Prepared By: Boyd M. Imai March 27, 2015
(Name) (^(Signature) (Date)
Page 4 of 4
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201 5\lnspectionReportRev0.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-Emergency-2015
EMERGENCY PLAN
ENERGY FUELS RESOURCES- WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT 1900479
References: Utah Administrative Code R313-22
DATE 3 ~ IZ - (S OPENING MEETING
MEETING MEMBERS
NAME DRC/COMPANY CONTACT INFORMATION
0
5
DISCUSSION
SITE STAFF COMMENTS
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Page 1 of 7
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.
(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 ofthe 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
U \COMMON\Uranium mills\UT1900479 EnergyFuels Res - While Mesa UMill\HP Inspection modules\2015\RADMOD-Emergency-20l5rev02 docx
Page 2 of 7
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,
(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 yz No
ll
2) Does the emergency plan contain a facility description? (A brief description of the licensee's facility
and area near the site.)
Comments: Yes A, No
tr~ .fit. . c \ _r
3) Type of Accidents—Does the emergency plan identify each type of radioactive materials accident for
which protective actions may be needed?
Comments: Yes X No
4) Classification of accidents. Does the emergency plan have a classification system for classifying
accidents as alerts or site area emergencies?
Comments: Yes )< No__
^ , ° *L n\a*
2) fife*. c%*OAry*~c^
3) £>n-SL-r-e £y+oJr<^-g^
U:\COMMON\Uranium mills\UT 1900479 EnergyFuels Res - White Mesa UMillVHP Inspection modules\2015\RADMOD-Emergency-2015rev02 docx
Page 3 of 7
5) Detection of accidents. Does the emergency plan identify the means of detecting each type of accident
in a timely manner?
Comments: Yes A No
'"TU^yU
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 /Q No
4* Ok
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 Xl No
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 \K No
^ 5.6 4fi* pts>^
ftaJ. S^(j.)a,l/j)
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 }Q No
U:\COMMON\Uranium mills\UT 1900479 EnergyFuels Res - White Mesa UMill\HP inspection modules\2015\RADMOD-Emergency-2015rev02.docx
Page 4 of 7
10) Information to be communicated. Does the emergency plan contain a brief description ofthe 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 K 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,
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 X No
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 X 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 PC No
. 9- *. -*—
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 y° No
3 , ^
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Page 5 of 7
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 exercises
although recommended is not required.)
Comments: Yes A No
13d) Exercises. Do exercises use accident scenarios postulated as most probable for the specific site?
Comments: Yes ^ No
13e) Exercises. Does the licensee critique each exercise using individuals not having direct
implementation responsibility for the plan?
Comments: Yes >C No_
13f) Exercises. Do critiques of exercises evaluate the appropriateness ofthe plan, emergency procedures,
facilities, equipment, training of personnel , and overall effectiveness of the response?
Comments: Yes X No
AJ&U<^laev- («=» 7<M3
13g) Exercises. Are deficiencies found by the critiques corrected?
Comments: Yes No
General Comments and Observations:
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Page 6 of 7
DATE 5/^/V5
CLOSEOUT MEETING
MEETING MEMBERS
NAME COMPANY CONTACT INFORMATION
DISCUSSION of FINDINGS
^3^43^(CA^4-gq-^v- c^u^nr^Sj JXVYUV^Q
T
SITE STAFF COMMENTS
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Page 7 of 7
Sa few Data Sheets
•Employee Training
• Uranium Oxl tie SDS
• Implementation Dates
Safety Meeting Schedule
May & June 2013
Hazcom / Quarterly Radiation
Aaron (D) Crew Fri.
Herschel (B) Crew Tues.
Maintenance Wed.
Utility Wed.
Frisbie (C) Crew Thurs.
Jerome ;A) Crew Mon.
May 31 7:00 A.M.
June 4 7:00 A.M.
June 5 9:30 P.M.
June 5 1:30 P.M.
June 6 7:00 A.M.
June 10 7:00 A.M.
Lab, W se, office and Scale house personnel please attend the meeting that
best fi: work schedule.
Anyon ; annot attend the meeting they are scheduled for please attend one
that is -ient or make other arrangements with the safety staff.
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:
GHS 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.
'*?\s Exatoelw*
"'• ,-Cr*mioalBant>lwup;denctosanura
Hazard OMSK Explosives, Sell Reactive* & Organic Peroxides
On
"*^.V Ctomtal can explode, rocket or harm heafth I thecyinder Is heated,
f ruptured or leaMno. Hazard Classes: Gases Under Pressure
QxWIzingchefTiteais can react wBJi^BvrnatenalsMusuigthemtotwrii or explode.
Hazard Classes: Oxidizers
Ramrrtablecrmiif^r^oatBhflra easily and burst into flames. Hazard Classes.' Rammabies, Self Reactlvte, Pyrophorics, Setf-Heating,
Emits Flammable Gas & Organic Peroxides
,pSc Chemical may be corrosive to metais and cause severe sMn burns and • ' endamage.
- Hazard Classes: Corrosives
Health Hazards
Health Hazards are determined by the properties of a chemical that can cause
illness or injury to people.
s\ toxic
ycasaV<- Exposure to the Is chemical can causa taedto art p<sslbry serious S**? rsajthnroblems,
\f Hazard Classes: Acute Toxicity (severe)
HMWI Hswd
j/W\ Chemical tnay cause aileron
> or the ui)bomehlld;rrHy causa g Hazard Classes: Carcipooon, Respiratory Sensitizer, Fteprtxtodtve Trafctty,
Target Organ Toxicity, Mutawrtdty & AspirattonTcsdclly
t ffitff 11 IHMrH f H0tft
CrHrrrWlstanrrMaiKiMnirrrmt89yes,sWr or respiratory systerrr, large < I > quantities are tatai
X. Hazard Classes Irritant, Derrr^
Effects, Respiratory Tract & Irrftatton
Environmental Hazards
Environmental Hazards cause an acute or long-term threat to the
aquatic environment
bwmxwwaol Toxicity
OvtgerouatoTttoAquatto
other Cle that Irve In fl»!ilW.
\/ Hazard Oaarn Envircnn^Toxidty
GHS Label Requirements
Signal Word Product Identifier
ToxiRam (Contains: XYZ)
DmoBfl Toxic It Swrtpwwd Rmunabia
mm tW •
Pictogram
In eaw of dm, m mtm too, dry dw«»^Cfcor"«toei)oi,^«m
/ aw tmm i*m tm mm in umi um nMtnnt—in—t\
Precautionary Statement Hazard Statement
1. Pictogram
An Identtebki symbol that conveys specific Irrfonnatkw about to
2. Product Identifier
Product name which matches prod^nanwefl the Safety Data Sh«
3. Signal Word
A single word used to indicate tne relative level ot severity ot a hazard
4. Hazard Statement
A etatement assigned to a Itazanl class and category des^
6. Precautionary Statement
A phrase descnlilrig tlie recornrw
netting from exposure to a hazardous chemical
GHS Safety Data Sheet (SD!
•SOS's Provide critical iriformalton for use ki
workplace chemical management
• Source of Wbrmatton about hazard to obtain a
cr? safety precautions
• Source of Hmafon for tnisporlrQ dangerous
• Enables employers to devetop active programs
workers protection measures
• 16 Sectta> format provides clarity ot data uset
Identify tlie hazards.
SOS's thai be dated aod eorttata tm
16 Section tormat for SDS
I. IdwtfftartJon of foe subsancs/mlxti
and of the cwnpanyAindortaajnrj
. nazaros lomntncautnt
3. r^n^miticn/MorHatto OH ingredi
4. Rnt-oM Rieasnres
5. Hre-flgftUng measttres
6. Accidental release measures
7. Handling and storage;
8. Exposure coimvfcc/persaaaJ prosecfo
9. PtrysteaJ and chemical properties
10. StaMltyatTdreacMty
II. Totdsologteal irrJorrnation
13. Disposal consideration?
14. Transport mfonnatton
15. Regulatory infonrtatlon
16. Other InJormatJon
Precautionary Statement Pictograrns
Precautionary Statement Pk^iarr«rk# convey warning^
alii
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ENERGYFUELS
Safety Data Sheet
Uranium Oxide (U308)
Energy Fuels Resouces (USA) Inc. requests that users of this EFR product study this data sheet to become
aware of the product's hazards, and promote safe handling of the product by making this information availble
to its employees, agents and contractors. If the material is resold, Energy Fuels Resources (USA) Inc. requests
that the purchaser be furnished a copy of this data sheet and advised to provide the information herein to its
employees, agents and contractors.
SECTION 1: CHEMICAL PRODUCTS & COMPANY IDENTIFICATION
EnergyFuels Resources (USA) Inc.
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
1.435.678.2221
Emergency Phone Number: 1.800.424.9300 (CHEMTREC)
Account #223794
Chemical Name: Uranium Oxide (U308)
SECTION 2: HAZARD IDENTIFICATION
OSHA Hazards:
Toxic by inhalation, toxic by ingestion.
Target Organs:
Kidney, Liver, Lungs, Brain.
GHS Label Elements:
Signal Words: Danger
Page 1 of 12
Hazard Statements
Toxic by inhalation and ingestion
Danger of cumulative effects
May damage kidneys
Precautionary Statements:
Avoid breathing dust
Avoid contact with skin, eyes and clothing
When using do not eat, drink or smoke
In case of accident or if you feel unwell seek medical advice immediately
Use only with adequate ventilation
GHS Classification:
Skin Irritation (Category 2)
Eye Irritation (Category 2)
Specific target organ toxicity - repeated exposure (Category 2)
Specific target organ toxicity - acute expsoure (Category 2)
GHS Hazard Ratings:
R23/25: Toxic by inhalation and ingestion
R33. Danger of cumulative effects
S20/21: When usmg do not eaty, drink or smoke
S45: In case of accident or if you feel unwell seek medical advice immediatelu
S61: Avoid release to the environment
SECTION 3: COMPOSITION/INFORMATION ON INGREDIANTS
Chemical Name: Uranium Oxide (U308), 100%
Common Names/Synonyms:
Uranium, Uranyl Oxides, Uranium Octaoxide, Uranous Oxide, Triuramum Octaoxide, Pitchblende, Uranite Nasturan,
CAS Number: 1344-59-8
SECTION 4: FIRST AID MEASURES
Indication of Immediate Medical Attention:
In all routes of exposure, seek medical treatment immediately See treatment/first aid measures below.
Necessary First Aid Measures:
INHALATION:
Remove from exposure area to a restricted area with fresh air as quickly as possible. If breathing has stopped,
perform artificial respiration by adminstratenng oxygen; mouth-to-mouth resuscitation should be avoided to prevent
exposure to the person rendering first aid Any evidence of serious contamination mdicates that treatment must be
Page 2 of 12
instituted. (Inhalation of radioactive particles may indicate that other parts of the body were also contaminated, such as
the digestive tract, skin and eyes.) If time permits, wipe the face with wet filter paper, force coughing and blowmg of the
nose. Get medical attention immediately. The victim may be contaminated with radioactive particles. Decontammate any
radiological contamination after mdividual is stabilzed from initial medical treatment. Any personnel involved in rendering
first aid must be monitored for radioactivity and thoroughly decontaminated if necessary (IAEA #3, Pg. 65).
SKIN CONTACT:
Remove victim to a suitable area for decontamination as quickly as possible. Remove clothing and shoes immediately.
Thoroughly wash the victim with soap and water, paying particular attention to the head, fingernails and palms of the
hands. Upon completion of washing, monitor the victim for radioactivity. It is imperative that the skin should be
decontaminated as quickly as possible. Minute skin injuries greatly increase the danger of isotope penetration into the
victim; shaving should not be attempted If water and soap have been inadequate in removing the radioactive compound,
decontaminating compounds consisting of surfactants and absorbent substances may be effective. Complexing reagents
may also be of use. The use of organic solvents is to be avoided, as they may increase the solubility and absorption of
the radioactive substance. Skin contamination with radiation may be an indiction that other parts of the body have been
exposed. Contaminated clothing must be stored in a metal container for later decontamination or disposal. The water used
to wash the victim must be stored in metal containers for later disposal. Any personnel involved in rendering first aid to
the victim must be monitored for radioactivity and decontaminated if necessary (IAEA #47, Pg. 9; IAEA #3, Pg. 62).
EYE CONTACT:
Remove victim to a resticted area for decontamination. Thoroughly wash eyes with large amounts of water, occasionally
lifting the upper and lower lids (approximately 15 minutes) Following the water treatment, provide an isotonic solution.
Do not lse eyebaths, rather provide a continuous and copious supply of fluid. Monitor the victim for radioactivity. If
activity is present, rewash the eyes, and re-monitor until little or no radioactivity is present Get medical attention
immediately. Any water used to wash the victim's eyes must be stored in a metal container for later disposal. Any other
articles that are used to decontaminate the victim must also be stored in metal containers for later decontamination or
disposal. Any personnel involved in rendering first aid to the victim must be monitored for radioactivity and
decontaminated if necessary (IAEA #3, Pg. 65; IAEA #47, Pg. 35).
INGESTION:
In the case of ingestion of radioactive substances, the mouth should be rinsed out immediately after the accident, care
being taken to swallow the water used for this purpose. Vomiting should be induced either mechanically, or with syrup of
ipecac. Do not induce vomiting in an unconscious person. Lavage may be useful. Care should be taken to avoid
aspiration. The vomitus and lavage fluids should be saved for examination and monitoring. Further action depends on the
nature ofthe radioactive substance. Get medical attention immediately. The gastric fluids and fluids used for lavage must
be stored in metal containers for later disposal The victim must be monitored for radioactivity and decontaminated, if
necessary, before being transported to a medical facility. Any personnel involved in rendering first aid to the victim must
be monitored for radioactivity and decontaminated if necaessary (IAEA #47, Pg. 9; IAEA #3, Pg. 59, 66).
NOTE TO PHYSICIAN:
There is no antidote for radiation sickness. Treatment should be symptomatic and supportive regardless of the dose
received. In all cases, medical attention should be obtained immediately.
Although chelating agents act on uranium, they should not be used because the increased migrant fraction leads through
renal precipitation to a greater kidney burden than would be received if there were no treatment at all; there is thus the risk
of serious toxic nephritis The basic treatment should be administration of a bicarbonate solution given locally and in
intravenous perfusion (one bottle of 250 mL at 1.4%). From IAEA safety series #47 - Manual on early medical treatment
of possible radiation injury - 1978. Pg 28
Most Important Symptoms/Effects, Acute and Delayed:
Page 3 of 12
INHALATION-
Short Term Exposure:
May cause irritation May cause kidney damage, yellowing of the skin and eyes, lack of appetite, nausea, vomiting,
diarrhea, dehydration, blood in the urine, weakness, drowsiness, incoordination, twitching, sterility, blood disorders,
convulsions and shock
Long Term Effects:
In addition to effects from short-term exposure, anemia, cataracts, lung damage, liver damage and bone effects may occur
INGESTION.
Short Term Expsoure: May cause kidney damage.
Long Term Effects: Same effects as short-term exposure.
SKIN CONTACT:
Short Term Exposure: May cause irritation.
Long Term Exposure: May cause irritation.
EYE CONTACT:
Short Term Exposure:
May cause irritation, redness and swelling. Additional effects may include sores and eye damage
Long Term Exposure:
In addition to effects from short-term exposure, cataracts may occur.
SECTION 5: FIRE FIGHTING MEASURES
Suitable Extinguishing Media:
Dry chemical, carbon dioxide, water spray or regular foam (2012 Emergency Response Guidebook, (ERG 2012), develope
jointly by Transport Canada (TC), the U.S. Department of Transportation (DOT) and the Secretariat of Transportation and
Communications of Mexico (SCT).) For larger fires, use spray or foam (flooding amounts)(2012 Emergency Response
Guidebook, ERG 2012.)
Fire and Explosion Hazard:
Negligible when exposed to flame or heat.
Hazardous Combustion Products:
Thermal decomposition may release toxic/hazardous gases.
Special Protective Equipment and Precautions for Fire-Fighters:
Move container from fire area if you can do it without risk. Apply cooling water to sides of containers exposed to flames
until well after fire is out (2012 Emergency Response Guidebook, ERG 2012).
Do not move damaged containers; move undamaged contamers out of fire zone. For massive fires in cargo area, use
unmanned hose holder or monitor nozzles (2012 Emergency Response Guidebook, ERG 2012).
Contact the local, State or Department of Energy radiological response team. Use suitable agent for surrounding fire.
Cool containers with flooding amounts of water, apply from as far a distance as possible. Avoid breathing dusts or
vapors, keep upwind. Keep unnecessary people out of area until declared safe by radiological response team.
Page 4 of 12
SECTION 6: ACCIDENTAL RELEASE MEASURES
Personal Protections and Protective Equipment:
Do not touch damaged containers or spilled material. Damage to outer container may not affect primary inner container.
Emergency Procedures/Methods and Materials for Containment and Clean-up:
For small hguid spills, take up with sand, earth or other absorbent material. For larger spills, dike far ahead of spill for late
disposal. Keep unnecessary people at least 150 feet upwind, greater distances may be necessary if advised by qualified
radiation authority. Isolate hazard area and deny entry. Enter spill area only to save life; limit entry to shortest possible
tune. Detain uninjured persons and equipment exposed to radioactive material until arrival or instruction of qualified
radiation authority. Delay cleanup until arrival or instruction of qualified radiation authonty.
SECTION 7: HANDLING AND STORAGE
Precautions for Safe Handling:
Avoid contact with skin, eyes and clothing. When using do not eat, drink or smoke. Avoid breathing dust. Wash
thoroughly after handling. Use only with adequate ventilation.
Conditions for Safe Storage:
Store in radioactive materials area. Keep storage container tightly closed. Store separately from incompatible materials.
Observe all Federal, State and Local regulations regarding storage of this substance.
SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION
Exposure Limits:
Uranium, insoluble compunds (As U):
0.05 mg/m3 OSHA PEL-TWA
0 2 mg/m3 ACGIH TWA; 0.6 mg/m3 ACGIH STEL
0.2 mg/m3 NIOSH Recommended TWA; 0.6 mg/m3 NIOSH Recommended STEL
Occupational exposure to radioactive substances must adhere to standards established by the Occupational Safety and
Health Administration (OSHA). 29 CFR 1910.96, and/or the Nuclear Regulatory Commission (NRC), 10 CFR Part 20. Fc
DOE and its contractors 10 CFR 835, Occupational Radiation Protection must be follwed.
Engineering Controls:
VENTILATION.
At a minimum, provide local exhaust or process enclosure ventilation. Depending upon the specific workplace activity and
the radioactivity of the isotope, a more stringent ventilation system may be necessary to comply with exposure limits set
forth by law (10 CFR 20.103).
RADIATION SHIELDING:
One method of controlling external radiation exposure is to provide adequate shielding The absorbing material used and
the thickness required to attenuate the radiation to acceptable levels depends on the type of radiation, its energy, the flux
and the dimensions of the source.
ALPHA PARTICLES:
For the energy range of alpha particles usually encountered, a fraction of a millimeter of any ordinary material is sufficient
for absorbance Thin rubber, acrylic, stout paper or cardboard will suffice.
Page 5 of 12
BETA PARTICLES
Beta particles are more pentrating than alpha, and require more shielding. Matenals composed mostly of elements of low
atmoic number such as acrylic, aluminum and thick rubber are most appropriate for the absorption of beta particles. For
example, 1/4 inch of acrylic will absorb all beta particles up to 1 MeV. With high-energy beta radiation from large sources
Bremsstrahlung (X-ray production) contribution may become significant and it may be necessary to provide additional
shielding of high atomic weight material, such as lead, to attenuate the Bremsstrahlung radiation.
GAMMA RAYS:
The most suitable materials shielding gamma radiation are lead and iron. The thickness required would depend on whether
the source is producing narrow or broad beam radiation. Primary and secondary protective barriers may be required to
block all radiation.
Personal Protective Equipment:
EYE PROTECTION:
Employee must wear appropriate eye protection that will not allow the introduction of particles into the eyes. Contact
lenses should not be worn.
Clothing , glove and eye protection equipment will provide protection against alpha aprticles, and some protection against
beta particles, depending on thickness, but will not shield gamma radiation
CLOTHING:
Disposable overgarments, including head coverings and foot covenng, should be worn by any employee engaged in
handling any radioactive substance. These garments are also recommended even if the employee is working with a
"glovebox" containment system. Certain clothing fibers may be useful in dosimetry so clothing should be kept.
In the event of an accident, large-scale release or a large-scale clean-up full protective clothing will be necessary.
GLOVES-
Employee must wear appropriate protective gloves to prevent contact with this substance. Used gloves may present a
radiation hazard and should be disposed of as radioactive waste.
RESPIRATOR:
The following respirators and maximum use concentrations are recommendations by the U.S. Department of Health and
Human Services, NIOSH pocket guide to chemical hazards, NIOSH criteria documents or by the U.S. Department of Laboi
29 CFR 1910 Subpart Z.
The specific respirator selected must be based on contamination levels found in the work place, must not exceed the
working limits of the respirator and be jointly approved by the NIOSH and the Mine Safety and Health Administration
(MSHA).
AT ANY DETECTABLE CONCENTRATION
Any self-contained breathing apparatus that has a full facepiece and is oriented in a pressure-demand or other
positive-pressure mode.
Any supplied air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode
in combination with an auxiliary self-contianed breathing apparatus operated in pressure-demand or other
positive-pressure mode.
Escape - any air-purifying, full facepice respirator with a high efficiency particulate filter.
Any appropriate escape typ, self-contained breathing apparatus.
Page 6 of 12
FOR FIREFIGHTING AND OTHER IMMEDIATELY DANGEROUS TO LIFE OR HEALTH CONDITIONS:
Any self-contained breathing apparatus that has a full facepiece respirator with a high-efficiency particulate filter.
Any supplied air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure
mode in combination with an auxiliary self-contained breathing apparatus operated in pressure-demand or other
positive-pressure mode.
SECTION 9: PHYSICAL AND CHEMCIAL PROPERTIES
Appearance:
Odor:
Odor Threshold:
pH:
Melting Point:
Freezing Point:
Boiling Point:
Flash Point:
Evaporation Point:
Flammabilitv:
Explosive Limits:
Vapor Pressure:
Vapor Densitv:
Relative Densitv:
Solubility:
Partition Coefficient:
Auto-Ignition Temperature:
Decompostion Temperature:
Viscosity:
Molecular Weight:
Molecular Formula:
Specific Gravity:
Chemical Family:
Dark green or black, dense, radioactive powder or crystals
N/A
N/A
N/A
1,300°C (2,372°F) decomposes
N/A
Decomposes
Non-flammable solid
Data Not Available
Data Not Available
Data Not Available
N/A
N/A
Data Not Available
Water Solubility: Insoluble. Solvent Solubility: Nitric acid, sulfuric acid
Data Not Available
Data Not Available
Data Not Available
Data Not Available
Approximately 833 to 842 (dependmg on enrichment)
u3o8
8.3
Metal oxide, radioactive
The half-lives of the various uranium isotopes are as follows:
233U = 1 59 X 105 y; 234U = 2.47 X 105 y, 235U = 7.04 X 108 y; 236U = 2.39 X 107 y; 238U = 4.51 X 109 y.
The specific activities of the various uranium isotopes are as follows:
233U = 3.6 X 102 MBq/g (9.7 X 10"3 Ci/g)
234U = 2.3 X 102 MBq/g (6 2 X 10"3 Ci/g)
235U = 7.8 X 10"2 MBq/g (2.1 X 10"6 Ci/g)
236U = 2.3 MBq/g (6.3 X 10"5 Ci/g)
238U = 1.2 X 10"2 MBq/g (3.3 X 10"7 Ci/g)
Page 7 of 12
SECTION 10: STABILITY AND REACTIVITY
Reactivity:
Chemical Stability:
Possibility of Hazardous Reactions:
Conditions to Avoid:
Incompatible Materials:
Hazardous Decomposition Products:
See below
Stable under normal temperatures and pressures.
No potentially hazardous conditions could be found in the literature, nor could any
accidents be recalled in which uranium oxide reacted in a hazardous manner.
Excessive heat
Bromine Trifluonde: Reaction is rapid below the boiling point of the tnfluonde.
Thermal decompostion may release hazardous and toxic gases.
SECTION 11: TOXICOLOGY INFORMATION
Likely Routes of Exposure: Inhalation, ingestions, skin and eye contact.
Uranium oxide is a skin, eye and mucous membrane irritant, as well as a nephrotoxin. Chronic inhalation may affect the
lungs and lymph nodes. Pneumoconiosis may occur. If uranium is deposited in the bone, there is a potential for blood
disorders such as anemia and leukopenia. In humans, cancer of the lung, lymphatic and hemopoietic systems, and
osteosarcoma have been reported Uranium compounds usually do not constitue an external radiation exposure hazard
since uranium emits mainly alpha-radiaiton at a low energy level. It may constitute an internal radiation hazard if it is
absorbed into the body, thus delivering alpha emission onto tissues in which it is stored. Significant quantities of highly
enriched material may also pose a gamma radiation hazard.
INHALATION
RADIOACTIVE/NEPHROTOXIN. 30 mg/m3 immediately dangerous to life and health.
Acute Exposure: May cause irritation.
Chronic Exposure: In animals, replaced inhalation of insoluble uranium compounds resulted in fibrotic
changes indicative of radiation damage in the lungs and tracheobronchial lymph
nodes. Pneumoconiosis may occur If uranium is deposited in the bone, there is a
potential for blood disorders such as anemia and leukopenia. In humans, cancer of the
lung, lymphatic and hemopoietic systems, and osteosarcoma have been reported.
Uranium is a nephrotoxin and exposure may lead to kidney failure. Kidney failure may
result in liver damage. See the following section on effects of alpha radiation and
radiation sickness.
ALPHA RADIATION
Acute Exposure: Alpha radiation is densely ionixing with very high energy and will kill cells immediately
adjacent to the source of contact. Damaged cells may not recover or be repaired. Alpha
emitters may or may not be absorbed, depending on the solubility and particle size.
Insoluble compounds may remain at or near the site of deposition, and soluble
compunds may rapidly enter the bloodstream. Heavier particles will be brought up to
the throat by ciliary action, and may then be swallowed. The lighter particles may be
lodged deep in the alveoler air sacs and reamin. The damage depends on how quickly
they are eliminated, and the susceptibility of the tissue in which they are stored. A
single large dose of radiation may lead to radiation sickness.
Page 8 of 12
Chronic Exposure: The effects of chronic exposure by internally deposited alpha radiation are dependent
upon the dose and target organ(s). If the total dose is sufficient, radition sickness may
occur. Possible disorders include lung cancer, sterility, anemia, leulemia, or bone cancel
RADIATION SICKNESS
Acute Exposure: Whole body doses of 200-1000 Rads may cause anorexia, apathy, nausea and vomiting
and may become maximal within 6-12 hours An asymptomatic period of 24-36 hours
may be followed by lymphopenia and slowly developing neutropenia.
Thrombocytoenia may become prominent within 3-4 weeks. The lymph nodes, spleen
and bone marrow may begin to atrophy. If bone marrow depression reaches a critical
level, death may occur from overwhelming infection. Whole body doses of 400 or more
Rads may cause intractable nausea, vomiting and diarrhea that may lead to severe
dehydration, vascular collapse and death. Regeneration of the intestinal epithelium may
occur, but may be followed by hematopoietic failure within 2-3 weeks. Whole body
doses of 600 or more Rads may be fatal due to gastrointestinal or hematopoietic
malfunction, with doses fatal <600 Rads, the possibility of survival is inversely related
to the dose Whole body doses >3,000 Rads, generally cause nausea, vomitmg,
hstlessness, and drowsiness ranging from apathy to prostration, temors, convulsions,
ataxia and death within a few hours. The gonads are also particularly radiosensitive
among men. In women, loss of fertility may be indicated by loss of menstruation.
Chronic Exposure: The delayed effects of radiation may be due either to a single large overexposure or
continuing low-level overexposure and may include cancer, genetic effects, shortening
of life span and cataracts. Cancer is observed most frequently in the hematopoietic
system, thyroid, bone and skin. Leuemia is among the most likely forms of malignancy.
Lung cancer may also occur due to radioactive materials residing in the lungs. Genetic
effects may range from pomt mutations to severe chromosome damage such as strand
breakage, translocations, and deletions. If the germ calls have been affected, the effects
of the mutation may not become apparent until the next generation, or even later.
SKIN CONTACT
Acute Exposure: There is no evidence that insoluble uranium compunds can be absorbed through the
skin, insoluble salts produced no signs of poisoning after skin contact. Animal tests on
a variety of uranium compounds caused varying degrees of eye damag, with the oxides
causing the mildest. Uranium oxide may irritate the skin.
Chronic Exposure: Prolonged skin contact with insoluble uranium compunds should be avoided because of
potential radiation damage to basal cells. Dermatitis has occurred as a result of handling
some insoluble uranium compounds. Repeated or prolonged contact may cause
conjunctivitis. Cataract formation as in acute exposure may occur with significant
exposure See the following sections regarding alpha radiation and radiation sickness.
ALPHA RADIATION
Acute Expsoure: Alpha radiation is not usually an external hazard. However, local damage may occur at
the site of a wound. Absorption or penetration through damaged skin may result in
radiation sickness.
Chronic Exposure: Prolonged or repeated contact my result in radiation sickness
Page 9 of 12
RADIATION SICKNESS. The clinical course of radiation sickness depends upon the dose, dose rate, area of the
body affected and time after exposure. External and internal radioactivity of any type
may cause radiation sickness
EYE CONTACT
Acute Exposure:
Chronic Exposure:
ALPHA RADIATION
Acute Exposures:
Chronic Exposure:
RADIATION SICKNESS
INGESTION
Acute Exposure:
Chronic Exposure:
Radiation sickness has three (3) clearly defined syndromes, which are described in detail
in the inhalation section.
Dust may be irritating to the eyes. A variety of soluble and insoluble compounds of
uranium were tested on the eyes of rabbits. The insoluble compounds caused the
mildest degree of injury. The effects of eye contact with any uranium tend to be
necrosis ofthe conjunctivae and eyelids, and ulceration of the cornea.
Prolonged exposure to uranium may produce conjunctivitis, or the symptoms of
radiation injury, such as cataracts. See the following sections regarding the effects of
alpha radiation on the eyes, and radiation sickness.
Radiation affects the eye by inducing acute inflammation of the conjunctiva and the
cornea. The most sensitive part of the eye is the crystalline lens. A late effect of eye
irradiation is cataract formation. It may begin anywhere from 6 months to several years
after a single exposure. Cataract formation begins at the posterior pole ofthe lens, and
continues until the entire lens has been affected. Growth of the opacity may stop at any
point. The rate of growth and the degree of opacity are dependent upon the dose of
radiation.
Repeated or prolonged exposure to alpha radiation may result in cataract formation, as
described above. Of the well-documented late effects of radiation on man, leukemia and
cataracts have been observed at doses lower than those producing skin scarring and
cancer or bone tumors. The lens of the eye should be considered to be critical organ.
The eyes are very radiosensitive; a single dose of 100 Rads may cause conjunctivities
and keratitis. It is unlikely that a dose sufficient to cause radiation sickness would occur
if only the eyes were irradiated. However, if eye damage by ionizing radiation occurs. I
may be best to assume that other parts of the body have also been contaminated.
Symptoms of radiation sickness are described in the inhalation section
Feeding studies on animals indicate that insoluble uranium is much less toxic than
soluble uranium compounds. Uranium entering the bloodstream will become stored in
the bone marrow, but the majority will become lodged in the kidney, which is the major
site of toxicity. More than a year and a half are requned to nd the body of an accidental
high dose of uranium, after which time measurable uranium is present in the bone and
kidney
The toxic action of uranium resides more in its chemcial action on the renal tubules,
rather than radiation effects. Rats injected with uranium metal in the femoral marrow
developed sarcomas, whether this was due to metallocarcinogenic or radiocarcinogenic
ingestion of alpha emitters, and radiation sickness. Also see the first aid section for
uranium compounds
Page 10 of 12
ALPHA RADIATION
The fate of ingested alpha emitters depends on their solubility and valence. High doses
may lead to radiation sickness as described in inhalation exposure
Repeated ingestion of alpha emitters may lead to radiation sickness as described in
inhalation expoure
The symptoms of radiation sickness depends upon the dose received. It may result
from acute or chronic exposure to any form of radiation. The symptoms are described in
the inhalation section.
OSHA: N
NTP: N
IARC: N
SECTION 12: ECOLOGICAL INFORMATION
Environmental Impact Rating (0-4): No data available
Acute Aquatic Toxicity: No data available
Degradability: No data available
Log Bioconcentration Factor (BCF): No data available
Log OctanolAVater Partition Coefficient: No data available
SECTION 13: DISPOSAL INFORMATION
Observe all Federal, State and Local regulations when disposing of this substance.
SECTION 14: TRANSPORTATION INFORMATION
The U.S. Department of Transportation (DOT) Code of Federal Regulations (49 CFR Parts 100-185), the International Air Transportation
Association (IATA), International Civil Aviation Organization (ICAO) and International Maritime Orgnaization (IIMDG) are all factored into 1
classification and transport of material.
Proper Shipping Name Radioactive Material, low specific activity (LSA-1)
Hazard Class: 7
UN/ID Number: 2912
Special Information: None
Packing Group: None
Classification of substances with multiple hazards must be determined in accordance with the criteria presented in the above mentioned
regulations. Due to the various quantities/combinations of matenals being shipped at one time, the information above must be determined
based on the characteristics of the specific shipment.
Acute Exposure:
Chronic Exposure:
RADIATION SICKNESS
CARCINOGEN STATUS:
Page 11 of 12
SECTION 15: REGULATORY INFORMATION
TSCA STATUS:
CERCLA SECTION 103 (40 CFR 302 4) N
N
N
N
SARA SECTION 302 (40 CFR 355.30)
SARA SECTION 304 (40 CFR 355.40)
SARA SECTION 313 (40 CFR 372.65)
OSHA PROCESS SAFETY (29 CFR 1910.119) N
CALIFORNIA PREPOSITION 65: N
SARA HAZARD CATEGORIES, SARA SECTIONS 311/312 (40 CFR 370.21)
ACUTE HAZARD. Y
CHRONIC HAZARD: Y
FIRE HAZARD: N
REACTIVITY HAZARD. N
SUDDEN RELEASE HAZARD: N
SECTION 16: OTHER INFORMATION
The information and recommendations set forth herein are presented in good faith and believed to be correct as of the revision date. However,
receipients of this material should use this information only as a supplement to other information gathered by them, and should make
judgement of the suitablihty and accuracy of this information. This statement is not intended to provide comprehensive instruction in
developmg an appropriate safety program and does not include all regulatory guidelines
This information is furnished without warranty, and any use of the product not in confrmance with this Safety Data Sheet, or in combination
with any other product or process, is the responsibility of the user.
Creation Date: September 5,2013 Revision Date: September 5,2013
Page 12 of 12
Table XIII-3--Effective Dates and Requirements
Effective completion date Requirement(s) Who
December 1, 2013.
June 1, 2 015
and
December 1, 2015,
June 1, 2016,
Transition Period 5/25/12 to the
effective completion dates noted
distributors, and
above.
Train employees on the new label elements
and SDS format.
Compliance with all modified provisions of
this final rule, except:
The Distributor shall not ship containers
labeled by the chemical manufacturer or
importer unless it is a GHS label.
Update alternative workplace labeling and
hazard communication program as
necessary, and provide additional
employee training for newly identified
physical or health hazards.
May comply with either 29 CFR 1910.1200
(this final standard), or the current
standard, or both.
Employers.
Chemical manufacturers,
importers, distributors
employers.
Employers.
Chemical manufacturers,
importers,
employers.
5 D 5
Page 1 of 1
Effective Dat.es
In the proposal, OSHA solicited comments regarding whether it would
be feasible for employers to train employees regarding the new labels
and SDSs within two years after publication of the final rule.
Additionally, OSHA inquired as to whether chemical manufacturers,
importers, distributors, and employers would be able to comply with all
the provisions of the final rule within three years, and whether a
phase-in period was necessary
OSHA received many comments and heard testimony regarding the
effective dates which are discussed in detail in Section XIII below.
First, after analysis of the record, the Agency has determined that
covered employers must complete all training regarding the new label
elements and SDS format by December 1, 2013 since, as supported by
record, employees will begin seeing the new style labels considerably
earlier than the compliance date for labeling. Second, OSHA is
requiring compliance with all of the provisions for preparation of new
labels and safety data sheets by June 1, 2015. However, distributors
will have an additional six months (by December 1, 2015) to distribute
containers with manufacturers' labels in order to accommodate those
they receive very close to the compliance date Employers will also be
given an additional year (by June 1, 2016) to update their hazard
communication programs or any other workplace signs, if applicable.
Additionally, OSHA has decided not to phase in compliance based on
whether a product is a substance or a mixture. OSHA has concluded that
adequate information is available for classifiers to use to classify
substances and mixtures. Finally, as discussed in the NPRM, employers
will be considered to be in compliance with the HCS during the
transition period as long as they are complying with either the
existing HCS (as it appears in the CFR as of October 1, 2011) or this
revised HCS. A detailed discussion regarding the effective dates is in
Section XIII.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?ptable=FEDERAL_REGIST... 3/3/2015
Off site Emergency Responder
Site Orientation
EMS Visit
Agenda
9/25 2013 @ 1900 HRS
The EMS team has developed concerns about radiation exposure and possible contamination to
themselves and equipment. These concerns have arisen during the mock incident training held
previously and as a result of the few ambulance trips to the mill. In an attempt to alleviate those
concerns and to provide continued training with this group they were invited for a mill tour and a
training session.
Primary objective is educate the EMS to possible radiation concerns and demonstrate, that the concern
is real, the exposure is minimal and the real hazards at the mill are chemical and industrial in nature.
1900 hrs
Greet and issue hard hats and safety glasses. Speak about radiation and the Alpha Survey at the end of
the mill tour.
Mill tour: Includes discussion of the mill process and chemicals used. Point out current work areas and
discuss the industrial hazards
Scan back in and review the mill process and lead a more in depth discussion about the chemical hazards
associated with the process. Question and answers.
Talk about the radiation exposure risk. Demonstrate the alpha and beta-gamma meters use sources to
show the difference. Answer question and discuss the procedure we use to scan the ambulance, the
personnel and the ER when an employee is transported.
General discussion of the concerns they may have and develop an ongoing training needs agenda.
Dale itz*In>
Time started g IW
Training Attendance Record
Instructor.
Time ended Zt&ci Total Time_
Subject, am (ttf
Full Name Social Security No. Job Classification
^/
ems
Outline Comments
2013 Biennial Emergency
Response Exercise
Crttinue
Blue Mountain Hospital
Operation Walking Dead
After-Action Report/Improvement Plan
November 15, 2013
This After-Action Report/Improvement Plan (AAR/IP) was developed from the evaluation of
activities which took place during a hazardous materials spill resulting in a patient surge to Blue
Mountain Hospital. This document contains compiled notes, evaluation points and feedback
from participants, evaluators and exercise staff.
After-Action Report/
Improvement Plan (AAR/IP)
t
Exercise Name
Exercise Dates
Core
Capabilities
Objectives
Threat or
Hazard
Scenario
Sponsor
Participating
Organizations:
Number of
Participants
EXERCISE OVERVIEW
Blue Mountain Hospital Operation Walking Dead Full-Scale Exercise
November 15, 2013, 9am - 12pm MT
Communications, Command Function, Patient Reception and Treatment,
Patient Decontamination, Safety and Security
1. Test activation of hospital disaster plan including stand up of Hospital
Command Center, notification of hospital staff, and recall of staff as
appropriate.
2. Evaluate communication with first responders, other healthcare
agencies, and internal staff.
3. Test hospital patient decontamination procedures in response to a
hazardous materials incident.
4. Evaluate hospital security and access control related to a hazardous
materials incident.
Hazardous Materials Incident Resulting in Patient Surge
On November 15 around 10am, a traffic accident occurred on Highway 191
at Shirttail Junction. A placarded tractor-trailer carrying hazardous materials
collided with a SUV and resulted in the tanker truck tipping on its side
spilling its contents. The drivers of the truck and SUV along with two
passengers are injured in the crash. Passing motorists have stopped to help
and called 911.
Blue Mountain Hospital, Blanding, UT
Blue Mountain Hospital: 11
San Juan County EMS: 5
Blanding Fire Department: 13
EnergyFuels: 3
All Clear Emergency Management Group: 2
Cari Spillman, AEMT
Emergency Manager/ER Tech Manager
Blue Mountain Hospital
Exercise Overview 1 Blue Mountain Hospital
FOUO - FOR OFFICIAL USE ONLY
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
802 South 200 West
Blanding, UT 84511
435-678-4677 (office)
[e-mail]
Ginny Schwartzer
Vice President
All Clear Emergency Management Group, LLC
3434 Edwards Mill Road, Suite 112-162
Raleigh, NC 27612
336-802-1800 (office)
[e-mail]
Exercise Overview 2 Blue Mountain Hospital
FOUO - FOR OFFICIAL USE ONLY
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
EXECUTIVE SUMMARY
Blue Mountain Hospital Operation Walking Dead Full-Scale Exercise was developed to test the
hospital's response to a hazardous materials incident requiring patient decontamination. The
exercise and evaluation was designed through a coordinated effort utilizing a planning team
consisting of representatives of the Blue Mountain Hospital Emergency Management
Committee, San Juan County EMS, Blanding Fire Department and Energy Fuels. All Clear
Emergency Management Group was contracted to design, conduct and evaluate the exercise for
Blue Mountain Hospital.
The exercise was designed to test specific activities that take place during a hospital emergency
involving a surge of patients from a transportation accident involving hazardous materials. The
activities evaluated during this exercise included Communications, Command Function, Patient
Reception and Treatment, and Safety and Security.
The purpose of this report is to analyze exercise results, identify strengths to be maintained and
built upon, identify potential areas for further improvement, and support development of
corrective actions.
Major Strengths
The major strengths identified during this exercise are as follows:
• Command cart resources are at the ready including charged radios, vests and
documentation.
• Staff completed timely notification of incident including the decision to call a Code
Orange.
• Staff participation in the exercise was excellent with some staff even coming in on off
days.
Primary Areas for Improvement
Throughout the exercise, several opportunities for improvement in the BMH's ability to respond
to the incident were identified. The primary areas for improvement are as follows:
• More training and practice of the use of HICS and greater understanding of roles
within the structure is needed.
• Formal documentation should be completed throughout an incident including incident
action plans, staffing assignments, and patient tracking.
• Review radio use procedures and etiquette for staff within the hospital.
Analysis of Core Capabilities 3 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
ANALYSIS OF RESPONSE
Evaluation took place at the scene, in the patient decontamination area, and at hospital command.
The following information is compiled by focus area. The analysis and recommendations were
compiled from evaluator reports and participant feedback shared with evaluators.
Communications
The strengths and areas for improvement for each focus area are described in this section.
Strengths
The following strengths were demonstrated during the exercise:
Strength 1: Once BMH staff learned of the incident, a Code Orange was initiated as an
overhead page within the hospital to notify of incoming patients.
Strength 2: Good communication between EMS and Fire Department was observed on the
scene.
Areas for Improvement
The following areas require improvement to achieve the full capability level:
Area for Improvement 1: No official notification to BMH was made from the scene/dispatch.
ED staff overheard the radio transmission from dispatch to the scene and pieced together what
the situation was. BMH was able to get patient information from EMS on arriving patients, but
no information was given about the chemical involved until after patients arrived. In a real
event, dispatch would be contacting BMH to provide additional information. Dispatch was only
used for the initial call during the exercise.
Analysis: Review and practice notifications to all agencies during drills and real events.
Include dispatch involvement in future drills to practice. Consider adding a quick
reference guide to the radio monitoring station to prompt asking for key information
when an event is happening. This can include number of patients, acuity, environmental
effects (temperature, hazardous materials), etc. Situational information is very important
to give the hospital lead time to prepare for incoming patients, especially if patient
decontamination will be needed.
Area for Improvement 2: While hospital staff utilized radios within the hospital effectively,
radio etiquette could be improved to avoid talking over one another.
Analysis: Internal radios can be a very efficient way to communicate within the hospital
especially if the hospital command center is located outside of the immediate action area.
Staff training should be held on proper radio etiquette to avoid cutting of communication
transmissions. During an event radio assignments should be formally made and
documented. Numbering radios may be helpful for tracking purposes.
Area for Improvement 3: Ensure formal communication is made from ED to Incident
Command.
Analysis of Core Capabilities 4 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Analysis: During the exercise the Incident Commander was located in the ED and was
privy to much of the information and situational status of activities in the ED. If
command was moved to a separate command center, formal communication will need to
be made to keep the command staff informed of what was happening. Include this
situational awareness consideration on job action sheets for the IC and the ED.
Command Function
Strengths
The following strengths were demonstrated during the exercise:
Strength 1: A briefing was held by the IC to pull the team together to discuss planning
considerations for the event, assign roles, and assess needs for supplies, equipment, etc.
Strength 2: IC expressed that good situational awareness was maintained with regard to the
activities happening within the hospital.
Areas for Improvement
The following areas require improvement to achieve the full capability level:
Area for Improvement 1: Formal documentation of assignments, activities, and decisions was
lacking.
Analysis: Documentation was not formally completed during the exercise. Staffing
assignments were made early on in the event, but not formally documented. Because the
conference room command center was not utilized, the HICS whiteboard was not
available. If command is located outside of the conference room, ensure staff
assignments are documented on paper or another means.
An assigned scribe to document activities right alongside the IC would be very helpful in
capturing the key information.
Area for Improvement 2: Command cart resources for documentation were not used
effectively.
Analysis: In addition to radios and vests, HICS binders were available for reference in
the command cart. These are excellent resources to utilize during an event. Review with
all staff to train on use of the HICS forms. While the IC did well in planning and
anticipating needs, many decisions were off the cuff and informal. The job action sheets
and checklists available in the binders would help formalize the decision making
processes and ensure all aspects of the event are considered and planned for accordingly.
Area for Improvement 3: Staff was unsure of ICS implementation.
Analysis: At times staff was unsure of how the incident command system was being
used. One participant commented on the feedback form that she was assigned to one task
but then moved to another and it was unclear of what her role should have actually been.
Additional documentation of the organizational chart would be helpful to post for all staff
to see the roles assigned and how they fit in the larger organization.
Analysis of Core Capabilities 5 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Additional training should be held with all staff to more fully educate on HICS and roles
for the BMH structure. Also a more clearly defined role should be made for the charge
nurse assigned as operations chief to distinguish between patient care role and operations
role.
Area for Improvement 4: No incident action plan was formed during the event.
Analysis: During an event, an incident action plan should be made to determine the
objectives and priorities of activities completed in the next operational period. While the
IC did try to anticipate items he would need such as supplies, a more formal process
would help guide the command staff in their activities. The IC should periodically
review the IAP and re-evaluate where resources should be directed. Additionally regular
briefings will help keep situational awareness with the whole team.
Patient Reception and Treatment Area:
Strengths
The following strengths were demonstrated during the exercise:
Strength 1: Bed availability was evaluated initially to determine if any stable patients could be
moved to make additional space.
Strength 2: Patients (victim actors) reported nursing staff were very caring, efficient, and tried
to provide comfort to their injuries.
Strength 3: BMH staff should be commended for excellent participation in the exercise. Many
staff came in on their day off to participate in the pre-exercise decon training and then participate
in the exercise.
Areas for Improvement
The following areas require improvement to achieve the full capability level:
Area for Improvement 1: Nursing staff in ED left assigned patients.
Analysis: Nurses were assigned to patients as they were brought in from decon. At
times patients were left alone while nurses completed other tasks. One patient was left
unattended in the ED for an extended period of time. It was unclear at times which nurse
was assigned to which patient. It may be helpful to have a chart where each patient is
assigned a nurse for quick reference in the ED.
Area for Improvement 2: Patient tracking was not completed until late into the exercise.
Analysis: Patient tracking was started over an hour into the exercise and upon prompting
from exercise staff. The IC began to fill in where each patient was, but was more
difficult to do late in the game. Patient tracking is an important part to maintaining
situational awareness during a multi-victim event. The tracking board in the ED seemed
like an appropriate tool for tracking purposes. Tracking should be included as a priority
assignment during an event. Also the IC does not need to complete this task; this can be
assigned to another member of the HICS structure to allow the IC to focus on other tasks.
Analysis of Core Capabilities 6 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Area for Improvement 3: Patient numbering system differed between EMS and the hospital.
Analysis: It was observed that EMS numbers their patients differently than the hospital.
In addition, the exercise patient cards were also numbered. As a consideration for future
exercises, use an alphabet system to distinguish patients instead of numbers to avoid
confusion.
Area for Improvement 4: A contaminated patient reported to the clinic and was taken back for
assessment potentially contaminating the clinic area.
Analysis: During the exercise one patient self-reported to the clinic entrance with
symptoms of chemical exposure. The clinic was aware of the "event" and was notified
appropriately through the Code Orange prior to the patient presenting. Additional
training should take place with all staff to reinforce procedures related to chemical
contamination. Consider reviewing triage procedures to limit contamination of the clinic.
This was a great learning point during the exercise for clinic staff. Exercise control staff
made a note of the breach, but did not allow the exercise to play through the
contaminated clinic as it was not included in the exercise objectives.
Patient Decontamination:
Strengths
The following strengths were demonstrated during the exercise:
Strength 1: Staff assigned to decontaminate patients was very willing to jump in and participate
once given basic training.
Strength 2: Staff in decon asked for help when needed for additional supplies, manpower, and
support.
Areas for Improvement
The following areas require improvement to achieve the full capability level:
Area for Improvement 1: Additional decon training is needed to form a formal decon team at
BHM.
Analysis: More training is needed if BMH is to form a decon team. The team should
include additional members to have a rescue/standby team and so that staff in suits can be
rotated out as fatigue becomes apparent. Also medical monitoring should be put in place
to ensure the safety of suited up staff members. Formal Hospital First Receivers training
is available through many training sources. Also review the equipment that is available
at BMH and discard (or save for training purposes) any outdated supplies.
Area for Improvement 2: Waste receptacles are needed in the decon shower room for
discarded/contaminated clothing.
Analysis of Core Capabilities 7 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Area for Improvement 3: Trauma shears should be kept in the decon equipment cache for
cutting off clothing. The shears used were not effective.
Area for Improvement 4: Have accessible clean backboards to transfer patients to gurneys.
Area for Improvement 5: The floor between the decon shower room and the ED became very
slippery with the water.
Analysis: Keep the door to the shower room closed during decon to limit splash of
contaminated water into the cold zone. Consider adding a rubber mat in the room
between the shower and the ED to make the floor less slippery for staff and patients while
allowing gurneys to still roll over. The towels used during the exercise on the floor were
not effective.
Area for Improvement 6: EMS requested a quicker process to deliver patients into the decon
room.
Analysis: It was observed by EMS during the exercise that patients were lining up
outside the decon room which did not allow the EMS unit to return to the scene. The
decon tent could be set up as a staging area to protect from the elements. Hypothermia
would be a definite concern if gross decon takes place in the cold temperatures.
Safety and Security:
Strengths
The following strengths were demonstrated during the exercise:
Strength 1: Facility lockdown is very easy at BMH. Facility was built with limited access in
mind.
Strength 2: Hospital access was controlled and any unlocked doors were manned.
Analysis of Core Capabilities 8 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
CONCLUSION
In conclusion, the Blue Mountain Hospital Operation Walking Dead Full-Scale Exercise
achieved its objectives and many lessons were learned by all participants in the exercise. The
key to continued success is to review and implement the recommendations for improvement and
continue building strengths and capabilities at BMH. This exercise demonstrated that BMH has
a dedicated staff that is invested in the continued improvement of the capabilities of the hospital.
This exercise was a great example of working with the community to meet multiple goals
through a community exercise, building and strengthening relationships in the process, and
practicing the skills committed to in plans. Full-Scale Exercises provide ample opportunities to
practice skills needed during an event, but with a focus on learning opportunities. It is
recommended to perform additional smaller scale drills in between the large Full-Scales to
further refine specific planning areas, staff training, and internal systems.
Analysis of Core Capabilities 9 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
APPENDIX A: IMPROVEMENT PLAN
This IP has been developed specifically for Blue Mountain Hospital as a result of Operation Walking Dead FSE conducted on
November 15,2013.
Focus Area
Focus Area 1:
[Focus Area
Name]
Issue/Area for
Improvement
1. [Area for
Improvement]
2. [Area for
Improvement]
Corrective Action
[Corrective Action 1]
Primary
Responsible
Organization
Organization
POC Start Date Completion
Date
[Corrective Action 2]
[Corrective Action 3]
[Corrective Action 1]
[Corrective Action 2]
Appendix A: Improvement Plan A-1
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
Blue Mountain Hospital
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
APPENDIX B: PARTICIPANT FEEDBACK SUMMARY
Assessment Factor
Strongly
Disagree
Strongly
Agree
Pre-exercise briefings were
informative and provided
the necessary information
for my role in the exercise.
The exercise scenario was
plausible and realistic.
Exercise participants
included the right people in
terms of level and mix of
disciplines.
Participants were actively
involved in the exercise.
Exercise participation was
appropriate for someone in
my field with my level of
experience/training
The exercise increased my
understanding about and
familiarity with the
capabilities and resources
of other participating
organizations.
The exercise provided the
opportunity to address
significant decisions in
support of critical mission
areas.
After this exercise, I am
better prepared to deal with
the capabilities and
hazards addressed.
Participant Feedback
1. I observed the following strengths during this exercise:
Strengths
It was chaotic but the staff was all willing to participate and communicate.
Element
Planning
Organization
Equipment
Training
Exercise
•
•
• El
•
Appendix B: Participant Feedback Summary B-1
FOUO
Blue Mountain Hospital
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Everyone moved into action. Everyone kept their cool and did their assigned
role.
Planning
Organization
Equipment
Training
Exercise
Excellent training on decon and cleansing.
Planning
Organization
Equipment
Training
Exercise
Team work, good communication
Planning
Organization
Equipment
Training
Exercise
Dr Key was very involved
Planning
Organization
Equipment
Training
Exercise
Good identification of supervising roles (incident command, charge nurse,
operation officer)
Planning
Organization
Equipment
Training
Exercise
The beginning; when the head nurse was organizing and telling people what to
do.
Planning
Organization
Equipment
Training
Exercise
Great communication amongst staff
Planning
Organization
Equipment
Training
Exercise
A lot of participation
Planning
Organization
Equipment
Training
Exercise
Appendix B: Participant Feedback Summary B-2 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Good equipment usable
Planning
Organization
Equipment
Training
Exercise
I liked how we all jumped in and helped each other get the job done and
patients taken care of.
Planning
Organization
Equipment
Training
Exercise
2. I observed the following areas for improvement during this exercise:
Areas for Improvement
Patient tracking. The board needs to be filled out in real time. Retrospectively
filled in boards don't help us know patient status.
Element
Planning
Organization
Equipment
Training
Exercise
Assign nurses to patients so there is ownership of that patient/patients so the
reporting goes up the chain clearly.
Planning
Organization
Equipment
Training
Exercise
IT -Tech equipment need to be ready in case there's a hardware failure.
Planning
Organization
Equipment
Training
Exercise
Traffic control didn't go very well for sending "Dialysis" pts to the only entrance
door for pts. So pts walked to "dialysis" entrance door, were told to go to other
door and then "walked" instead of driving and being placed in a wheelchair and
escorted to dialysis unit
Planning
Organization
Equipment
Training
Exercise
Being very informative of what specific job duties are.
Planning
Organization
Equipment
Training
Exercise
Appendix B: Participant Feedback Summary B-3 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
Have a room and plan set up for overflow equipment
Planning
Organization
Equipment
Training
Exercise
I think there should have an "Incident Command Board" available that is
"mobile" and can be moved into the area (ER)
Planning
Organization
Equipment
Training
Exercise
Better communication among decon nurses, triage nurses and ER nurses (
report, type of triage/where triaged)
Planning
Organization
Equipment
Training
Exercise
Delegating tasks, making clear roles (defining roles)
Planning
Organization
Equipment
Training
Exercise
Registration was very confused of what and how to register patients.
Planning
Organization
Equipment
Training
Exercise
Confused of where I was supposed to be? I was registering; then I was told to
do this and that. Very confusing.
Planning
Organization
Equipment
Training
Exercise
Familiarity with equipment is needed.
Planning
Organization
Equipment
Training
Exercise
Staff designated to certain jobs
Planning
Organization
Equipment
Training
Exercise
Appendix B: Participant Feedback Summary B-4 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
I think that some people were confused if we were pretending (with some
treatments) or not, so it was kinda chaotic for a bit.
Planning
Organization
Equipment
Training
Exercise
•
•
•
•
3. What specific training opportunities helped you (or could have helped you) prepare for
this exercise? Please provide specific course names if applicable.
Training
Blue mountain Hospital Annual Training
Completed
Prior to
Exercise?
(Y/N)
Y
More Training on equipment. N
Where the equipment could be found. N
The decon training right before the exercise Y
4. Which exercise materials were most useful? Please identify any additional materials or
resources that would be useful.
Two way radios worked great along with the orange and green vest.
Demonstrate with proper equipment, hands -on training , "real life" situations
Can't think of anything right now.
Having a briefing beforehand helped to understand how the patient flow would be handled.
This was a first time mock code in the ER for a mass incident.
I thought the whole thing was good. It was good to act out the whole thing... with patients
and all, so we know what it's going to be like if it happens for real.
5. Please provide any recommendations on how this exercise or future exercises could be
improved or enhanced.
I'm a new employee here, so I'm still learning. So, I have no recommendations right now.
I guess another exercise/drill.
Appendix B: Participant Feedback Summary B-5 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
After-Action Report/
Improvement Plan (AAR/IP)
Blue Mountain Hospital
Operation Walking Dead FSE
I think the repat should be sent out to all of the staff members once it is compiled. I enjoyed
participating and I learned but I would have enjoyed seeing other aspects how the flow of
patients actually moved or care given.
I thought it ran pretty smooth once we got going... at the first it kinda seemed like people
were a little flustered but once they got to working it ran good.
The only thing I would recommend is maybe more communication on what our company
policy is if something like this were to happen for real.
Appendix B: Participant Feedback Summary B-6 Blue Mountain Hospital
FOUO
Homeland Security Exercise and Evaluation Program (HSEEP)
Player Handout
Operation Walking Dead
Player Handout
Purpose
Blue Mountain Hospital and its supporting partner agencies have developed Operation
Walking Dead, a Full-Scale Exercise (FSE), to evaluate the response of participating agencies
and current response plans and procedures during a hazardous materials event. The focus of
the exercise will be on communications between responders on the scene, to/from the Hospital
Command Center, and to/from the Emergency Department of BMH and on hazardous
materials response and patient decontamination.
Exercise Objectives
The exercise will focus on the following design objectives to guide exercise play:
1. Test activation of hospital disaster plan including stand up of Hospital Command
Center, notification of hospital staff, and recall of staff as appropriate.
2. Evaluate communication with first responders, other healthcare agencies, and internal
staff.
3. Test hospital patient decon procedures in response to a hazardous materials incident.
4. Evaluate hospital security and access control related to a hazardous materials incident.
Participants
• Players. Players are personnel who have an active role in discussing or performing their
regular roles and responsibilities during the exercise. Players discuss or initiate actions in
response to the simulated emergency.
• Controllers. Controllers plan and manage exercise play, set up and operate the exercise
site, and act in the roles of organizations or individuals that are not playing in the exercise.
Controllers direct the pace of the exercise, provide key data to players, and may prompt or
initiate certain player actions to ensure exercise continuity. In addition, they issue exercise
material to players as required, monitor the exercise timeline, and supervise the safety of
all exercise participants.
• Evaluators. Evaluators evaluate and provide feedback on a designated functional area of
the exercise. Evaluators observe and document performance against established
capability targets and critical tasks, in accordance with the Exercise Evaluation Guides
(EEGs).
• Actors. Actors simulate specific roles during exercise play, typically victims or other
bystanders.
Safety
Exercise participant safety takes priority over exercise events. The following general
requirements apply to the exercise:
• For an emergency that requires assistance, use the phrase "real-world emergency." The
following procedures should be used in case of a real emergency during the exercise:
• Anyone who observes a participant who is seriously ill or injured will immediately notify
emergency services and the closest controller, and, within reason and training, render aid.
Exercise play may be suspended until further information is gathered on the real life event.
Blue Mountain Hospital
Full-Scale Exercise 1 November 15, 2013
Player Handout
Player Instructions
• Respond to exercise events and information as if the emergency were real, unless
otherwise directed by an exercise facilitator.
• If you do not understand the scope of the exercise, or if you are uncertain about an
organization's or agency's participation in an exercise, ask a controller or evaluator.
• Parts of the scenario may seem implausible. Recognize that the exercise has objectives to
satisfy and may require incorporation of unrealistic aspects. Every effort has been made by
the exercise's trusted agents to balance realism with safety and to create an effective
learning and evaluation environment.
• All exercise communications will begin and end with the statement "This is an exercise."
This precaution is taken so that anyone who overhears the conversation will not mistake
exercise play for a real-world emergency.
• Speak when you take an action. This procedure will ensure that exercise staff is aware of
critical actions as they occur.
• Maintain a log of your activities. Many times, this log may include documentation of
activities that were missed by exercise staff.
Assumptions and Artificialities
In any exercise a number of assumptions and artificialities may be necessary to complete play
in the time allotted. During this exercise, the following apply:
• The exercise is conducted in a no-fault learning environment wherein capabilities, plans,
systems, and processes will be evaluated.
• The scenario is plausible, and events occur as they are presented.
• There is no "hidden agenda", nor any trick questions.
Scenario
On November 15 around 10am, a traffic accident occurred on Highway 191 at Shirttail
Junction. A placarded tractor-trailer carrying hazardous materials collided with a SUV and
resulted in the tanker truck tipping on its side spilling its contents. The drivers of the truck and
SUV along with two passengers are injured in the crash. Passing motorists have stopped to
help and called 911.
Blue Mountain Hospital
Full-Scale Exercise 2 November 15, 2013
EEG Operation Walking Dead Blue Mountain Hospital FSE
Operation Walking Dead
Blue Mountain Hospital
Exercise Evaluation Guide
Communications:
1. Was the hospital notified in a timely manner of the incident?
2. Was notification disseminated within the hospital to key decision makers to determine
the appropriate next steps?
3. Did the notification trigger the appropriate response?
a. Was NIMS activated?
b. Was an alert or notification made to all personnel?
4. Were the internal communications:
a. Timely
b. Efficient
c. Documented
d. Complete
5. What method/mechanism was utilized to communicate internally?
6. Were external agencies communicated with or given consideration?
a. What methods were used for external communication?
b. Was sufficient information provided?
7. When information was received from internal or external sources, was appropriate
consideration given as to who else needed the information?
8. Was information recorded and referred to or addressed later?
Command Function:
1. Did appropriate command staff respond to the notification?
2. Was an IC established?
3. Was a briefing given to IC?
4. Was the HICS structure clearly defined?
5. Was appropriate and sufficient information conveyed during the briefing?
6. Did planning chief and IC formulate IAP?
7. Were objectives taken through the proper channels of command?
8. Are forms being completed? Were available Job Action Sheets and HICS resources being
used?
9. Do members ofthe ICS structure understand their roles?
10. Were timely updates provided?
11. As decisions are made are they documented?
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EEG Operation Walking Dead Blue Mountain Hospital FSE
12. When information is tracked, is it tracked and recorded in an organized manner?
13. If patient tracking is taking place, what method is being used to confirm the accuracy of
the tracking?
Patient Reception and Treatment Area:
1. Was a hot zone established?
2. Were patients and staff made aware of the hot, warm, and cold zones?
3. Were patients entered into the computer system and tagged as disaster patients?
4. Was staffing adjusted to handle influx of patients?
5. Was discharge planning and surge plan used or considered?
6. Was bed availability evaluated? Was there alternate care site/space consideration?
7. Did staff understand their roles?
8. Was the situation communicated with the patients already in the hospital?
Patient Decontamination:
1. Did staff consider appropriate PPE?
2. Was the decon facility prepared and setup efficiently and properly?
3. Is equipment accessible and appropriate?
4. Was a decon team established with clearly defined roles, responsibilities, and a
command structure?
5. Did staff effectively decon patients?
a. Appropriate communication with patients
b. Decon all areas of the patient
c. Safely move patient through decon area
6. Was the decon area safe for patient and staff movement?
Safety and Security:
1. Was campus access controlled?
2. Was building access controlled?
3. Were media areas established?
4. Were communications from the officers to the HCC effective and timely?
5. When communicating about situation status, were non-security personnel involved,
either in the field or in the command center?
Mini Check-Ins with: Lab, Radiology, MedSurge, Admissions, Blood Bank, Facilities, Security.
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