DRC-2009-004169 - 0901a068801424e4

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DENISON ^i
MINES
VIA PDF AND FEDERAL EXPRESS
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denisonmines.com
September 14, 2009
Mr. Dane Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Dear Mr. Finerfrock:
Re: Renewal Application for Radioactive Materials License (RML) No.
UT1900479: Health Physics Interrogatories - Round 2; and Engineering
Comment Interrogatories - Round 1
Reference is made to our letter of August 14, 2009 in response to the Executive Secretary's
correspondence of July 2, 2009 with attached Health Physics and Engineering Comment
Interrogatories.
As contemplated by our response to Health Physics Interrogatory Statement No. 7, enclosed
please find a draft Section 6.0 to the White Mesa Mill Radiation Protection Manual reladng to
release surveys from the Mill's restricted area.
If you should have any questions or require additional information, please contact the
undersigned.
Yours very truly,
DENISON MINE^ (USA) CORP.
By:
Davia C. Frydenlund
Vice President, Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
White Mesa Mill - Standard Operating-Procedures Date 09/09 Revision: DUSA - 0
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
6. RELEASE SURVEYS
6.1 General
This Section contains the following procedures for the release of equipment and product drums
from the Mill: (1) restricted release of exclusive use vehicles; and (2) um-estricted release of
tractors, trailers, intermodal containers ("IMCs") and other vehicles, other equipment and
product drums.
Items can be released from the Mill's restricted area provided that those items meet certain
requirements as spelled out in Regulatory Guide 8.30, Health Physics Surveys in Uraniimi
Recovery FaciUties and NRC's Guidelines for Decontamination of Facilities and Equipment
Prior to Release for Unrestricted use or Termination of Licenses for Byproduct, Source, or
Special Nuclear Material, August 1987.
Release surveys will be conducted to make sure that no contaminated equipment is released from
the facility. This Section 6 sets out the surveying procedures to be used in order to verify that the
equipment or product drum meets the applicable release criteria prior to exiting the Mill's
restricted area.
6.2 Survey Equipment
Release surveys are performed using a variety of detecting instmments, as listed in Appendix 1
and specified below. Each instrument is checked using a calibrated alpha or beta/gamma source,
as applicable, for proper function and operation prior to use, as described in Sections 6.3.1(c) and
6.3.2(b) below. In the case of alpha instmments, this calibration check is also used to derive the
daily conversion from counts per minute (cpm) observed by the meter to actual disintegrations
per minute (dpm) being emitted. The cpm indicated by the alpha meter is multiplied by the
product of the cpm indicated during the instmment check divided by the actual dpm emitted by
the check/calibration source.
In the case of alpha detecting instruments, adjustments to the surface area being measured must
also be made to convert from the particular detector's surface area to the reference surface area
of 100 square centimeters. Therefore when converting a measurement to the units of dpm/100
cm", an area adjustment factor must be applied to the measurement. For example, for the
Ludlum instmment with a 43-1 detector of 75 cm" surface area, multiply the value by 1.33 (i.e.
100 cm" divided by 75cm^).
Radiation Manual - Scanning Procedure Page 1
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SOP PBL-RP-6
Bool< 9: Radiation Protection Manual, Section 6
The bela/gamma detecting instruments used al the Mill read directly in mrem/hour.
Each instmment has a manufacturer's user's manual which describes the function, use and
capability of each instrument. These manuals must be understood by the surveyor before any
surveying proceeds.
6.3 Pre-Survey Procedures
6.3.1 Alpha Surveys
At the outset, prior to performing an alpha survey:
a) Tum the meter on and check the meter battery condition;
b) Check the alpha detector mylar surface for pinholes, etc. Replace if necessary and
repeat calibration;
c) As specified in Section 3.1.2.3.2, perform a function check using a calibrated alpha
source;
d) If the check is acceptable, use the conversions indicated above to convert from cpm to
dpm in conjunction with the area adjustment factor to determine the necessary
correction factor to convert the cpm recorded to the actual number of dpm/100cm' and
proceed to monitoring; and
e) The ability of the alpha meter to detect alpha radiation will be compromised if the
surface area to be surveyed is wet. If an area to be surveyed for alpha contamination is
wet, then, prior to surveying:
(i) Wail for the area to dry on its own;
(ii) Wipe the area dry with a towel; or
(iii) Use a hand held torch or similar device to dry the area.
6.3.2 Beta/Gamma Surveys
a) Tum the meter on and check the meter battery condition;
Radiation Manual - Scanning Procedure Page 2
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Book 9: Radiation Protection Manual, Section 6
b) As specified in Section 3.1.4.1, perform a function check using a calibrated
beta/gamma source.
c) If the check is acceptable, proceed to monitoring.
6.4 Restricted Release
Exclusive use vehicles, i.e., vehicles that are part of a dedicated run between the Mill and another
site may be released under a restricted release. Under a restricted release, the exterior of the
vehicle will be surveyed for total activity. Provided that the cargo area is covered, the inside of
the cargo area need not be surveyed for restricted release.
6.4.1 Restricted Release Standards
Alpha (combined fixed and removable)
Average 2,200 dpm/lOOcm' Applies to an area of not more than 100 cm
Beta/Gamma
Maximum at each accessible surface On extemal surface
0.5 mrem/hr
6.4.2 Restricted Release Procedure
A restricted release survey can be performed on, but is not limited to, ore trucks, IMCs and
closed box trailers, that have been designated as exclusive use conveyances.
1. For restricted release surveys, use a Ludlum Model 3 with a 43-5 probe or the equivalent,
which measures both alpha and beta/gamma. Because this instrument measures both
alpha and beta/gamma, a separate beta/gamma survey is not performed for restricted
release surveys. Compliance with both the alpha release standard and the beta/gamma
release standard set out in Section 6.4.1 is determined by the single survey with this
instrument.
2. Perform the pre-survey procedures outlined in Section 6.3 above. Because the Ludlum
Model 3 with a 43-5 probe measures both alpha and beta/gamma, it must be calibrated for
alpha and for beta/gamma.
3. The radiation technician will start by obtaining the proper release form (see Section 6.6 of
this procedure for the various release forms). The technician will then obtain the needed
Radiation Manual - Scanning Procedure Page 3
White Mesa Mill - Standard Operating Procedures Date 09/09 Revision: DUSA - 0
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
information to complete the release form. This informalion will usually be the tractor
trailer identification markings. There should be one number for the tractor and one for the
trailer.
4. As a safety precaution, the technician will have the driver exit the vehicle prior to
approaching the equipment. If the driver does not leave the vehicle, the technician will
contact the RSO to have the driver removed from the vehicle.
5. The survey will begin by taking the required radiation detection instrumentation and
addressing the tractor.
a) The tractor survey should begin by surveying the tires. This will consist of slowly
moving the combined alpha/beta/gamma detector approximately 14 inch off of the
surface of the tread of the tire. While doing this, the technician should be watching the
needle movement on the detector. The display on the Ludlum Model 3 with a 43-5
probe simultaneously shows cpm, which is used to determine alpha activity, and
mrem/hr which is used to determine combined beta/gamma activity. Also, the
technician should be looking at the treads of the tire for any rocks or other objects
protmding from the tire. Any such rocks and other objects should be removed from the
tread. The technician will then place the rocks and any other objects into a bucket
behind the Guardhouse to be taken up to the ore storage area at the end of each shift;
b) After the tread is completed, the outside and inside facing surfaces of the tire should be
surveyed in the same manner;
c) After the tire has been surveyed and observed, the technician should then survey the
interior of the wheel well. Here too, the detector should be held approximately VA inch
off of the surface of the tractor. At the same time, the technician should be observing
the wheel well for any visible contamination. If visible contamination is found, the
tractor must be sent back to either secondary decontamination or back to the
decontamination pad for another washing. If no visible contamination is found, then
the technician should move to the next tire and start the process over.
d) The procedures set out in paragraphs a), b) and c) should be repeated for every tire on
the tractor.
e) The technician will then survey the tractor itself, by slowly moving the detector, at a
distance of approximately 14 inch, over the sides and/or undemeath the carriage of the
Radiation Manual - Scanning Procedure Page 4
White Mesa Mill - Standard Operating Procedures Date 09/09 Revision: DUSA - 0
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
tractor. Sufficient measurements must be taken in the most appropriate locations to
yield a representative assessment of the contamination levels. For tractors, this means
at least 3 measurements must be taken on each side of the tractor for a total of at least 6
measurements. In addition, the technician should look for any visible contamination,
noting in particular any areas where ore may collect. If any visible contamination is
found, the tractor must be redirected to either secondary decontamination or back to the
decontamination pad;
After the tractor is completed, the technician should move to the trailer and IMC, if
applicable.
a) The trailer's tires and wheel wells will be surveyed in the same manner as the tractor's
tires and wheel wells, as set out in Sections 6.4.2 (5) (a), (b), (c) and (d);
b) The trailer itself should be surveyed by slowly moving the detector, at a distance of
approximately VA inch, over the sides, bottom and if possible the tops of the unit.
Sufficient measurements must be taken in the most appropriate locations to yield a
representative assessment of the contamination levels. For ore trucks and other end
dump trailers, see the locations specified on the Equipment Survey for Restricted
Release form attached to the Mill's End Dump Trailer Acceptance, Handling &
Release procedure No.: PBL-9, and for IMCs see the survey locations specified on the
Intermodal Container Survey for Restricted Release form attached to the Mill's
Intermodal Container Acceptance, Handling & Release procedure No.: PBl-2, for the
locations to be surveyed. Copies of those forms are attached to this procedure;
c) The technician should be aware that there may be numerous areas where material may
collect. The technician should observe all of these locations for visible contamination.
On ore trucks, the technician should make sure to look under the support legs, rear
bumper, along the edge of the end dump tailgate and the mud flaps. These areas tend
to be collection places for ore as it is being unloaded.; and
d) If any visible contamination is found, the unit must be redirected to either secondary
decontamination or back to the decontamination pad.
After the technician has surveyed all tires and wheel wells, and the sides, bottom and top
(if at all possible) of the trailer or IMC with the radiation detection instrumentation, and
the surveys satisfy the criteria in Section 6.4.1 and there is no visible contamination, the
Radiation Manual - Scanning Procedure Page 5
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SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
technician will report to the guardhouse and document the findings on the appropriate
paperwork which has already been determined.
8. The technician will then make sure the driver surveys him or herself following proper
individual scanning methods. At that point, the technician will authorize the driver to re-
enter the vehicle. The technician will then open the gate and the vehicle will be allowed
to exit the facility.
6.5 Unrestricted Release
Vehicles, trailers, IMCs, other equipment and product drums may be released from the Mill's
restricted area on an unrestricted basis only if surveys are performed as described below and the
release criteria specified in Section 6.5.1 are satisfied.
6.5.1 Unrestricted Release Criteria
Alpha (flxed and removable):
Average 5,000 dpm/lOOcm^ alpha Average over no more than 1 m"
Maximum 15,000 dpm/100 cm^ alpha Applies to an area of not more than 100 cm^
Removable 1,000 dpm/100 cm^ alpha Determined by smearing with dry filter or soft
absorbent paper, applying moderate pressure, and
assessing the amount of radioactive material on the
smear.
Beta/Gamma
Average 0.2 mrem/hr Average at 1 cm
Maximum 1.0 mrem/hr Maximum at 1 cm
6.5.2 Unrestricted Release of Tractors, Trailers, Intermodal Containers and Other
Vehicles
1. The radiation department will be notified at least 24 hours prior to the time that an
unrestricted release is required for any tractor trailer that has been hauling under a
dedicated haul.
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SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
2. For unrestricted release, separate alpha and beta/gamma surveys will be performed. For
the alpha survey, use a Ludlum Model 177 with a 43-1 75cm" probe, or the equivalent.
For the beta/gamma survey, use a Ludlum Model 3 with a 44-6 probe, or the equivalent.
3. Perform the pre-survey procedures described in Section 6.3 above.
4. An unrestricted release for a trailer will start with surveys of the exterior with the
appropriate radiation detection instmmentation. This will include an alpha survey and a
beta/gamma survey.
a) The technician will first survey the tires, wheel wells, sides, bottom and top of the
trailer for alpha using the same techniques mentioned under Section 6.4.2 above. The
tractor (or any other non-conveyance vehicle) will also be surveyed in the same manner
as set out in Section 6.4.2 (5). However,
(i) instead of using the combined alpha and beta/gamma meter, the alpha meter will
be used; and
(ii) instead of applying the restricted release standards specified in Section 6.4.1
above to the surveys of the tractor and trailer, the criteria for unrestricted release
specified in Section 6.5.1 above for alpha will apply. The alpha meter will
measure the total alpha (both fixed and removable). If the total alpha reading is
less than the standard for removable alpha alone, then the release standard will
have been met. However, if the total alpha activity exceeds the standard for
removable alpha alone, then additional swipes will be performed at the locations
that exceeded the standard to determine the removable component of the total
alpha contamination (see paragraph (6)(a) below); and
b) The technician will then repeat the survey described in a) using the beta/gamma meter
and will apply the unrestricted release criteria specified in Section 6.5.1 for
beta/gamma. This will be done by slowly moving the detector over the same areas that
were surveyed with the alpha detector. The technician will hold the instmment
approximately 1 cm above the surface. The technician will survey the same general
areas as specified in the release forms.
If a survey fails to meet the standards set out in Section 6.5.1 above, or if there is any visible
contamination, then the trailer or IMC must be sent back to the decontamination wash station. If
the material will not wash out, then more advanced methods of decontamination will be used.
Radiation Manual - Scanning Procedure Page 7
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Book 9: Radiation Protection Manual, Section 6
This could include, but is not limited to, sandblasting of the trailer or IMC to remove
contamination.
5. For an umestricted release, the interior of the trailer, intermodal container or closed box
trailer, must also be surveyed. The survey will consist of dividing the trailer into sections.
Each section will be surveyed in the same manner, as follows:
a) Step one will have the technician using the alpha probe and slowly moving the probe
over the trailer or IMC. The technician should keep the probe approximately VA inch
from the surface of the trailer. Sufficient measurements must be taken in the most
appropriate locations to yield a representative assessment of the contamination levels.
The number and locations of these readings is listed on the release forms (for end dump
trailers, see the Equipment Survey for Restricted Release form attached to the Mill's
End Dump Trailer Acceptance, Handling & Release procedure No.: PBL-9, and for
IMCs see the survey locations specified on the Intermodal Container Survey for
Restricted Release form attached to the Mill's Intermodal Container Acceptance,
Handling & Release procedure No.: PBl-2, for the locations to be surveyed. Copies of
those forms are attached to this procedure);
b) The technician will document the alpha readings in the section by indicating them on
the appropriate paperwork. If a survey fails to meet the standards set out in Section
6.5.1 above, or if there is any visible contamination, then the trailer or IMC must be
sent back to the decontamination wash station. If the material will not wash out, then
more advanced methods of decontamination will be used. This could include, but is
not limited to, sandblasting of the trailer or IMC to remove contamination; and
c) After the alpha survey work is completed, the beta/gamma survey will proceed. This
will be done by slowly moving the detector over the trailer section as the technician
had done with the alpha detector. The technician will hold the instmment
approximately 1 cm above the surface of the trailer or IMC. The technician will survey
the same general areas as specified in the release forms and that were surveyed for
alpha contamination. This information will then be documented on the form in its
proper location. If a survey fails to meet the standards set out in Section 6.5.1 above,
then the trailer or IMC must be sent back to the decontamination wash station. If the
material will not wash out, then more advanced methods of decontamination will be
used. This could include, but is not limited to, sandblasting of the trailer or IMC to
remove contamination.
Radiation Manual - Scanning Procedure Page 8
White Mesa Mill - Standard Operating Procedures Date 09/09;Revision: DUSA - 0
SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
6. After the technician has completed both the alpha and the beta/gamma surveys, the
technician will perform a removable alpha survey on the trailer. This will be done by
a) swiping any area on the inside or outside of the conveyance that was found by the
surveys to be over the facility's removable alpha release requirements. The alpha
survey will detect both fixed and removable alpha contamination. Because the piece of
equipment will not have any visible contamination (any piece of equipment that has
visible contamination will have been sent back for re-decontamination), the swipe will
be used to determine if the removable alpha exceeds the removable alpha limit; and
b) Even if no areas are found by the meter survey to be over the limit for removable alpha
contamination, the technician should pull removable swipe samples from the inside of
the conveyance at a minimum of 10% of the sections in the trailer, using the
procedures set out in Section 2.3.3.3. Each removable swipe should cover 100 square
centimeters.
These removable samples will then be taken to the radiation department for reading. If a
swipe fails to meet the standards set out in Section 6.5.1 above for removable alpha
contamination, then the trailer or IMC must be sent back to the decontamination wash
station. If the material will not wash out, then more advanced methods of decontamination
will be used. This could include, but is not limited to, sandblasting of the trailer or IMC to
remove contamination.
7. After the completion of the surveys described above, the technician will document his or
her findings on the appropriate paperwork. If all data collected is within the facility's
release requirements, the technician will then place a red sticker on the driver's side, front
panel of the trailer or IMC. The sticker will be dated and signed by the releasing
technician. The technician will then file the paperwork in the radiation department files
under the corresponding release surveys.
8. The driver will then perform an appropriate individual survey. Once that survey has been
completed, the technician will open the gate and allow the tractor trailer to leave the
facility.
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Book 9: Radiation Protection Manual, Section 6
6.5.3 Unrestricted Release of Equipment
An equipment release is the same as an unrestricted release of tractors, trailers, IMCs and other
vehicles specified in Section 6.5.2 (4) above, except that the item to be released is a piece of
operating equipment rather than a feed material haulage conveyance.
1. The technician will first be notified by the individual or group who wants the piece of
equipment to be released from the site. These groups or individuals may need the
equipment to go off site for repair, exchange or sale. The equipment must first go through
a decontamination process before it arrives at the front gate for surveying. The
decontamination may include, but is not limited to. a water wash, sand blasting, acid
wash, etc., as necessary in the circumstances.
2. The same survey instruments will be used as specified in Section 6.5.2 (2) above.
3. Perform the pre-survey procedures specified in Section 6.3 above.
4. The technician must visually observe all sections, top, bottom and all sides of the piece of
equipment to make sure that there is no visible contamination. The technician needs to
also observe that there is no oil, grease or other material that may mask contamination.
The piece of equipment should be free of all such material prior to being released. If any
such contamination is observed, the piece of equipment must be sent back for re-
decontamination.
5. Prior to commencing the surveys, the technician will take a photograph of the piece of
equipment to be released.
6. The technician will then survey the piece of equipment using the same methods described
in Section 6.5.2 (4). Sufficient measurements must be taken in the most appropriate
locations to yield a representative assessment of the contamination levels. Because each
piece of equipment may be different or unique, the technician will use his or her judgment
as to the survey locations. The technician will describe the locations surveyed on the
release form.
7. If any areas surveyed are found to be over the facility's removable release requirements,
then a swipe will be perfonned using the procedures set out in Section 2.3.3.3. The alpha
survey will detect both fixed and removable alpha contamination. Because the piece of
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Book 9: Radiation Protection Manual, Section 6
equipment will not have any visible contamination (any piece of equipment that has
visible contamination will have been sent back for re-decontamination), the swipe will be
used to determine ifthe removable alpha exceeds the removable alpha limit.;
8. If at any time, either visual contamination is observed or contamination is found by one of
the radiation detection instruments or a swipe to exceed the unrestricted release standards,
the piece of equipment must be sent back for additional decontamination. If at any time
the technician sends a piece of equipraent back for additional cleaning, the technician
should document this and why he or she sent it back on the comment section of the
equipment release form.
9. After the piece of equipment has been successfully cleaned and surveyed, the technician
will allow the piece of equipment to be released from the Mill's restricted area.
10. The technician will place the form and the photograph in the equipment release book in
the radiation depaitment.
6.5.4 Release of Product Drums
All uranium and vanadium product dmms and any other product dmms will be released for
unrestricted release only, and must satisfy the standards set out in Section 6.5.1 above. In
addition, vanadium product dmms must also satisfy the release criteria specified in the Mill's
Release and Shipping of Vanadium Blackflake procedure No. PBL-15.
1. The same survey instmments will be used as specified in Section 6.5.2 (2) above.
2. Perform the pre-survey procedures specified in Section 6.3 above.
3. The Technician will perform an alpha scan of the dmm by slowing moving the alpha
detector, at a distance of approximately VA inch, over the sides and top of the drum. Sufficient
measurements must be taken in the most appropriate locations to yield a representative
assessment of the contamination levels. For product dmms this means that all dmms must be
surveyed. Each drum will be surveyed on at least 2 different locations on the lid and an average
reading for the lid recorded. The technician will then measure al least 4 different locations on
the sides of the drum and get an average reading for the drum itself. The technician will survey
any area that is discolored, dented or creased to verify that there is no contamination present. If a
survey fails to meet the standards set out in Section 6.5.1 above (or in the Release and Shipping
of Vanadium Blackface procedure), then the drum must be cleaned. If the drum still does not
Radiation Manual - Scanning Procedure Page 11
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SOP PBL-RP-6
Book 9: Radiation Protection Manual, Section 6
pass the survey, the drum is to be replaced. That means that Operations will collect the
contaminated drum and return it to the packing area and will repack the material into a new
drum. The old drum will then be taken to the Tailings area to be crushed and disposed of.
4. In addition to the alpha surveys, a minimum of 25% of all product drums must also be
swiped for alpha contamination using the procedures set out in Section 2.3.3.3. If a product
dmm fails to meet the removable alpha standards set out in Section 6.5.1 above for any swipe,
then the drum must be cleaned. If the dmm still does not pass the survey, the drum is to be
replaced. That means that Operations will collect the contaminated drum and retum it to the
packing area and will repack the material into a new dmm. The old dmm will then be taken to
the Tailings area to be crushed and disposed of
5. After the alpha survey work is completed, the beta/gamma survey will proceed. This will
be done by slowly moving the detector over the dmm as the technician had done with the alpha
detector. The detector will be placed at 1 cm from the drum and then moved slowly over the
same locations on the lid and dmm as were surveyed by the alpha meter. The highest reading
will be documented for the areas. This information will then be documented on the form in its
proper location. If a product drum fails to meet the standards set out in Section 6.5.1 above for
any survey, then the drum must be cleaned. If the dmm still does not pass the survey, the drum
is to be replaced. That means that Operations will collect the contaminated dmm and retum it to
the packing area and will repack the material into a new dmm. The old dmm will then be taken
to the Tailings area to be cmshed and disposed of
6.6 Forms
Attached are the various release survey forms to this section.
Radiation Manual - Scanning Procedure Page 12
4356782224 International uiallium 11 1453am 09-H-2009 2/11
Date:
Designates
Top
Denison Mines (USA) Corp.
Ore Haulage Survey for Restricted Release
Trailer ID:
LoMHon*
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Ralls
Total Alpha/
B«ta4jamnia
cpm
Surveyed By:
Tractor ID #
o
oo
00
0
00
oo
Location #
1:
2:
3:
4:
5:
6:
Truck Ext.:
Total Alpha/
BeU-Gamma
cpm
Trailer Tires
7 00
9 00
11 00
oo
00
00
8
10
12
Removable alpha •
Fixed alpha
Beta-Gamma
Comnients:
lOOOdpm/IOOcm^
5000 dpnV100cm'average
15000 dpm/IOOcm^ maximum
0.2 mr/hr @ 1cm average
1.0 mr/hr @ 1 cm maximum
Instrument Oata
Total Alpha/
Beta/Gamma
Model #;
SN:
Cai. Date:
Source:
Efficiency:
Factor
Background:
MDA
Locatioii #
Total Alpiia/
Beta.Gamma
cpm
7
8
9
10
11
12
Ore Haulage 2
4356782224 Internalional uranium 11:15:03 am 09-14-2009 3/11
Denison Mines (USA) Corp.
Equipment Survey for Unrestricted Release
Date; Container ID:
Inside Locations
L. Side
13 14
7 8
1 2
Front
19
23
13 16
22
9 10
21
3 4
20
Tailgate
RSide
17 18
11 12
5 6
Total Removable
Alplia Alpiia Beta
dpm/loOcm' dpm/ioocm' Gamma Location *
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Total
Alpha
Instojment:
SN
Cal. Dale:
fHinction Check (5x1 min.)
Th 230® 33000 dpm
Bkg Average:
Dpm Average:
Efliciency:
Eff Factor
MDA
Removable alpiia -1000 dpmflOOcm^
Fixed alpiia- SOOOdpmflOOcm'average
15000 dpm/tOOcm'maximum
Beta - Gamma • 0.2 mr/iir @ 1cm average
1.0 mr^hr @ 1cm maximum
Surveyed By:
Outside Locations
29 27
26
25
28
Front
37
34
36
33
35
32
30
31
dpmflOOcm'
24
Total Removable
Alpha Alptia Beta
Truck
and Tire Survey
1 0 02
3 00 004
5 00 OOe
Totai Alpiia/
Beta.Gamma
Location #
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Instrument
dpm/IOOcm' dpm/IOOcm' Gamma
Data
Tn
LocatlOfL
1:
2:
3:
4:
5:
6:
idk Ext.:
cpm
TRAILER TIRES
7 00 OOe
9 00 OOlO
11 00 O0i2
Total Alpiia/
Beta-Gamma
Location com
Removable Total
Alpha Beta/Gamma
Model:
SN:
Cal. Date:
Function Check (Sx 1 min.)
Model #:
SN:
Cal. Dale:
Soiree:
Alptia Bkg Ave: Reading:
Clia!
7
3
9
10
11
12
ssis Ext.
Alpha eff:
Alpha Factor
Commente :
4356782224 international uranium 11:15 14a.m. 09-14-2009 4/11
Date:
Daily
License/
Container #
Vehicle Scan for Vehicles Leaving the Restricted Area
Operator Truck/Tires
Total Alpha
dpm/IOOcm'
Rem. Alpha
dpm/100cm*
Beta/Gamma
p/r
mr/hr Done Bv
Removable alpha •
Fixed alpha -
Beta-Gamma -
1000 dpm/IOOcmZ
5000 dpm/100cm2 average
15000 dpm/lOOcmZ maximum
0.2 mr/hr @ 1 cm average
1.0 mr/hr @ 1 cm maximum
Alpha Meter
Model #177/43-1
SN
Cal. Date
Ctm:
Th-230 @330O0 dpm
Effidencv:
Factor:
Rka:
MDA:
Dose Rate Meter
Model*
3/HP270 SN 12658fl?N012026
3/43-2 SN 12661/PR3178
2/44-6 SN12859/RN012171
2/44-6 SN 4796/RN012490
Cs-V37#2
Cpm:
Efficiency:
Rka:
Comments:
4356782224 international uranium 11 15 22 a.m. 09-14-2009 5/11
DENISON MINES (USA) Corp.
White Mesa Mill
Radiation Survey of Equipment Released for Unrestricted Use
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with lhe following procedure.
1. Monitor for Gross alpha contamination with the appropriate survey meter.
2. If calculated assay exceeds 1,000 dpm/lOOcm^ then perform swipe analysis at applicable points.
3. Decontaminate if a removable alpha exceeds 1,000 dpm/IOOcm^ or fixed alpha exceeds 5,000 dpm/IOOcm^
4. Release equipment or material if alpha contamination and Beta-Gamma levels are below the following
limit:
Removable alpha- 1,000 dpm/IOOcm"
Fixed alpha- 5,000 dpra/lOOcm^ average
15,000 dpm/IOOcm^ maximum
Beta-Gamma- 0.2 mr/hr @ 1 cm average
1.0 mr/hr @ 1cm maximum
Released from White Mesa Mill to:
Released by:_ Date:
List of Equipment
1.
2.
3.
4.
5.
Total Alpha dpm/IOOcm^ Removable Alpha
dpm/IOOcm'
Beta/Gamma mr/hr
Instrument Function checks
Alpha Meter:
Inst. Model
Th-230 Source SN_
dpm cpm_
Efficiency Factor_
Bkg
MDA
SN
eff
Beta-Gamma Meter:
Inst. Model
Cs-137 Source SN_
Inst. Response
SN
Removable Alpha:
Inst. Model
Th-230 Source SN_
dpm cpm_
Efficiency Factor
SN
eff
Comments:
4356782224 International uranium 11:15:33am. 09-14-2009 6/11
Source Material Assay
&
Radiological Survey of Vanadium
Denison Mines (USA) Corp. Lot # :
Date:
Surveyed By:
Source Material Assay
Total Weight U : mg/kg
Total Weight Th : mg/kg
Total Source Material:
Total
Alpha
Instrument:
SN
Cal. Date:
Function Check (5x1 min.)
Th 230 @ 33000 dpm
Bkg Average:
Dpm Average
MDA
Removable
Alpha
Model:
SN:
Cal. Date:
Alpha Bkg Ave.
Alpha eff:
Alpha Factor:
MDA
Total
Beta/Gamma
Total
Gamma
Model #:
SN:
Cal. Date:
Source:
Reading:
Background:
Note:
Model #:
SN:
Cal. Date:
Source:
Reading:
Background:
Laboratory assay results for this lot of vanadium product are attached.
Comments:
4356782224 International uranium 11:15 41 a.m. 09-14-2009 7/11
DATE LOT NO.
BACKGROUND EFFICIENCY FACTOR
Drum
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
Total Alpha
dpm/IOOcm'
Removable Alpha
dpm/IOOcm^
Dose Rate mr/hr
Tops
Dose Rate mr/hr
Sides
Average Gamma Dose Rate/Lot_
Maximum Garnma Dose Rate/Lot
4356782224 International uranium 11:15 51 am. 09-14-2009 8/11
DATE LOT NO.
BACKGROUND EFFICIENCY FACTOR
Drum
Number
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
Total Alpha
dpm/100cm'
Removable Alpha
dpm/IOOcm'
•
Dose Rate mr/hr
Tops
DoseR
S
ate mr/hr
des
4356782224 international uranium 11:16:01 am 09-14-2009 9/11
atemSdns, UT &eg1l1
USA
Tsl: 435 676-2221
FSBE: 435 878-2224
www.datiisonmlna3.eom
SHIPMENT SURVEY
CONTRACT NO.
TRACTOR NO.
LOT NO.
TRUCK CARRIER
TRAILER NO.
ALPHA SURVEY
TOTAL
MODEL NO.
SERIAL NO.
CALIBRATION
EFRGIENCY
FACTOR
MDA
ALLOWABLE L MITS (FIXED) 5,000 DPM AVG. 15,
1.0
NSTRUMENTS
REMOVABLE
MODEL NO.
SERIAL NO.
CALIBRATION
EFFICIENCY
FACTOR
DOO DPM MAX ( REMOVABLE) 1,000 DPM
SURFACE AREA OF PROBE X EFFICIENCY OF INSTRUMENT (%; = FACTOR
100 cm' 100
(EFFICIENCY/1 OOcm')
Factor X counts/minute = Disiritegrations/minute/100cm'
GAMMA SURVEY (49 CFR 173.441 (b) (1))
INSTRUMENT NO.
SERIAL NO.
CALIBRATION
TRAILER SURFACE
SIX FEET DISTANCE
DRIVERS SEAT
SLEEPER
MEASURED IN MILLIREMS/ HOUR
(MR/HR)
200 MR/HR ALLOWABLE
10 MR/HR ALLOWABLE
5 MR/HR ALLOWABLE
5 MR/HR ALLOWABLE
ALL DRUMS WERE INSPECTED PRIOR TO LOADING. ALL DRUMS WERE TIGHTLY
SEALED. NONE LEAKED AND THERE WAS NO LOOSE MATERIAL IN THE VEHICLE.
INSPECTOR SIGNATURE DATE
4356782224 International uranium 11:16:16a m 09-14-2009 10/11
Denison Mines (USA) Corp.
DRUM CONTAMINATION SURVEY Page 2
Type of Shipment:, Lot#: Date:
Drum
#
1
2
3
4
5
6
! 7
8
9'
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total Alpha
dpm/100 cm^
Top Sides
Removable Alpha
dpm/IOOcm^
Top Sides
1
P/Y
Average
mrem/hr
* If total Alpha is greater than or equal to 1,000 dpm/100 cm^, a removable smear Is required.
Alpha Meter
Model #:
SN#:
Removable Alpha
Model #:
SN#:
Beta/Gamma Meter
Model #:.
SN#:
Cal. Date: _______
Check Date:
Th 230 @ 33,000 dpm
dpm Average:
Efficiency:
Bkg:
MDA:
Cal. Date:
Check Date:
Th 230 @ 33,000 dpm
Efficiency:
Bkg:
Cal. Date:
Check Date: _
Cs137SN#2
Reading:
Bkg:
4356782224 International uranium 11:16:26a.m 09-14-2009 11/11
Page 3
Drum
#
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
Total Alpha
dpm/IOOcm^
Top Sides
Removable Alpha
dpm/100 cm^
Top Sides
P/Y
Average
mrem/hr
'
Comments: