DRC-2009-002042 - 0901a06880118549

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DENISO
MINES
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Ji V^ ^ Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denlspnmines.com
May 15,2009
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: Interrogatory, Renewal Application for Radioactive Materials License (RML)
NO.UT1900479—Submittal of Draft Revised Radiation Safety Training Program
(Including Respiratory Protection Training Program Requirements)
Reference is made to the Executive Secretary's correspondence of November 24, 2008, which
sets out the first round of Interrogatories pertaining to the White Mesa Mill's (the "Mill's")
February 2007 License Renewal Application, and to Denison Mines (USA) Corp.'s
("Denison's") February 5, 2009 response to that letter.
In your November 24, 2008 letter you stated as Interrogatory 25:
Demonstrate that the Radiation Safety Program covers all of the material that
is outlined in NRC Reg. Guide 8.31 Section 2.5 Radiation Safety Training.
Explain in detail how this training is documented.
In our February 5, 2009 response we agreed that the Mill's Radiation Safety Training Program
is currently not structured so as to allow for an easy comparison of the topics covered and the
requirements of Reg. Guide 8.31. We committed to rewrite the Mill's Radiation Safety
Training Program so that the topics covered line up better with the topics outlined in Section 2.5
of Reg. Guide 8.31 to allow for a more direct comparison of the training program to those
requirements.
In your November 24, 2008 letter, you also stated in Interrogatory 26:
Demonstrate that the Respiratory Protection Program covers all ofthe material
that is outlined in NRC Reg. Guide 8.15 Section 5.2 Training.
In our February 5, 2009 response we agreed that the Mill's Respiratory Protection Training
Program is currently not structured so as to allow for an easy comparison of the topics covered
and the requirements of Reg. Guide 8.15. As with the Radiation Safety Training Program, we
committed to rewrite the Mill's Respiratory Protection Training Program so that the topics
covered line up better with the topics outlined in Section 5.2 of Reg. Guide 8.15 to allow for a
more direct comparison of the training program to those requirements.
In correspondence with your office on May 4, 2009 we advised that, in preparing the revised
Radiation Safety Training Program we realized that it would be preferable to combine the
Respiratory Protection Training Program into the Radiation Safety Training Program. This
better reflects the way the training is actually done at the Mill, and will result in one
comprehensive program.
Enclosed please find two copies of Denison's draft revised Radiation Safety Training Program,
which includes the Mill's respiratory protection training program requirements. This draft
Program has been updated to better track the requirements of Section 2.5 of Reg. Guide 8.31
and Section 5.2 of Reg. Guide 8.15, in order to address your concerns.
The revised Radiation Safety Training Program will replace the existing Addendum 9 of White
Mesa Mill SOP Book #13 Training Manual and will become the new Addendum 9 to that
Manual. Because this revised Program includes the respiratory protection training program
requirements, it will supersede Section 2.3 ofthe Mill's Respiratory Protection Program, which
will be deleted and replaced with a reference to the fact that the Mill's respiratory protection
training program requirements are included in the Mill's Radiation Safety Training Program.
We will provide you with a CD that contains an electronic copy of the draft revised Radiation
Safety Training Program within the next two business days.
If you should have any questions or require additional information, please contact the
undersigned.
Yours very truly.
DENISON MINES (USA) CORP.
By
David C. Frydenlund
Vice President, Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
DENISO MINES
fi^M
WHITE MESA MILL
RADIATION SAFETY TRAINING PROGRAM
1.Overview
This program outlines the radiation safety training (including respiratory protection training)that
will be given to all Mill workers,as well as to contractors and visitors at the Mill.
Radiation safety training for workers at the White Mesa Mill is comprised ofan initial four-hour
comprehensive session for all newly hired "inexperienced"Mill workers and a one-hour session
for all newly hired "experienced"Mill workers.White Mesa Inc.employees who work at the
Mill are considered to be Mill workers and will receive the same radiation safety training as
Denison employees.
The purpose ofthe initial training is to instruct all Mill workers on the inherent risks ofexposure
to radiation and the fundamentals ofprotection against exposure to uranium and its daughters
before beginning their jobs.
The initial radiation safety training is supplemented by annual one-hour re-fresher training
sessions which are provided to all facility workers.
In addition,contractors performing work at the Mill are required to be given appropriate training
and safety instruction,and there are training requirements applicable to visitors at the Mill.
Special pre-natal training is required for female Mill workers.
2.Definition of Experienced vs.Inexperienced Mill Workers
Newly hired Mill workers will be considered to be "experienced"Mill workers if:
(a)They have received the full 24-hour training for newly hired employees,including the
four-hour radiation safety training,at the Mill within the previous five years;
(b)They were previous Mill workers who satisfied the initial training requirements at the
Mill at some time in the past,and completed their last annual refresher training,including
radiation refresher training,within the last five years;or
(c)They have satisfied either (a)or (b)at another facility that the RSO has determined has a
comparable radiation safety training program.
All other newly hired Mill workers are considered to be "inexperienced"Mill workers,and are
required to take the full four-hour initial radiation safety training described in Section 3 below.
Newly hired experienced Mill workers are required to take the one-hour initial radiation safety
training described in Section 4 below.
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3.Initial Radiation Training For Newly Hired Inexperienced Mill Workers
All newly hired inexperienced Mill workers are required to be provided a four-hour radiation
training session as part oftheir initial 24-hour training required by MSHA.This training will be
provided by the Mill's RSO or Safety Coordinator or by a designee from the Radiation or Safety
Departments that meets the instructor requirements established by MSHA and that has adequate
knowledge and experience ofradiation safety matters as detennined by the RSO.The topics to
be covered in this initial four-hour training session are set out in Appendix A.The Alpha
Contamination Training Acknowledgement Fonn,Radiation Exposure Request Fonn and any
other fonn or document referred to in Appendix A are attached as Appendix B.
Employees are required to document that they have received their initial training by signing the
attendance list for the training session.These training lists are maintained on file with the
Radiation Safety Depmiment.
In addition,each newly hired inexperienced worker may,at the discretion of the instructor,be
provided with handouts for his or her review and reference,such as one or more ofthe
documents entitled "Radiation Protection at the White Mesa Mill,"or "Radiation Infonnation
Handout (Summary ofKey Concepts)"set out in Appendix C.
4.Initial Radiation Training For Newly Hired Experienced Mill Workers
All newly hired experienced Mill workers are required to be provided a one-hour radiation
training session as part oftheir initial eight-hour training required by MSHA.This training will
be provided by the Mill's RSO or Safety Coordinator or by a designee from the Radiation or
Safety Departments that meets the instructor requirements established by MSHA and that has
adequate knowledge and experience of radiation safety matters as detetmined by the RSO.The
topics to be covered in this initial one-hour training session are set out in Appendix D.
Employees are required to document that they have received their initial training by signing the
attendance list for the training session.These training lists are maintained on file with the
Radiation Safety Department.
Each newly hired experienced worker may,at the discretion ofthe instructor,be provided with
handouts for his or her review and reference,such as one or more ofthe documents entitled
"Radiation Protection at the White Mesa Mill,"or "Radiation Infonnation Handout (Summary of
Key Concepts)"set out in Appendix C.
5.Respirator Protection Training
The initial four hour training course for new inexperienced workers includes training for
respirator users.The topics to be covered are included in Appendix A.This training will include
hands-on training,and will take place prior to fit-testing.
Under the respirator protection training for newly hired inexperienced Mill workers,each worker
will:
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(a)be infOlmed of the hazard to which the respirator wearer may be exposed,the effects of
contaminants on the wearer if the respirator is not worn properly,and the capabilities and
limitations ofeach device that may be used;
(b)be shown how spectacle adapters communications equipment,and other equipment that
will be used directly in conjunction with the respirator are to be attached and operated
properly;
(c)be able to demonstrate competency in donning,using,and removing each type of
respiratory protective device that may be used;
(d)be instructed in how to inspect each type ofrespiratory protective device that may be
used and be instructed to perform such an inspection before donning any device;
(e)be instructed in how to perform a user seal check on face-sealing devices and be
instructed to perform this user seal check each time this type of device is donned;
(f)be informed that any respirator user may leave the work area at any time for relieffrom
respirator use in the event ofequipment malfunction,physical or psychological distress,
procedural or communications failure,significant deterioration of operating conditions or any
other condition that might necessitate such relief;and
(g)be advised that in case ofrespirator malfunction or wearer distress,the respirator may be
removed as the respirator user exits the airborne contamination area.
The initial training course for newly hired experienced Mill workers will include training for
respirator users as necessary,at the discretion ofthe instructor,depending on the level of
knowledge and experience ofthe worker,and will generally include,at a minimum,the items
listed in paragraphs (b),(c),(d),(e)and (f)above.
6.Annual Refresher Radiation Training
All Mill workers receive eight-hours ofrefresher training in accordance with the Mill's MSHA
training plan each year.This training includes one hour ofradiation safety training,including
relevant information that may become available during the past year,a review ofsafety problems
that arose during the year,changes in regulations and license conditions,exposure trends and
other current topics.This eight-hour annual refresher training is normally divided into 10
modules,one or more ofwhich comprises the required one-hour radiation safety training.
The annual refresher radiation training will be provided by the Mill's RSO or Safety Coordinator
or by a designee from the Radiation or Safety Departments that meets the instructor requirements
established by MSHA and that has adequate knowledge and experience ofradiation safety
matters as determined by the RSO.An example ofthe topics to be covered in the refresher
training session(s)is set out in Appendix E.
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Workers are required to document that they have received their annual refresher training by
signing the attendance list for the training session.These training lists are maintained on file
with the Radiation Safety Department.
In addition,further radiation safety training may,at the discretion ofthe RSO,be given at other
monthly or periodic safety meetings.
7.Tests For Newly Hired Mill Workers
As a component ofthe initial training program for both newly hired inexperienced and newly
hired experienced Mill workers,as well as for annual refresher training for all Mill workers,
written tests on radiation safety and respiratory protection are required to be completed.The
radiation safety test will have questions directly relevant to the principles ofradiation safety and
health protection covered in the initial training course for newly hired inexperienced Mill
workers.An example ofthis written test is set out in Appendix F.The respiratory protection test
will have questions directly relevant to respiratory protection and the proper use ofrespiratory
protection equipment covered in the initial training course for newly hired inexperienced Mill
workers.An example ofthe respiratory protection test is set out in Appendix G.The questions
on these tests will be changed from time to time.
Employees are required to attain a passing score of70%on each ofthese tests in order to
proceed or continue with Mill related work assignments.After completion ofthe tests,the
instructor will review the test results with each worker.Any wrong answers will be discussed
with the worker until he/she fully understands the subject ofthe question and the correct answer.
Workers who fail either test will receive additional training and be re-tested until a passing score
is attained.All test results are maintained on file with the Radiation Safety Department.
In special circumstances,where it is not possible or practicable for the individual to take one or
both ofthe written tests,the RSO or his designee may give the tests orally.In those
circumstances,the RSO or his designee will make a written record ofthe questions asked and
answers given.This record will be maintained on file in the Radiation Safety Department.
8.Specialized Training
In addition to the new hire training and refresher training described in items 3,4,5 and 6 above,
all new workers (including supervisors)are given specialized training on health and radiation
aspects oftheir specific jobs,including non-radiological hazards.New workers are first
provided with their initial radiation safety training described in items 3,4 and 5 above.When
the worker gets to his or her particular job,the supervisor will give the worker individualized on-
the-job training.This training typically does not cover radiation protection,to the extent it is
already covered in the initial training.Ifspecific radiation protection issues exist for any
particular job,or new job (such as may result for a new alternate feed material),such issues
would typically be addressed in a new Procedure or Radiation Work Permit ("RWP")or,in
celiain circumstances,by specific training given by the RSO or his designee.In all cases,the
training should be commensurate with the risks and hazards of the task.
Specific radiation protection training is nOlmally given on any new Procedure or RWP either at a
regularly scheduled radiation and safety meeting or at a radiation and safety meeting held for the
affected workers,prior to implementation of any such Procedure or RWP.New employees that
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are required to be given training on Procedures or RWPs or other training specific to their jobs
will be given such training prior to commencement oftheir jobs.
Such specialized training will be provided by the Mill's RSO or Safety Coordinator or by their
designees.Workers are required to document that they have received any specialized training on
a new Procedure by signing the attendance list for the training session.These training lists are
maintained on file with the Radiation Safety Department.With respect to RWPs,any required
training is given verbally by the member ofthe Radiation Safety Department who issues the
RWP.
If determined necessary by the RSO,supervisors will be provided additional specialized training
on their supervisory responsibilities in the area ofworker radiation protection.However,given
the nature of Mill operations and activities,the comprehensive training given to all workers,
including supervisors,and the supervisory role on radiation safety matters provided by the
Radiation Safety Department,such specialized training for supervisors is usually not required.
Any such specialized training will be documented and kept on file in the Radiation Safety
Department.
In addition,radiation safety matters of concern that may arise during Mill operations or activities
will,at the discretion of the RSO,be discussed with all affected workers during regular meetings,
such as tailgate meetings for maintenance and/or operations personnel,or at specially called
radiation safety meetings.
9.Visitors At The Mill
All visitors at the Mill who have not received radiation training must be escorted by a properly
trained individual who is knowledgeable about the hazards at the Mill.Such individual will
instruct visitors on what they should do to avoid possible radiological and non-radiological
hazards in the areas ofthe facility they will be visiting as an element ofproviding escort to the
visitor.
10.Contractors At The Mill
Any contractors receiving work assignments at the Mill will be given appropriate training and
safety instruction.Contractors who provide services on a full-time or long term basis or who
will perform work on heavily contaminated equipment will be given the same training regime as
Mill workers.However,onlyjob-specific radiation safety instruction is necessary for contract
workers who have previously received full training on prior work assignments at the Mill or have
previously received full training elsewhere.Casual or short term contractors having work
assignments at the Mill,where there is little or no risk ofany significant exposure to radiation,
are given abbreviated job-specific training and safety instructions specific to their assignments.
In all cases,the training should be commensurate with the risks and hazards ofthe task.
A copy ofthe packet given to contractors is attached as Appendix H.Contractors are required to
sign the packet acknowledging their acceptance thereof.Contractors that receive the same
training as newly hired Mill workers will be required to sign an attendance list for the training
session.These training lists will be maintained on file in the Radiation Safety Department.
Where such training is not required,basic radiation training is given to contractors verbally,
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unless more specific training is required,which will be addressed on a case by case basis and
will be provided by the RSO or his designee.
11.Pre-Natal Training
In addition to the foregoing training requirements,pre-natal training is provided to all female
workers pertaining to the content and requirements ofNRC Reg.Guide 8.13 while attending the
initial "new-hire"training session.A copy ofNRC Reg.Guide 8.13 is attached as Appendix I.
These workers are required to sign the form attached as Appendix J,attesting to the fact that they
have received this pre-natal training.
12.RSO Training
The Mill's RSO will attend refresher training on uranium recovery facility health physics every
two years.
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APPENDIX A
RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED INEXPERIENCED
MILL WORKERS
RADIATION AND RESPIRATORY PROTECTION SAFETY TRAINING OUTLINE
FOR NEWLY HIRED INEXPERIENCED MILL WORKERS:
1.Video -"Practical Radiation Safety"or "Radiation Naturally"
2.Fundamentals of Health Protection
a.The radiologic and toxic hazards ofexposure to uranium and its daughters
i.U-238 is a kidney toxin
ii.Lungs
iii.Liver
iv.Skin
b.How uranium and its daughters enter the body
i.Inhalation
11.Ingestion
111.Skin penetration
c.Why exposures to uranium and its daughters should be kept ALARA
i.Definition/explanation ofthe ALARA principle
11.Identification ofpostings in elevated areas
111.Reference potential hazards with material and why it is important to
maintain levels to ALARA
d.Different types ofradiation
i.Alpha
1.Will not penetrate dead layer ofskin
2.Travels about 2 inches in air
3.Can be blocked by a single sheet of paper
4.Large particle that is the easiest to protect against,but the one that can
cause the most damage when taken internally.The delicate internal
workings of the living cell forming the lining of the lungs or internal
organs,most certainly will be changed (mutated)or killed outright by
the energetic alpha particle.
5.Housekeeping and good personal hygiene are critical.
11.Beta
1.Can be blocked with plastic or PPE
2.Penetration greater than Alpha
3.Can penetrate the first two layers of skin
4.Second largest particle.
5.Travels about one meter in the air.
111.Gamma
1.Smallest in size
2.Can be blocked by lead
3.Is capable ofdamaging living cells as it slows down by transferring
energy to the surrounding cell components
IV.Radon Progeny
1.Ineli gas
2.Transported by carrier (water,diesel smoke,etc...)
3.Ventilation is principle remedy
4.Found in soils worldwide
e.Various types ofradiation exposure potential at the Mill
i.Conventional Ore -stockpiles and in process
ii.Yellowcake product -in process and final product
111.Alternate feed materials -stockpile (by various supplier)and in process
IV.Miscellaneous -sealed sources
3.Personal Hygiene at the White Mesa Mill
a.Wearing protective clothing
i.Importance -how the PPE protects against Alpha and/or Beta/Gamma
activity
11.Types ofPPE available
1.Tyvex
2.Coveralls
3.Rubber suits/gloves
4.Respiratory Protection
b.Using respiratory protective equipment correctly -See item 4
c.Eating,drinking and smoking only in designated areas
i.Regulated by the State ofUtah and MSHA
ii.Weekly alpha survey
111.Reducing potential for exposure
iv.Wash hands regardless ofjob assignment
d.Using proper methods for decontamination
i.Showers requirements
1.Mandatory for Yellowcake Operators
11.Laundry facility
4.Respiratory Protection Training
a.General
1.Video on Respiratory Protection
11.Program evaluation and revisions and record keeping
111.Employee training and documentation
IV.Fit Testing
1.Medical Clearance
2.Fit Tester 3000
3.Irritant smoke
v.Exchange/Issuance requirements -Daily Exchanges are required for all
devices
vi.Storage and care ofdevice
b.Hazards to which the respirator wearer may be exposed,the effects of
contaminants on the wearer if the respirator is not worn properly and the
capabilities and limitations ofeach device that may be used
i.Respiratory Hazards
1.Uranium airborne and effect
2.Radon daughters and effect
3.Chloride and effect
4.Ammonia and effect
5.Airborne vanadium dust and effect
6.Acid gases and effect
7.Other potential effects
11.Respirator selection
1.Types ofrespirators,their function,limitations
a.Full-face with combo cartridges -good for all environments at the
facility (pfof 50)
b.PAPR's -good for only dusty environments,not good for any
environment that may contain chemical mists (pf 1000)
c.SCBA's -good for all environments,has only thirty minute bottle of
air (pf10000)
d.NIOSH and MSHA approved respirators only
2.Identification ofhazards
a.02 content
b.Routine hazards
c.Non-routine hazards
c.Spectacle adapters,communications equipment and other equipment that will be
used directly in conjunction with the respirator are to be attached and operated
properly
i.At the White Mesa Mill,we only use the spectacle adapters.Spectacle
adapters are used for individuals who have prescription eyewear.The
adaptor is used so that there is not an issue with the arms ofthe glasses
potentially breaking the seal of the device.
11.Each employee who has to wear prescription eyewear must present a copy
of their current prescription to the Safety Department and the devices will be
ordered.
111.After the spectacle adapter has alTived,the Safety Department will train
each wearer on the proper care,maintenance and installation ofthe device.
This training is documented with a signed training certificate by both the
instructor and wearer and the document is then placed in the file in the
Radiation Office files.
d.Demonstration in donning,using and removing each type ofrespiratory protective
device that may be used
i.Wearing Instructions and training
1.Donning,wearing and removing the respirator
2.Adjusting the respirator so that its respiratory-inlet covering is properly
fitted on the wearer and so that the respirator causes a minimum amount
ofdiscomfOli to the wearer
3.Allowing the respirator wearer to wear the respirator in a safe
atmosphere for an adequate period of time to ensure that the wearer is
familiar with the operational characteristics ofthe respirator
4.Have each employee perform the donning for each device they may have
to wear while on property
e.Instruction in how to inspect each type ofrespiratory device that may be used and
be instructed to perform such an inspection before donning any device
i.Field Inspection
1.Valves
2.Body ofMask
3.Straps
4.Lens
5.Air lines
11.Respirator Sealing Problems
1.A person who has hair (stubble,mustache,sideburns,beard,low
hairline,bangs)which passes between the face and the sealing surface of
the face piece ofthe respirator shall not be pelIDitted to wear such a
respirator.
2.A person who has hair (mustache,beard)which interferes with the
function ofa respirator va1ve(s)shall not be permitted to wear such a
respirator.
3.A spectacle which has temple bars or straps which passes between the
sealing surface ofa respirator full face piece and the wearer's face shall
not be used.
4.A head covering which passes between the sealing surface ofa respirator
face piece and the wearer's face shall not be used.
5.The wearing ofa spectacle,or goggle,a face shield,a welding helmet,or
other eye and face protective device which interferes with the seal ofa
respirator to the wearer shall not be allowed.
6.Ifscars,hollow temples,excessively protruding check bones,deep
creases in facial skin,the absence ofteeth or dentures,or unusual facial
configurations prevent a seal ofa respirator face piece to a wearer's face,
the person shall not be permitted to wear the respirator.
7.Ifmissing teeth or dentures prevent a seal of a respirator mouthpiece in a
person's mouth,the person shall not be allowed to wear a respirator
equipped with a mouthpiece.
8.If a person has a nose ofa shape or size which prevents the closing of
the nose by the nose clamp ofa mouthpiece/nose clamp type of
respirator,the person shall not be permitted to wear this type of
respirator.
k.Instruction in how to perfOlID a user seal check on face sealing devices and how
to perfOlID this user seal check each time this type of device is donned
1.Refer to "d"ofthis section.
2.Demonstrate the proper techniques for performing a field positive and
negative pressure test.
3.Have each employee perform this task.(pass/fail)
4.Emphasis to each employee the importance ofperforming this task each and
every time the seal has been broken.
1.Information that any respirator user may leave the work area at any time for relief
from respirator is in the event ofequipment malfunction,physical or
psychological distress,procedural or communications failure,significant
deterioration of operating conditions, or any other condition that might necessitate
such relief
1.A respirator wearer shall be permitted to leave the hazardous area for any
respirator-related cause.Reasons which may cause a respirator wearer to
leave a hazardous area include,but are not limited to,the following:
a.Failure of the respirator to provide adequate protection
b.Malfunction ofthe respirator
c.Detection ofleakage ofair contaminant into the respirator
d.Severe discomfort in wearing the respirator
e.Increase resistance to breathing
f.Illness of the wearer,including:sensation of dizziness,nausea,weakness,
fatigue,breathing difficultly,coughing,sneezing,vomiting,fever or chills.
g.Claustrophobia,anxiety or other psychological factors that may affect the
wearer
h.Emergency respirator use
i.SCBA -Self-Contained Breathing Apparatus
ii.Emergency respirator issuance
iii.Only Certified individuals may use these devices
Be advised that in case ofrespirator malfunction or wearer distress,the respirator
may be removed as the respirator user exits the airborne contamination area
m.Each respirator wearer must understand that during any problem with the device
or distress,the device can be removed upon exiting the contamination area.A
report ofthe incident should be given the Safety Watch and the Safety
Depmiment immediately.
5.Facility Provided Protection
a.Ventilation systems and effluent controls
i.Explain the Demister and Scmbber system
ii.Negative pressure is Yellowcake Dryer and Packaging Enclosures
b.Cleanliness ofthe work place
i.ALARA and the impOliance ofthe principle
ii.Prevention of the spread ofmaterials
iii.Wash down ofwork areas
iv.Prompt notice and cleanup ofmaterials if spilled
v.Wash hands regardless ofjob assignment
c.Features designed for radiation safety for process equipment
i.Ventilation system in the process areas
ii.Remote access for packaging operations
d.Standard operating procedures
i.Each circuit's SOP addresses the specific radiation concerns
ii.Knowledge ofthe SOP's and radiation concerns ofone's circuit is
needed prior to commencement ofany work activity
111.Radiation Work Permit (RWP)
e.Security and access control to designated areas
i.Restricted Area requirements
11.Identification cards needed to access the Restricted Area
111.Access to the Product Storage Yard
IV.Surveillance cameras around the facility
v.24 hour coverage by a member ofthe Radiation Staff
f.Electronic data gathering and storage
g.Automated processes
i.Nuclear Density Gauges
h.Postings
i."Radioactive Materials Area"-This sign designates the Restricted
Area and signifies that one may come in contact with radioactive
materials once one has pasted the signage.
11."Caution Radiation Area"-Beta/Gamma values at or above 5.0
mR/hr.This posting means reduction in time and increase distance
from source or added shielding is required.
111."Caution Airborne Radioactivity Area"-Alpha activity value at or
above 25%of the conesponding DAC value.Respirators required
prior to entering area and increased bioassays.
6.Health Protection Measurements
a.Measurements ofairborne radioactive materials
1.Alpha Monitoring
11.Area Airborne
111.Radon Progeny
IV.Beta/Gamma
v.Breathing Zones
b.Bioassays to detect uranium (urinalysis)
i.Entrance/Exit Monitoring
11.Schedule
1.Monthly during production periods for all employees
2.Bi-month1y for employees working in ore handling and yellowcake
packaging operations.Also for declared pregnancy workers.
111.Action limits ofuranium detection in the bioassays
1.0 to 14 flg/L
a.Continue to review fuliher bioassay results
2.15 to 35 flg/L
a.Obtain additional sample
b.Identify the cause ofthe elevated sample
c.Examine air sampling data to determine the source ofintake
d.Determine ifother workers could have been exposed.
e.Consider work assignment limitations
f.Improve uranium confinement controls or respiratory
protection
3.Over 35 /-Lg/L
a.Take actions given above
b.Continue operations only ifit is virtually certain no other
worker will exceed the concentration
c.Establish work restrictions for affected employees
d.Weekly bioassays
IV.Investigation ofpotential uptake
v.Mitigation ofuptake
c.Surveys to detect contamination ofpersonnel and equipment
i.Exit Alpha Monitoring -leaving the Restricted Area
11.Break Times -Entering into an designated eating area
111.Spot checks
IV.Equipment releases and the limits for the facility
1.Alpha Personnel Release Rate (l,000 dpm/l 00 cm2)
2.Alpha values for unrestricted release
a.Removable 1,000 dpm/l00 cm2
b.Average 5,000 dpm/l 00 cm2
c.Maximum 15,000 dpm/lOO cm2
3.Beta/Gamma limits for unrestricted release
a.Average 0.20 mR/hr
b.Maximum 1.0 mR/hr
d.Personnel dosimetry
i.OSL
e.Potential Sources of Exposure at the facility
i.Conventional Ore Dust
ii.Alternate feed materials
iii.Yellowcake
iv.Tailings
v.Obsolete Equipment
f.Ways to reduce exposure
i.Time -limiting the amount oftime one spends in a given work
environment.Example is only allowing a celiain amount of time to be
allowed in an RWP.
11.Distance -creating a separation between one selfand the source of
exposure.Example is remote handling ofmaterial.
111.Shielding -placing a barrier between one selfand the source.
Example is a respirator.
7.Radiation Protection Regulations
a.Regulatory authority ofNRC,MSHA and State ofUtah
b.Employee rights in 10 CFR Part 19
c.Radiation protection requirements in 10 CFR Part 20
d.State ofUtah R313 rules
e.30 CFR Parts 47 and 56
f.Previous Radiation Exposure Information requests
8.Emergency Procedures
a.Emergency Response Plan
b.Facility notification cards
c.Decontamination procedures during an emergency
9.Alpha Contamination Training
a.Proper use of the personnel alpha monitor
b.What to do ifthe alarm were to sound and who to contact
c.Documentation ofthe training session and acceptance of possible disciplinary
actions for failure to comply with the regulation
10.Prenatal Radiation Exposure
a.Presentation ofNRC infOlmation (see Appendices I and J)
b.Discussion ofincreased monitoring
c.Completion ofFOlm
11.Any Handouts
12.Radiation Protection Quiz
13.Respiratory Protection Quiz
APPENDIXB
FORMS
Training on Proper use of Personnel Alpha Monitor
On , I received training on the proper use ofthe alpha monitor,and the
importance and need to conduct an alpha survey of all personnel leaving the restricted
area.What constitutes a proper survey with the alpha meter was discussed,along with
the possible use ofdisciplinary actions for 110t complying with the survey policy.I have
received the above training and understand the importance ofconducting a proper
personal alpha survey and the possible disciplinary actions that can be taken for non
compliance with this license requirement.
Training Conducted by :.~.__
Training Received by :___
Spectacle Kit Use Training
On _, I received training on how to properly use a spectacle
kit with a full face respirator.This instruction is part ofthe Respirator
Protection Program at the White Mesa Mill ofDenison Mines (USA)Corp.I
understand that Denison Mines will provide me with the spec kit,but it is
my responsibility to clean and care for the spec kit.Ifthe spec kit is lost with
in the first year,I will be responsible for the replacement cost ofthe spec kit.
Training received by
Training conducted by
Date
Date
Denison Mines (USA)Corp.
P.O.Box 809
6425 South Hwy 191
Blanding,Utah 84511
Date:--------
Re:---------
SSN:--------
DOB:--------
To:---_.
The above named person is employed,or is being considered for employment by Denison
Mines (USA)Corp.In accordance with provisions ofthe United States Nuclear
Regulatory Commission Regulations 10 CFR 19.13 (b),we request that you provide a
report ofthe occupational exposure to radiation while in your employ.
Sincerely,
David Turk
Radiation Safety Officer
Denison Mines (USA)Corp.
I,Hereby authorize release,to Denison Mines (USA)
Corp.,ofmy exposure history requested below.
TOTAL RADIATION EXPOSURE HISTORY
1.Period employed to
2.Place ofemployment _
3.Total exposure during period ofemployment _
Signed:_
Date:---------
Position:------
APPENDIXC
EXAMPLE HANDOUTS
RADIATION PROTECTION AT THE WHITE MESA MILL
1.Radiation
High levels of radiation are hannful to us.The amount of radiation a person is exposed to is
referred to as his or her "dose",and is typically measured in millirems ("mrems")per year.
Weare exposed to radiation from natural sources such as the sun,the soils and rocks around us
as well as the air we breathe.We are also exposed to radiation from other sources such as x-rays
perfonned in connection with medical and dental examinations.In the Blanding area,each
member of the general population is exposed to about 400 mrem per year from these natural
sources,not counting things such as x-rays.
2.Exposure Limits
In order to protect workers from excessive exposure to radiation,the Nuclear Regulatory
Commission ("NRC")has set maximum doses that workers can receive each year from working
at facilities such as the White Mesa Mill.Under these standards,the maximum total dose from
all sources at the Mill,over and above background radiation from natural sources,is 5,000 mrem
per year.
In addition,the NRC requires that each facility make efforts to keep exposures to workers As
Low as is Reasonably Achievable ("ALARA")below the 5,000 mrem/yr limit.In accordance
with this requirement,the Mill has set an ALARA goal at 1,250 mrem/yr for each worker,over
and above natural background.This goal is 25%ofthe regulatory standard of5,000 mrem/yr.
Exposures to Mill workers are typically well below this ALARA goal,being usually in the 80
mrem/yr to 400 mrem/yr range above background.
3.How do we Keep Exposures to Radiation to a Minimum
One of our prime objectives is to keep radiation exposures to Mill workers to a minimum.This
not only requires the effOlis of Denison.It also requires the efforts ofeach Mill worker to keep
his or her exposures to a minimum.In order for workers to be able to do this,a proper
understanding ofradiation,how you can be exposed to it and what precautions you can take are
extremely important.These topics are summarized below.
4.Types of radiation
There are three types ofradiation:alpha,beta and gamma radiation.
4.1 Alpha Radiation
Here at the White Mesa Mill,we work with uranium,one ofthose elements that are naturally
radioactive.Uranium is an alpha emitter.Alpha radiation doesn't travel very far,even in air.
The range in air for alpha radiation is about 1.25 inches.A single sheet of paper can block
alpha radiation.Even the skin layer on our bodies stops alpha radiation.So,outside of our
body,alpha radiation is really no problem.What about inside the body?Breathing uranium
dust or swallowing uranium dust is the problem.Uranium in the human body tends to seek
the bones and kidneys (i.e.,to collect there),where it can cause damage.
In addition,radon gas,which comes primarily from uranium ores and tailings,emits alpha
radiation and is in the air we breathe at the Mill.There is no smell or taste to radon gas and
you can't see it.Breathing high levels ofradon in the air is also hmmful to us.
4.2 Beta Radiation
Beta radiation does not travel very far in air,but it can penetrate the body,so merely being
close to a source of beta radiation will result in exposure to radiation.It is not necessary to
breathe in or swallow beta emitting particles,although that would also be another way that
beta radiation could enter your body.
However,because most of the radiation associated with the uramum process is alpha
radiation,beta radiation is not much of a problem at the Mill.While exposures to the body
merely from being close to beta radiation are minimal at the Mill,internal exposure to beta
radiation that enters the body through inhalation or ingestion of radioactive dust is a concern.
For example,as uranium decays some beta radiation is emitted,especially where aged
yellowcake is concerned,so personal hygiene in the yellowcake processing portion of the
Mill is important.
4.3 Gamma Radiation
Gamma rays are constantly being emitted from the raw ore.Like beta radiation,gamma
radiation can penetrate the body,so being close to a source of gamma radiation will result in
exposure to radiation.However,gamma radiation is stronger,can travel further in air and
can penetrate the body more readily than beta radiation.As with beta radiation,it is not
necessary to breathe in or swallow gamma emitting paliicles,although that would also be
another way that gamma radiation could enter your body.
Gamma radiation at the Mill is mainly associated with raw ores,tailings solids and some
alternate feed materials.So the people working in the ore piles,bucking room,tailings or
close to certain alternate feed materials should have the highest exposure to gamma radiation
here at the Mill site.
4..(RadioactiveDlIstis tlteMatit Coltcel'lt attlteUti!JI/e
As can be seen from the discussion above,radiation that enters the body through the inhalation
or ingestion of dust is the main concern at the Mill site.Keeping dust to a minimum and
providing protections to workers to minimize their exposure to radioactive dust is therefore a
primary objective.Radon is usually not a problem,unless in confined spaces.Exposures from
being close to beta/gamma radiation is also not usually as big a concern at the Mill site,due to
the relatively low levels ofthose types ofradiation found at the Mill.
5.Exposure Pathways and Precautions to be Taken
Radiation can enter the body in three different ways:
5.1 Being Close to a Source ofGamma Radiation
Being close to ore,tailings or certain alternate feed materials will expose the worker to
gamma and beta radiation.The stronger the source,the closer you are and the longer you
spend close to the source will increase your exposure.Shielding,such as lead can be used in
some circumstances to reduce exposures to gamma and beta radiation,although shielding is
not commonly used at the Mill,due to the generally low beta/gamma radiation experienced at
the Mill.
Each worker is required to wear an OSL badge that records his or her exposure to beta and
gamma radiation.The OSL badge must be worn on the torso and must not be shielded by
clothing.
Areas where beta/gamma radiation is high (i.e,over 5 mrad/hr)must be posted as "Radiation
Areas").
The precautions we take at the Mill to keep exposure to beta/gamma radiation to a minimum
are:
•Keeping workers away from areas with high beta/gamma radiation.When you see an
area posted as a "Radiation Area"do not go near that area unless required to do so for a
specific task;
•Minimizing the time each worker is required to work in areas with elevated beta/gamma
radiation.This also involves rotating workers so that the time each worker spends in the
"Radiation Area"is kept to a minimum;
• Using shielding in some cases;and
•Engineered controls in our process to reduce exposures faced by workers.
5.2 Breathing in Radioactive Dust or Radon
Any dust at the Mill can be radioactive.Ore dust is radioactive.Dust from the ore pad is
radioactive.Dust from around the facility buildings can be radioactive.Yellowcake dust is
radioactive,and tailings dusts are radioactive.In addition,radon gas is radioactive and can be
found in all areas of the Mill facility and property.Radon gas is particularly dangerous in
closed areas,where it can accumulate.
The Mill monitors various areas of the Mill facilities and Mill properties for radioactive dust
and radon gas.Each worker is required to keep track ofthe time he or she spends in each area
of the Mill each day and record these times on his or her Exposure Time Sheet.This allows
Mill Radiation Safety Staff to calculate how much exposure to radiation the worker has had
each day by determining how much time each worker spends in each area and by calculating
the exposure for the time spent in each area based on the monitoring results for that area.
This is why it is important for each worker to carefully and accurately fill out his or her
Exposure Time Sheet each day.
The precautions we take to keep exposures to radioactive dust and radon to a minimum are
the following:
•Good housekeeping is important in order to keep dust to a minimum within facility
buildings;
•Water is sprayed on the ore pad and other areas ofthe Mill propeliy in order to keep dust
to a minimum;
•Posting and restricting access to areas where there is a potential for higher exposures to
radioactive dust;
•Respiratory protection is required in areas where there is a potential for higher exposures
to radioactive dust and/or radon,such as in the yellowcake packaging area where uranium
concentrate is being handled;
•Showers are available to all workers and yellowcake workers are required to shower at
the end of their work shift;
•Non-routine projects that may result in radiation exposure are controlled by a Radiation
Work Permit where personal protective equipment (PPE)and additional monitoring (such
as breathing zone sampling)requirements can apply;and
•Work clothing remains at the Mill and all workers entering the restricted area are required
to survey for alpha contamination prior to leaving the facility.
5.3 Ingesting Radioactive Particles
Ingestion ofradioactive materials at the Mill is minimal but can occur directly by swallowing
dust that has entered your mouth or indirectly from contamination of food or other items a
person might put into his or her mouth.Smoking,eating,chewing gum or tobacco etc.are not
allowed in working areas of the Mill.Eating is restricted to only designated eating areas.
You may smoke only in a designated area outside ofthe Mill's restricted area.This exposure
pathway is best controlled by personal hygiene principles such as cleaning your hands before
eating.
6.Monitoring and Calculation of Total Dose Received by the Worker
In order to ensure that worker exposure is maintained within the regulatory limits and the Mill's
ALARA goal,various monitoring methods are used to assess the workers exposure.Air samples
are collected throughout the plant to assess concentrations of radioactive dust and radon in the
air,and the amount of time spent by workers in the various plant areas is recorded to determine
the inhalation exposure of each worker given his/her particular job assignment.In addition,
gamma and beta exposure is monitored by means of personal exposure badges (OSL)to assess
individual exposure to external sources.The amount of exposure a worker receives from
radioactive dust,radon and beta/gamma radiation to the body are added up to determine the total
dose (referred to as the worker's Total Effective Dose Equivalent or TEDE)received by the
worker for the year.The worker's TEDE is then compared to the regulatory limits and the Mill's
ALARA goal.
Urine samples are also collected from workers to ensure that internal uptake of uranium is not
damaging kidneys and in some instances to detennine uptake due to unusual circumstances.In
addition,and as mentioned above,workers are required to scan for alpha contamination as they
exit the restricted area to protect against offsite contamination and exposure.
7.Leaving the Mill Each Day
As can be seen from the infOlmation provided above,contamination control is important as a
means ofminimizing exposure to radiation at the Mill.One of the more important places where
this control is necessary is when a worker leaves the Mill.Taking a shower,leaving work
clothes at the work place and scanning out to ensure that you are not taking contaminants home
on your person are good practices to protect you and your family from offsite exposure.All
workers must scan before leaving the Mill's restricted area.All yellowcake workers must also
shower before leaving the restricted area.
8.Reporting
In order to detelmine that employee exposures are being maintained within the regulatory limits
and company goals,annual exposure calculations for each worker are completed by the
Radiation Safety Department.These reports are utilized to demonstrate compliance with the
standards,assess any trends in exposure and to provide a record to the individual worker.Each
worker receives an exposure report annually from the Radiation Safety Department.
9.Conclusion
Uranium is a naturally occurring radioactive element which can have harmful effects if not
properly monitored and controlled.At the Mill we can be exposed to alpha,beta and gamma
radiation and our exposures to those fonus of radiation are limited by regulation and company
policy.Because uranium is primarily an alpha emitter,alpha radiation is the principle type of
radiation exposure at the Mill.This means that minimizing the inhalation or swallowing of
radioactive dust at the Mill is a primary objective.
The radiation you may be exposed to at the Mill is monitored by sampling the air you breathe
and measuring the external radiation received by your personnel exposure badge.The results of
this monitoring are evaluated and reported to you annually so that you are made aware of your
exposure.
While the company provides engineering controls to protect you from sources ofradiation,each
employee must remain aware of conditions at the Mill.Avoiding high radiation areas,wearing
respirators where/when required,cleaning your hands before eating,avoiding dusty situations
and using contamination control procedures when you leave the propetiy are individual
protections you can use to minimize your exposure to radiation at the Mill.
RADIATION INFORMATION HANDOUT
(Summary of Key Concepts)
The following are items that are central to one's understanding ofthe Radiation Protection
Program for Denison Mines (USA)Corp.at the White Mesa Mill.
Definitions:
•DAC -Derived Air Concentration
•ALARA -As Low As Reasonably Achievable
•NRC -Nuclear Regulatory Commission
•DRC -State ofUtah Division ofRadiation Control
•TEDE -Total Effective Dose Equivalent (total dose from beta/gamma,as
measured by the OSL badge,air particulate and radon)
•CEDE -Cumulative Effective Dose Equivalent (dose from radon and air
particulate.Does not include the dose from beta/gamma)
• PAPR -Powered Air Purifying Respirator
•SCBA -SelfContained Breathing Apparatus
•RWP -Radiation Work Permit
•OSL -Optically Stimulated Luminescence.Device used to monitor
beta/gamma exposure.Device must be worn in the center of the chest not on
the back of the hardhat.
•Restricted Area -Consists ofall operational and disposal areas.
DACs:
Radioactive dust (air particulate)has a different impact on our bodies depending on what stage
ofthe process or location ofthe facility we are in.This is because the combinations ofuranium
and its daughters (Radium 226,Thorium 230 and Lead 210)are different in the different stages
ofthe process.For example uranium and its daughters have equal radioactivity levels in
conventional ores on the ore pad,but yellowcake is mostly uranium and has hardly any daughters
present.The DAC is the acceptable level ofradioactivity in a particular area ofthe Mill,taking
into account the mixtures ofradionuclides found in the area.It sets the level ofradioactivity in
air particulate that you could breathe on a full time basis for an entire working year in that area
ofthe Mill before exceeding the regulatory limit.For example,the DAC for the ore pad is more
restlictive than the DAC for the yellowcake area,reflecting the fact that the mixture of
radionuclides on the ore pad is more harmful to our bodies for any given level ofradiation.
However,even though the mixture ofradionuclides found on the ore pad is more dangerous than
the mixture ofradionuclides found in the yellowcake packaging area for any given level of
radiation,the radiation levels in the yellowcake area are much higher than on the ore pad,thus
making the yellowcake packaging area an area ofhigher radiation concern than the ore pad.
Postings:
•"Radioactive Materials Area"-signifies that anywhere beyond that point
there is the potential ofcoming into contact with radioactive materials.That
includes disposal areas,operational areas,product and raw ore.
•"Caution Radiation Area"-signifies that that area contains material that has
beta/gamma values at or above 5 mrem/hr.Areas that are posted as this are
the yellowcake dryer enclosures,centrifuges,packaging enclosure and some
alternate feed locations.
•"Caution Airborne Radioactivity Area"-signifies that an area contains
airborne alpha activity at or above 25%of the corresponding DAC and
respiratory protection is required.Areas that are posted as this are the
yellowcake dryers and packaging enclosure.The SAG Mill is sometimes
posted as an airborne activity area.It will all depend on the grade ofore being
processed.
Bioassays:
Bioassays are collected from all employees.These samples are collected to test to see if
there has been a possible ingestion or inhalation of uranium.During production periods,every
employee is tested monthly.Some individuals,depending on their job assignment can be tested
weekly or every two weeks.Samples are also collected after the completion ofspecial work
assignments,such as an RWP.Also,all newly hired individuals are tested to see ifthere is a
baseline ofuranium in their mine.All employees upon their telmination must submit a final
sample.
All bioassays are to be given prior to the beginning ofone's shift and before one enters
the Restricted Area.
Exposure Limits:
The NRC states that all occupationally exposed employee shall not exceed 5 rem/yr.Our
ALARA limit is 25%or 1.25 rem/yr.
Scanning:
Every person who enters into the Restricted Area must scan themselves prior to exiting or
entering an eating area (within the Restricted Area).A proper scan consists of a slow brush of
the detector over the hands,arms,chest,legs and shoes.The meter should be kept at l;,j"away
from the body in order to not puncture the mylar face ofthe probe.If the alarm sounds,hit reset
and scan that affected area again.If the meter alarms again,contact the Radiation Department.
A proper scan should take approximately 30 seconds.
Health and Hygiene:
Wash your hands regardless of your job assignment.Some positions at the facility
require mandatory showers.You are paid for that shower time,so make sure you do it.Also,
the facility is equipped with a laundry.Make sure you wash your work clothes periodically.Do
not take home any clothing or materials without having them scanned by a member ofthe
Radiation Department first.
Radiation:
•Alpha-
o Will not penetrate dead layer of skin
o Travels about 1.25 inches in air
o Can be blocked by a single sheet of paper
o Large patiicle that is the easiest to protect against,but the one that can
cause the most damage when taken internally.The delicate internal
workings ofthe living cell forming the lining ofthe lungs or internal
organs,most certainly will be changed (mutated)or killed outright by
the energetic alpha particle.
o Housekeeping and good hygiene are critical
•Beta-
o Can be blocked by plastic or PPE
o Penetration greater than Alpha
o Can penetrate the first two layers of skin
o Second largest particle
o Travels about one meter in air
•Gamma-
o Smallest in size
o Travels furthest in air
o Can penetrate into and through your body
o Can be fully or partially blocked by lead or other shielding,depending
on the strength of the source,the distance you are from the source and
the type and thickness ofthe shielding
o Is capable ofdamaging cells as it slows down by transferring energy to
the surrounding cell components.
•Radon-
o Inert gas
o TranspOlied by carrier (water,diesel smoke,etc...)
o Ventilation is principal remedy
o Found in soils worldwide
Three ways to reduce exposure from beta/gamma radiation:
•Time -by limiting the amount oftime one spends in an area,one can reduce
the amount of exposure they receive.
•Distance -by creating a space between one's self and the source you can
reduce exposure.
•Shielding by placing something between one's self and the source you can
reduce exposure.This can be done by placing a barrier,such as a wall,PPE
or other physical barriers between yourself and the source.
Ways to reduce exposure to alpha radiation:
•Dust minimization
o Good housekeeping
o Water sprays on ore pad and roadways
o Dust collection systems at various points in the process
•Enclosed areas ofhigh potential exposure to air particulate,such as
yellowcake areas
•Use ofrespiratory protection in areas ofhigh potential exposure to air
particulate
•Designated eating areas
•Personal hygiene to minimize ingestion (e.g.,washing hands before eating,
washing work clothes)
•Mandatory showers for yellowcake workers
•Mandatory alpha scan for everyone who leaves the Mill's restricted area
Respiratory Protection:
•Types ofdevices on site
o Full-face -with combo cmiridges is good for both chemical and dusty
environments.Has a protection factor of50.
o PAPR -is only good for dusty environments.Will not protect you in
a chemical mist type of environment.Has a protection factor of 1,000.
o SCBA -is good for all environments,but only has a 30 minute bottle
ofair.Has a protection factor of 10,000.
•Exchange policy -all respirators must be turned into the Radiation/Safety
Depmiment on a daily basis.
APPENDIXD
RADIATION SAFETY TRAINING OUTLINE FOR NEWLY HIRED EXPERIENCED
MILL WORKERS
The following topics will be discussed in this training:
1.Review of Key Radiation Safety Topics
(a)At the discretion ofthe instructor,review selected key radiation safety topics,such as one
or more ofthe topics set out in the handouts included in Appendix C or in the Radiation
Safety Training outline in Appendix A,as necessary to ensure that the worker has an
equivalent level ofknowledge as a newly hired inexperienced worker who has completed his
or her training,depending on the level ofknowledge and experience ofthe worker.
(b)At the discretion ofthe instructor,distribute one or more handouts for the worker's
review and reference,such as one or more ofthe documents entitled "Radiation Protection at
the Mill,"or "Radiation Information Handout"set out in Appendix C.
2.Site Specific Training
(a)Where the worker has received his or her previous radiation safety training at another
facility,provide site specific training as necessary,in the discretion ofthe instructor.
3.Relevant information that has become available since the worker's last radiation safety
training or refresher training
(a)Processing changes that may affect exposures
(b)Posting changes,if any
(c)Discussion ofair,radon and beta!gamma survey results
(d)Changes to SOP's that affect Radiation Safety
4.Review ofsafety problems that have arisen since the worker's last radiation safety
training or refresher training
(a)Discuss issues that have been raised through daily and weekly inspections
(b)Housekeeping issues
(c)RWP's
5.Changes in regulations and license conditions since the worker's last radiation safety
training
(a)Discuss changes that affect the operation or other activities in the Mill
(b)Discuss NOY's or recommendations from the DRC
6.Exposure trends
(a)Average exposure for the previous year
(b)Highest exposure for the previous year
(c)Comparison ofexposures versus background
(d)Discussion on the exposures rates received and how those results compare with the
ALARA goals
7.Other current topics
(a)Discuss any problem areas that may have arisen
8.Respirator Training
(a)Provide respirator training as necessary,including at a minimum:
i)Have the worker demonstrate how spectacle adapters communications
equipment,and other equipment that will be used directly in conjunction with
the respirator are to be attached and operated properly;
ii)have the worker demonstrate competency in donning,using,and removing each
type ofrespiratory protective device that may be used;
iii)have the worker demonstrate how to inspect each type ofrespiratory protective
device that may be used and instruct the worker to perform such an inspection
before donning any device;
iv)have the worker demonstrate perfOllliance ofa user seal check on face-sealing
devices and instruct the worker to perform this user seal check each time this
type ofdevice is donned;
v)infOllli the worker that any respirator user may leave the work area at any time
for relief from respirator use in the event ofequipment malfunction,physical or
psychological distress,procedural or communications failure,significant
deterioration ofoperating conditions or any other condition that might
necessitate such relief;and
i)advise the worker that in case ofrespirator malfunction or wearer distress,the
respirator may be removed as the respirator user exits the airborne
contamination area.
(b)The instructor should be satisfied that the worker understands,through this or previous
training,the hazard to which the respirator wearer may be exposed,the effects of
contaminants on the wearer ifthe respirator is not worn properly,and the capabilities and
limitations ofeach device that may be used.
9.Pre-Natal Training
(a)Presentation ofNRC information (see Appendices I and J)
(b)Discussion ofincreased monitoring
(c)Completion of Form
APPENDIXE
RADIATION SAFETY TRAINING OUTLINE FOR ANNUAL REFRESHER TRAINING
The following topics will be discussed in this training:
1.Relevant information that has become available during the past year
(a)Processing changes that may affect exposures
(b)Posting changes,if any
(c)Discussion ofair,radon and beta!gamma survey results
(d)Changes to SOP's that affect Radiation Safety
2.Review of safety problems that have arisen during the year
(a)Discuss issues that have been raised through daily and weekly inspections
(b)Housekeeping issues
(c)RWP's
3.Changes in regulations and license conditions
(a)Discuss changes that affect the operation or other activities in the Mill
(b)Discuss NOV's or recommendations from the DRC
4.Exposure trends
(a)Average exposure for the previous year
(b)Highest exposure for the previous year
(c)Comparison ofexposures versus background
(d)Discussion on the exposures rates received and how those results compare with the
ALARA goals
5.Other current topics
(a)Discuss any problem areas that may have arisen
6.Review ofKey Radiation Safety Topics
(a)At the discretion ofthe instructor,selected key radiation safety topics,such as one or
more of the topics listed on the handouts included in Appendix C or on the Radiation Safety
Training outline set out as Appendix A,may be reviewed.
APPENDIXF
SAMPLE RADIATION SAFETY QUIZ
Name ------------------.---
Rev 03-02-09
Date _
Radiation Protection Quiz 2009
Select the com;:ct answer from the possible choices.
1.Radiation Exposure time cards are:
a.Filled out the same every day.
b.A important part in estimating yom radiation exposure to airborne radioactivity
c.Filled out by your supervisor.
d.Filled out in pencil.
2.OSL badges are used at the Mill to monitor:
a.Microwave radiation exposure.
b.External Beta/Gamma exposure.
c.Radon exposure.
d.Cosmic radiation exposmc.
3.When issued a clean respirator you must:
a.Return after each shift.
b.Fit test with irritant smoke.
c.Perform a field inspection oftherespirator.
d.All ofthe above.
4.To minimize the ingestion ofuranium,you should:
a.Wash hands before eating regardless ofjob assignment.
b.Wash hands before eating only if you are working with yellowcake.
c.Wear gloves while eating.
d.Wash hands before eating when visibly dirty.
5.Leaving the restricted area requires you to:
a.You do not have to monitor yourself.
b.Monitor your selfby brushing the detector over your cloths,hands,and sales ofyour feet.
c.Monitor your selfwhen you are being watched.
d.Monitor your selfonly on the way home.
6.Housekeeping is:
a.Regulated byMSHA.
b.Regulated by the State ofUtah Division ofRadiation Control.
c.Essential to reducing the potential for exposure.
d.All ofthe above.
7.Ifyour supervisor wants you to do a task that is 110t routine for yow'job,you should:
a.Find out what special hazards maybe encountered and ifpermits are needed.
b.Contact the Radiation Office afterwards.
c.Leave it for the next shift.
d.None oHhe above.
8.A.n area posted,as "Caution Radiation Area"means:
a.Airbome ttl'anium concentrations are above 25%ofDAC.
b.Beta/Gmmlla values are at or above 5 111rem/hr.
c.You must weill'a respirator.
d.An RWP is required to enter the area.
9.The ways to reduce workers dose exposures are:
a.Decrease time.
b.Increase distance.
c.Shielding.
d.All ofthe above.
10.Alpha radiation is the same as:
a.Gamma radiation.
b.Microwave radiation.
c.Radiation from the sun.
d.None ofthe above.
.11.An area posted as "Caution Airborne Radioactivity Area"means:
a.Airborne uranium concentration is above 25%ofDAC.
b.Beta-Gamma levels are at or above 2 mrem/hr.
c.You must wear a respirator when you work in the area.
d.Both A and C.
12.Bioassay monitoring determines:
a.Quantity ofuranium absorbed through the skin.
b.Probable ingestion orinhalation ofuranium.
c.Probable exposure to gamma radiation.
d.Quantity ofthorium absorbed through the skin.
13.Total Effective Dose Equivalent (TEDE)is:
a.Internal exposure effect on the individual.
b.The sum ofinternal and extemal exposure.
c.Calculate extemal exposure.
d.The release requirements set by the state for equipment.
14,!\LARA stands for:
a.Acceptable Level Assimilation Resonance AJlowable.
b.As Lovv As Reasonably Achievable.
c.As Long As the RSO Allows.
d.Just another acronym that no one understands.
15.Yellowcake is;
a.Chemically toxic.
b.Produces only Gamma radiation.
c.Yellow all the time.
d.Should be eaten with ice cream.
16.DAC stands for:
a.Daily Accumulated Concentration.
b.Daily Accumulated Contaminate.
c.Dose Actually Calculated.
d.Derived Air Concentration.
17.ALARA limits are:
a.More restrictive than NRC limits.
b.Essentially the sanle as NRC limits.
c.Less restrictive than NRC limits.
d.Have nothing to do with NRC limits.
18.The Restricted Area:
a.May be visited,with permission,regardless ofage.
b.Contains high level radioactive materials.
c.Is an excellent hunting preserve.
d.Consists ofall operational and disposal area.
19.The Utah Radiation Control Division has regulatory authority for:
a.Uranium Mills.
b.Employee health in uranium mills.
c.Environmental concerns while processing uranium.
d.All ofthe above.
20.A "Radioactive Materials"sign signifies that in the area:
a.There maybe a potential external exposure level greater than 2.0 mrem/hr.
b.There maybe a potential external exposure level of5.0 mrem/hr or greater.
c.There maybe drums in the area that contain uranium product.
d.All ofthe above.
21.Bioassay smnplcs must be given:
a.Whenever you feel like it
b.Before reporting to yourjob assignment.
c.After you get ready for the day.
d.When wearing work gloves.
22.1ft11e persOlUlel scanner alann goes off,what must one do:
a.Hit reset and leave it for the next employee to deal with.
b.Walk on by and just sign your name.
c.Contact the radiation department.
d.Pick up the probe and go through the motions.
23.When required to wear certain PPE,one must wear it:
a.Whenever the RSO walles by.
b.Whenever you think the supervisors are watching you.
c.Whenever you remember.
d.Whenever you enter a job assignment that it has been required and until restriction have been
lifted.
24.Which ofthe following materials must be surveyed prior to leaving the restricted area:
a.Tools.
b.Vehicles.
c.Equipment.
d.All ofthe above.
25.Radiation Work Pennits (RWP's)are issued by:
a.Safety Department.
b.Radiation Department.
c.Any Supervisor.
d.All ofthe above.
26.The gravel roadway can be accessed by Mill vehicular traffic without going tlU"ough
decontamination?
a.True
b.False
27.Equipment and vehicles can be scanned out by any supervisor?
a.True
b.False
28.\iVhere are OSL bndges stored?
a.In one's locker.
b.On the OSL badge board.
c.At home.
d.Vvherever you leave at the end ofthe shift.
29.Ifyour OSL badge is lost,when should you report it?
a.As soon as you realize it is missing.
b.When you get around to it.
c.At the end ofthe quarter.
d.It is up to the Radiation Department,not me.
APPENDIXG
SAMPLE RESPIRATORY PROTECTION QUIZ
Nalnc._....._..__..._..
Rev 03-06-09
Date-----
ResQiratory Protection Quiz 2009
Select the corrcct answer from the possible choices_
1.If you wear a respirator for only a few minutes,how often must you exchange?
a.Daily
b.Weekly
c_Monthly
d.Quatterly
2.Ifyou are experiencing wanu air blow back what is the likely cause?
a.Watm weather conditions.
b.Cartridges are starting to plug up.
c.No need for alanu.
d.All ofthe above.
3.When issued a clean respirator you must:
a.Fill out a respirator issuance log.
b.Fit test with irri.tant smoke.
c.Perform a field inspection ofthe respirator.
d.All ofthe above.
4.Who may issue a respirator?
a.Any supervisor.
b.I can check out my own respirator.
c.A member ofthe Radiation/Safety Department.
d.My direct supervisor.
5.When you are not wearing your respirator where must your respirator be stored?
a.In the zip locked plastic bag that comes with the device.
b.In your circuit.
c.In the Central Control Room.
d.Wherever you want.
6.A field inspection consists of:
a.Inspecting for cracks,wear marks and split rubber.
b.Checking the seals.
c.Checking the face shield.
d.All ofthe above.
7.Ifyou wear your respirator for more than four hours a shift,how often must you exchange the
device?
a.Daily.
b.Weekly.
c.Monthly.
d.Quarterly.
8.To wear a respirator,which ofthe following must be done?
a.Be clean shaven.
b.Ifyou wear glasses,make sure you have a spectacle kit for the device.
c.Pelfonn a smoke test.
d.All ofthe above.
9.A full face respirator has what protection factor?
a.10
b.50
c.1,000
d.10,000
10.A PAPR (Powered Air Pmifying Respirator)is good for which environments?
a.All enviromnents on site.
b.Dusty environment.
c.Chemical mist environment.
d.None ofthe above.
11.An area posted as "Caution Airborne Radioactivity Area"means?
a.Airborne uranium concentration is above 25%ofDAC.
b.Beta-Gamma levels are at or above 2 mremlhr.
c.You must wear a respirator when you work in the area.
d.Both A and C.
12.Ofthe following which areas are mandatory respirator areas?
a.Yellowcake Dryers.
b.Vanadium Packaging Area.
c.Yellowcake Packaging Area.
d.Any area labeled as an airborne radioactivity area.
e.All ofthe above.
13.Occasional respirator use requires device exchange:
a.Daily.
b.Weekly.
c.Monthly.
d.Qualterly.
14.A field test is not required every time the seal is broken during usage:
a.True.
b.False.
15.What type of respirator protection is available at this facility?
a.Full face
b.PAPR
c.SCBA
d.All ofthe above.
16.Who is required to use an SCBA?
a.Anyone can use an SCBA
b.Only certified individuals
c.Only Maintenance Crew Members
d.Only Operation Crew Members
APPENDIXH
CONTRACTOR SAFETY RULES
CONTRACTOR SAFETY RULES
Contractor shall be responsible for compliance with all local,State,Federal and Company safety,
health and environmental laws and regulations in effect.Contractor shall also be held to
understand that this site is a State of Utah Division of Radiation Control licensed facility and is
governed by the rules and regulations of the Owner,State of Utah DRC and MSHA.Owner
requires that all work conducted by Contractor and its employees be performed in a responsible
manner with special attention and mutual cooperation on the part ofeveryone involved including
Contractor,its employees and the employees of the Owner.
As pmi of its Contractual obligation,Contractor and its employees are expected to abide by all
applicable safety rules.Mandatory,(MSHA,OSHA,State or Company,etc.)safety and health
training must be received by all workers prior to starting any work on site.The rules listed
below are minimum basic Owner Safety Rules and Regulations;they do not in any way contain
every necessary rule.If the Contractor has questions concerning Safety Rules and Regulations,
Contractor shall consult with Owner's Representative before stmiing work.
The fact that other applicable rules,regulations or requirements (Federal,State or local)are not
printed herein will not be an excuse for any violation.Any violations of these rules and
regulations be it accidental or intentional may be cause for termination ofthis contract.
OWNER SAFETY RULES AND REGULATIONS
I.TRAINING
All contract employees must receive the training required by Owner prior to starting
work on site.
II.PERSONNEL PROTECTION
Hardhats,safety glasses,identification badges and steel toe shoes will be required
when entering the mill area.whenever,work is performed in an environment,which
requires special protection,such as respirators,hearing protection,goggles or face
shield,wet suits,etc.this protection must be worn.If there is a question as to
whether this special equipment is required,contact the Owner's Representative.
Persons with hair that extends longer than two (2)inches below the tee shirt collar
must confine the hair.
If respiratory protection is required a respirator fitness physical and fit test are
required.Any question regarding this subject shall be directed to the Owners
Representative.
Appropriate fall protection shall be worn at locations where there is a danger of
falling and/or where required by Owner.
III.RADIATION PROTECTION
The White Mesa Mill has a radioactive materials license with the State of Utah
Division of Radiation Control.Under that license, there are certain items that must be
observed by all parties on site.Those are,but not limited to:
a.Eating,drinking and chewing are only authorized in designated areas.These
areas are determined and posted by the Radiation Safety Officer.Potentially
contaminated PPE is not allowed in these areas.
b.All personnel,equipment and vehicles that enter into the restricted area,must be
surveyed for radiological release prior to leaving the restricted area.All mobile
equipment must travel through the decontamination wash station before being
presented for release from the site.
c.Before work assignments commence,the Contractor must present their job
assignment to the Radiation Department.The Radiation Department will
determine exposure potential and will issue a Radiation Work Pelmit if
applicable.
d.All Contractor personnel must submit to periodic bioassay monitoring for the
determination of potential uptake or ingestion ofuranium.
e.Respiratory protection may be needed if there is determined that an area is
contaminated.If respiratory protection is required,the Contractor will provide
medical clearance for their personnel.Respiratory devices will only be issued
upon the successful completion of the medical evaluation and onsite respirator fit
testing.
f.Personnel must monitor him or her with the use of an alpha monitoring device
prior to leaving the restricted area.Monitoring locations are under surveillance to
ensure that proper techniques are being applied.Contractor personnel will be
trained in the proper use ofthese instruments.
g.Failure to comply with these items and others as deemed necessary by the
Radiation Safety Officer will be grounds for immediate telmination of services at
the facility.
IV.HOUSEKEEPING AND STORAGE
Debris will not be allowed to accumulate.Regular removal to designated areas is a
requirement.Tools,equipment and materials will be stored in a safe and orderly
fashion that minimizes interference with operations or traffic.Upon completion of
the job,Contractor shall remove all construction debris and leave the site neat and
orderly.
V.FIRE PROTECTION
a.Fire extinguishers are to be provided by Contractor and will be kept immediately
available when burning or welding in areas adjacent to combustible material.
They must not be obtained by removing Owner's extinguishers from established
locations.
b.The White Mesa Mill is a smoke free work place.Therefore smoking is
prohibited in the administration building and the restricted area.It is necessary
however to post areas as no smoking areas wherever flammables are stored.
c.No person shall use open flames within 50 feet of where flammable materials are
stored.
d.Combustible material;i.e.,grease,lubricants,flammable liquids,etc.shall not be
allowed to accumulate where they can create a fire hazard.
e.Personnel must be familiar with site emergency procedures;i.e.fire drills
evacuation drills,etc.as instructed by the Owner's Representative.
f.Fire alarm procedures will be provided by Owner's Representative.
g.Flammable liquids (flash points below 100°F)shall not be used for cleaning
purposes.
h.Containers of combustible or flammable liquids shall be bonded and grounded
whenever liquid is being transfened;hose must be in metallic contact during
transfer.
1.Flame pelmits will be used where required by Owner's Representative.
J.Flammable or combustible materials must be stored in spill proof containers and
properly labeled.
VI.GENERAL
a.Utilities -Connection to or disruption of service ofany utility,such as electricity,
steam,water,gas,etc.,requires notice to and approval ofOwner's Representative
before action is taken.
b.Alcohol and Drugs -No person will be permitted to work while under the
influence of or in the possession of alcohol or drugs.Persons taking medication
will not be permitted to work it is affects their performance or judgment.A drug
and alcohol testing policy is in place at this facility.All Contractor personnel will
be subject to random and accident investigation samplings.
c.Signs and Warnings -Anytime work is performed which could present a hazard
to others;the area must be roped off or barricaded.All posted signs and other
warnings devices shall be strictly observed.
d.Horseplay -Horseplay will not be tolerated.
e.Eating Areas -Eating,drinking and chewing is permitted only in designated areas
by the Owner.
f.Restricted Area - A radiation survey must be performed on all personnel and
equipment prior to leaving the restricted area.The restricted area consists of all
operational and disposal areas.
VII.SPECIAL PROCEDURES
a.Lockout procedures -When work is to be perfOlmed on any equipment,tanks and
lines the "Zero Energy"concept will apply.
Each job,which requires lockout must be authorized by Owner's Representative
before any equipment is turned off or locked out.Owner's Representative will
assist Contractor to assure proper lockout procedure is followed.
To assure that the correct drive switch has been locked out;an attempt must be
made to start the equipment before work is started.The assurance can be gained
on interlocked systems by attempting to start the equipment at its local control
station.Ifthis proves satisfactory,push the stop switch again.
Any gas or chemical lines that enter work locations must be blanked or have the
valve locked in the closed position.The valve must be locked or tagged so it can
easily be identified as a Contractor lockout.It will be the responsibility of the
Contractor,to assure lockout knowledge and compliance from their employees.
b.Flame Permits - A flame permit will be required and must be displayed when
welding or torching anywhere a fire hazard exists.A fire extinguisher and a
pressurized water hose must be ready at the job location during all welding and
torching.A person must be standing by and able to watch for any sparks which
could start a fire.
No welding or cutting will be done within 50 feet offuel storage areas.
c.Confined Space Entry -Whenever work is done that involves entry into tanks,
bins or similar enclosures,a Confines Space Entry Evaluation and Safe Work
Pelmit will be required.
Other Safe Work Permit area include:working on chemical lines,working on any
high pressure system,operating equipment close to electrical lines or any
hazardous operation as detelmined by the Site Safety Coordinator.
Where a hazardous or oxygen deficient atmosphere is possible,special
precautions will be needed in addition the normal safety precautions,such as
lockout,air fans,respirators,safety ropes,etc.Safety precautions may be found
in the Safe Work Procedure,which will be furnished by the Owner's
Representative ifapplicable.
d.Process Lines -Process lines which contain or may have contained hazardous
chemicals or gases can be worked on only with specific approval of the Owner's
Representative.
VIII.MOBILE EQUIPMENT
Equipment will be kept in safe operating condition and be checked frequently.All
equipment must be operated by experienced operators and will be confined to the
work areas or places designated by the Owner's Representative.Dtivers must be
licensed if driving on public roads.Speed limits and traffic rules will be observed.
Owner's equipment has the tight-of-way.Observe caution,yield to traffic control
signs.Speed limits on property shall not exceed 15 mph.
Cranes,power shovels and similar equipment will be directed by a responsible person
on the ground when being moved through congested areas.Special attention must be
paid to overhead wires,piping and other obstructions.(The ten-foot rule must apply)
All suspended loads which are being moved by mobile equipment;i.e.,winch truck,
chelTY picker,etc.,shall be secured with a tagline to prevent it from swinging.
All persons shall ride inside the cab or truck bed;absolutely no one is to ride on the
fenders or running boards.All persons riding in a vehicle shall keep both body and
feet within the protective area of the vehicle frame.
Protruding material that extends (2)feet beyond the rear of the vehicle shall be
flagged.
Operators of gasoline powered vehicles shall stop the engines and place the ignition
in the offposition when refueling.
Drilling equipment must not be operated within (50)feet ofany energized power line.
IX.HEAVY EQUIPMENT
a.All self-propelled equipment shall have adequate overhead protectors (Roll-over
Protective Structures -RaPS)to insure worker protection.
b.All self-propelled equipment (except wheeled tractor scrapers)shall be equipped
with backup alarms and the alarms must function when equipment is in use.A
second person will be responsible to guide tractor scrappers when scrapers are in
reverse.
c.Buckets,lifts or blades shall be left down when equipment is not in use.
d.Dump huck beds shall be in the down seat position while traveling.
e.No person shall place any part of his/her body under a suspended load.Push,
never pull.A suspended load,thereby keeping one's feet and body in the clear.
Whenever possible,use a device to direct the load.
f.After a piece of equipment has been down,the operator shall walk around and
inspect the equipment before moving it.
g.Persons shall not get on or offmoving equipment.
h.Operators of equipment shall not work under overhanging walls until all safety
precautions have been taken and then only after a Safe Work Pelmit has been
issued.
1.Travel speed ofequipment shall be consistent with road conditions.
X.TOOLS AND EQUIPMENT
Tools and equipment will be kept in safe condition with all safety devices and guards
kept operable.Electrical tools will be provided with grounding protections (separate
ground wire,double insulated and or Ground Fault IntelTupter).All portable
electrical lights will be properly guarded.Extension cords hoses;etc.will be kept in
good condition and strung so as not to create a hazard.All electrical devices will be
checked prior to start of work for resistance to ground to insure proper grounding is
provided.
Compressed gas cylinders will be secured in an upright position.Gauged bottles will
be protected and guarded and shut off when unattended.Hoses and leads will be
checked for leaks prior to each use and repaired or replaced iffound defective.
The "quick opening"coupling on compressed air,steam or any other high-pressure
hose must be pinned and whip checked.All bull hose must be securely chained.
XI.EXPLOSIVES AND BLASTING
a.All explosives shall be properly stored per ATF "Table of Distance"as to
distance.The construction of the magazine shall meet the ATF specifications.
b.All magazines shall be licensed.
c.No open flame shall be permitted in or within 100 feet of any explosive magazine.
d.Explosives and detonators (primers)shall not be transported together.When
being transported in the same vehicle,they shall be in different compartments,
with appropriate signs on vehicle (see local regulations).
e.All unused explosives and detonators shall be returned to their proper magazine.
f.All blasts shall be properly guarded.
g.Warning signs shall be used to halt use of two way radios during the loading and
blasting cycle when electrical blasting caps are used.
h.For blasting in open pit works,Owner's Representative shall be notified of each
blast prior to the blast.All blasting plans and guarding procedures shall be
approved by the Owner's Representative.
1.All blasting materials and magazines will be removed by Contractor upon
completion ofjob.
XII.REGULATORY AGENCIES
Code of Federal Regulations specifies that independent contractors will be held
responsible for compliance with all standards.The regulations require that the
independent contractor provide Owner with the following;
a.Contractor's trade name,business address,telephone number,contractor's ID
number for MSHA/OSHA or State and name ofperson in charge ofproject.
b.A description of the work to be performed and the place where it will be
performed.
Contractor must provide Owner with the same infOlmation for each subcontractor
before each subcontractor begins work on Owner's Work Site.
XIII.ACCIDENT REPORTING
All accidents and/or injuries shall be reported to Owner's Representative
immediately.
XIV.TRAFFIC CONTROL
Only those vehicle authorized by the Owner's Representative will be permitted in the
restricted area.All Contractor vehicles,equipment and personnel will be scanned for
radiological release prior to leaving the restricted area.
XV.MONITORING CONTRACTOR'S EMPLOYEES
Owner may perform certain monitoring on Contractor's employees,from time to
time,to asceliain the exposure of such employees to various substances they may
encounter in the course oftheir work under Contractor's contract with Owner.
Owner will select the times,the conditions and the equipment to be used for such
monitoring.Owner will conduct such monitoring using its own personnel,but will do
so solely as an agent for the Contractor,and on the Contractor's behalf.Owner's
monitoring may have for the protection and surveillance of the Contractor's
employees and the performance of such monitoring shall not be deemed a waiver by
the Contractor or as an assumption by Owner ofsuch responsibilities.
XVI.ADDITIONS OR CHANGES TO RULES
Additional area restrictions,rules or procedures not defined in the Special Rules,etc.,
will be provided by Owner's Representative or the department supervisor as
necessary and must be observed.Contractor personnel must immediately contact
Owner's Representative if there is any concerns about potential hazards or proper
methods before proceeding.
XVII.ARCHAEOLOGICAL DETERMINATION
During the course of any work performed by Contractor,if any archaeological
evidence is discovered,i.e.,artifacts or remains,the work must cease immediately
and Contractor must notify the Owner Representative immediately.
By signing this acknowledgement,each Contractor denotes acceptance ofall of the above safety
requirements of this Contract and agreement to abide by all federal,state and local laws and
regulations.
Name:---------------
(Print)
Date:-----------
Contractor:---------------------
Brief Job Description:
Signature:_
APPENDIX I
NRC REG.GUIDE 8.13
Retfisioiil3
June 1999
REGULATORY GUIDE 8.13
(Draft was issued as DG-a014)
A.liNTROl!)fUCTION
The Code ofFederal Regulations in 10 CFR Part
19,"Notices,Instructions and Reports to Workers:In-
spection and Investigations,"in Section 19.12,"In-
structions to Workers,"requires instruction in "the
health protection problems associatedwith exposure to
radiation and/orradioactive material,in precautions or
procedures to minimize exposure,and in the purposes
andfunctions ofprotective devices employed."The in-
structions must be "commensurate with potential ra-
diological health protection problems present in the
work place."
The Nuclear Regulatory Commission's (NRC's)
regulations on radiation protection are specified in 10
CFR Part 20,"Standards for Protection Against Radi-
ation";and 10 CFR 20.1208,"Dose to an Embryo/
Fetus,"requires licensees to "ensure that the dose to an
embryo/fetus during the entire pregnancy,due to occu-
pational exposure ofa declared pregnant woman,does
not exceed 0.5 rem (5 mSv)."Section 20.1208 also re-
quires licensees to "malce efforts to avoid substantial
variation above a uniform monthly exposure rate to a
declared pregnant womiln."A declared pregnant
woman is definedin 10 CFR 20.1003 as a woman who
has voluntarily informed her employer,in writing,of
herpregnancy and the estimated date ofconception.
This regulatory guide is intended to provide infor-
mation topregnantwomen,andotherpersonnel,to help
themmalce decisionsregardingradiation exposuredur-
ing pregnancy.This Regulatory Guide 8.13 supple-
mentsRegulatory Guide8.29,"InstructionConcerning
Risks from Occupational Radiation Exposure"(Ref.
1),which contains a broad discussion ofthe risks from
exposure to ionizing radiation.
Othersections ofthe NRC's regulations also speci-
fy requirements for monitoring external and internal
occupational dose to a declared pregnant woman.Inl0
CPR20.1502,"ConditionsRequiring Individual Mon~
itoringofExternal andInternal OccupationalDose,"li-
censees are required to monitor the occupational dose
to a declared pregnant woman,using an individual
monitoring device,ifit is likely that the declared preg~
nant womanwill receive,from external sources,adeep
dose equivalent in excess of0.1 rem (1 mSv).Accord-
ing to Paragraph (e)of10 CFR 20.2106,"Records of
Individual Monitoring Results,"the licensee must
maintainrecords ofdos~to anembryo/fetus ifmonitor-
ingwasrequired,and therecordsofdose to the embryo/
fetus must be kept with the records of dose to the de-
clared pregnant woman.The declaration ofpregnancy
must be kept on file,but may be maintained separately
from the dose records,The licensee must retain the re-
Th..guide.are inlluod in the following ten broed divisions:
r""uadguidesmayalsob.pUrchasedfromthoNotions!Thchnic:allnfonnatlonServic..on
astandingorderba5ls.DetallaonlhIseelV[camaybeobtalnedbywritingNTIS,5285Port
Royal Road,Springfield,VA221al.
Singlecoplesofregulatoryguidesmaybaobtalned(rooofcI1ergobywriUng to theRep....ductlonand DistributionServicesSection,OCIO,U.S.Nuclear ReguletoryCommission,
Washington,DC 20555-0001;or by fax to (301)41!>-2289;or by a-mall to DISTRIBU-
[e-mail]
USNRC REGULATORYGUIDES
RegulatoryGuldesarelll.eUed todescribeand make "vall.bletothepublicsuchInforma--Uon at>methodsacceptableto theNRClltaffforImplementingspecificparts oftheCcm·miStlion'sregul.Uons,technlquosusedbythoat.ffInevaluatingspeeifIcproblema orpos-
tulsted 'lceidenls,Mddataneeded bythaNRCslaff[nlisreviewof applications forper·
mit.and Ilcenses.RegulateI}'guideserenot aubstilUtasforregulalions,endcompllanca
withthemIsnotrequired.MethodsMd""luiIonsdifferentfromtMaasstOUlIn the guld••
v~1Ibeacceptabk>H!heyprovldaII baal.for thefll1dlng.r.quiellet"th9 I~uanc..orcan-
tinuanceof"permitorlIoe/139 by the Comml~lon.
Thisguidewas issued after con:;iderati"n ofcommantsrecaived fromthe pUblic.Com-mentsendsugg<lStlon.forlmprovemantsIntheseguidesllI'tlencouragodatall Umes,and
guIdeswill beravlsad,asapproprillte,toIlccommodato commontsand torefiactnawln·
formaUon orexparienco.
Written commont.may be submitted to tho Aulas end Directives Br.mch.ADM,U.S,
NuclearAegulatoty Commission,Wa:lhlnglon,DC 2055!>-0001.
I.Pow.rReactors
2.Research onel TestReaclorn
3.Fuelsand MatarieJsFacilities
4.Environmental endSlUng
5.Materials endPlontProtection
6.Products
1.Transportation
8.Occupational Health
9.Antitrustond Financial Review
II).General
quired fOlT.!l or record until the Commission terminates
each pertinent license requiring the record.
The information collections in this regulatory
guide are covered by the requirements of10CPR Parts
19 or 20,which were approved by the Office ofMan-
agementand Budget,approvalnumbers 3150-00tlA and
3150-0014,respectively.TheNRCmay notconductor
sponsor,and a person is not required to respond to,a
collection ofinformation unless it displays a cun-ently
valid OMB control number.
B.ll)][SCUSSION
As discussed in Regulatory Guide 8.29 (Ref.1),
exposure to any level of radiation is assumed to carry
with it a certain amount oflisk.Inthe absenceofscien-
tific celtainty regarding the relationship between low
dose exposure and health effects,and as a conservative
assumption for radiation protection purposes,the
scientific communitygenerally assumes that any expo-
sure to ionizing radiation may cause undesirable bio-
logicaleffects andthatthelikelihoodoftheseeffects in-
creases as the dose increases.At the occupational dose
limitfor the whole body of5 rem (50 mSv)peryear,the
risk is believed to be very low.
The magnitude ofrisk ofchildhood cancerfollow-
ingin utero exposure is uncertain in that bothnegative
and positive studies have been reported.Thedatafrom
these studies "are consistentwith a lifetime cancer risk
resulting from exposure during gestation which is two
to three times that for the adult"(NCRP Report No.
116,Ref.2).The NRC has reviewed the available
scientific literature and has concluded that the 0.5 rem
(5 mSv)limitspecified in 10CFR 20.1208 provides an
adequate margin of protection for the embryo/fetus.
This dose limit reflects the desire to limit the total life-
time risk ofleukemia and othercancers associatedwith
radiation exposure during pregnancy.
Inorderfor apregnant worker to talce advantage of
the lower exposure limit and dose monitoring provi-
sions specified in 10 CFR Part20,thewomanmust de-
clare her pregnancy in writing to the licensee.A form
letter for declaring pregnancy is provided in this guide
orthe licenseemay use itsownform letterfor declaring
pregnancy.A separate written declaration should be
submitted for each pregnancy.
C.REGULATORY POSITION
1.Who Should Receive Instruction
Female workers who require training under 10
CFR 19.12 should be provided with the information
contained in this guide.In addition to the information
containedinRef,/IIlatory Guide 8.29 (Ref.1),thisinfor-
mationmay be included as part ofthe trainingrequired
under 10 CPR 19.12.
2.Providing InstmctR01ill
The occupational worker may be given a copy of
this guide with its Appendix,an explanationofthe con-
tents ofthe guide,and an opportunity to ask questions
and request additional information.The information in
this guide and Appendixshould also beprovided to any
workerorsupervisor whomay be affectedby adeclara-
tion ofpregnancy orwhomay have to talce some action
in response to such a declaration.
Classroom instructionmay supplement the written
information.Ifthe licensee provides classroom instruc-
tion,the instructorshould have some knowledge ofthe
biological effects ofradiation tobe able to answerques-
tions that may go beyond the information provided in
this guide.Videotaped presentations may be used for
classroom instruction.Regardless of whether the li-
censeeprovidesclassroom training,the licenseeshould
give workers the opportunity to askquestions aboutin-
formation containedin this Regulatory Guide8.13.The
licensee may take credit for instruction that the worker
has receivedwithin the pastyeatat otherlicensed facili-
ties or in other courses ortraining.
3.Licensee's Policy on Declared PregnantWomen
The instruction provided should describe the li-
censee's specific policy on declared pregnant women,
including how those policies may affect a woman's
work situation.In particular,the instructionshouldin-
clude a description ofthe licensee's policies,ifany,that
may affect the declared pregnant woman's worksitua-
tion after shehas filed a written declaration ofpregnan-
cy consistent with 10 CFR 20.1208.
Theinstructionshouldalsoidentify who to contact
for additional information as well as identify who
should receive the written declaration of pregnancy.
Therecipient ofthewoman'sdeclarationmaybeidenti-
fied byname(e.g.,JohnSmith),position(e.g.,immedi-
ate supervisor,the radiation safety officer),or depart-
ment (e.g.,the personnel department).
4.Duration ofLower Dose Limits for the Embryo/
Fetus
The lower dose limit for the embryo/fetus should
remain in effect until the woman withdraws the
declaration in writing orthe woman is no longerpreg-
nant.If a declaration ofpregnancy is withdrawn,the
dose limit for theembryo/fetus would apply only tothe
time from the estimated.date of conception until the
time the declaration is withdrawn.Ifthe declaration is
8.13-2
not withdrawn,the written declaration may be consid-
ered expired one year after SUblIllssion.
5.§llAb5U:8lIfJl9Jiaft Vm:R2tnOJilS Above 2l Undfoft'm Month·
Iy Dose lP'~~
According to 10 CPR 20.1208(b),"The licensee
shall make efforts to avoidsubstantial variation above a
uniform monthly exposure rate to a declared pregnant
woman so as to satisfy the limit inparagraph (a)ofthis
section,"that is,0.5 rem (5 mSv)to the embryo/fetus.
The National Council on Radiation Protection and
Measurements (NCRP)recommends a monthly equiv-
alent dose limit of0.05 rem (0.5 mSv)to the embryo/
fetus once the pregnancy is known (Ref.2).In view of
the NCRP recommendation,any monthly dose of less
than 0.1 rem (1 mSv)may be considered as not a sub-
stantial variation above a uniform monthly dose rate
and as such will not require licensee justification.How-
ever,a monthly dose greater than 0.1 rem (1 mSv)
should be justified by the licensee.
8.13-3
The purpose ofthis section is to provide infOlma-
tion to licensees and applicants regarding the NRC
staff's plans for using this regulatory guide.
Unless a licensee or an applicant proposes an ac-
ceptable alternative method for complying with the
specified portions ofthe NRC's regulations,the meth-
ods described in this guide will be used by the NRC
staffinthe evaluation ofinstructions to workers on the
radiation exposure of pregnant women.
REFERENCJES
1.USNRC,"InstmctionConcerning Risks from Oc-
cupational Radiation Exposure,"Regulatory
Guide 8.29,Revision 1,February 1996.
2.National Council on Radiation Protection and
Measurements,Limitation ofExposure to Ioniz-
ingRadiation,NCRP Report No.116,Bethesda,
MD,1993.
J!..Why 21m Kn'eceftviIDlg t!lJlHS Rllilfm"matnol1l?
The NRC's regulations (in 10CFR19.12,"Instruc-
tions to Workers")require that licensees instruct indi-
viduals working with licensed radioactive materials in
radiation protection as appropliate for the situation.
The instruction below describes infonnation that occu-
pational workers and their supervisors should know
about the radiation exposure of the embryo/fetus of
pregnant women.
The regulations allow a pregnant woman to decide
whethershe wants to formally declare her pregnancy to
take advantage of lower dose limits for the embryo/
fetus.This instruction provides information to help
women make an informed decision whether to declare a.pregnancy.
2.IfI become pregnant,am !required to declare
my I!lregnancy?
No.The choice whether to declare yourpregnancy
is completely voluntary.Ifyou choose to declare your
pregnancy,you must do so in writing and alower radi-
ation dose limitwill apply to your embryo/fetus.Ifyou
choose not to declare your pregnancy,you and your
embryo/fetus will continue to be subject to the same
radiation dose limits that apply to other occupational
workers.
3.If I declare my pregnancy in writing,what
happens?
Ifyou choose to declare your pregnancy in writing,
the licensee must take measures to limit the dose to
yourembryo/fetus to 0.5 rem (5 millisievert)during the
entire pregnancy.This is one-tenth ofthe dose that an
occupational worker may receive in ayear.Ifyou have
already received a dose exceeding 0.5 rem (5 mSv)in
the period between conception and the declaration of
your pregnancy,an additional dose of 0.05 rem (0.5
mSv)is allowed during the remainderofthe pregnancy.
In addition,10 CFR 20.1208,"Dose to an Embryo/
Fetus,"requires licensees to make efforts to avoid sub-
stantial variation above a UnifOlID monthly dose rate so
that all the 0.5 rem (5 mSv)allowed dose does notOCcur
in a short period during the pregnancy.
Thismay mean that,ifyou declare yourpregnancy,
the licensee may not permit you to do some ofyournor-
mal job functions if those functions would have al-
lowed you to receive more than 0.5 rem,and you may
110t be able to have some emergency response
responsibilities.
4.Why do the rtegulatioHls have 11 lower dose limit
[or the embryo/fetus of a dedali."ed pregnant
woman than for 11 pregnant wod.:eJi·who has not
declared?
A lower dose limit for the embryo/fetus of a de-
clared pregnant woman is based on a consideration of
greater sensitivity to radiation ofthe embryo/fetus and
the involuntary nature oftheexposure.Severalscientif-
ic advisory groups have recommended (References 1
and 2)that the dose to the embryo/fetus be limited to a
fraction of the occupational dose limit.
S.Whatare ~hepotentially harmful effectsofradi-
ation e1qJOSUre to my embryo/fetus?
The occurrence and 'severity of health effects
caused by ionizing radiation are dependent upon the
type and total dose ofradiation received,as well as the
time period overwhich the exposure was received.See
Regulatory Guide 8.29,"Instmction Concerning Risks
from Occupational Exposure"(Ref.3),for more infor-
mation.The main concern is embryo/fetal susceptibil-
ity to the hannful effects ofradiation such as cancer.
6.Are there any rislG ofgenetic defects?
Althoughradiationinjury has been induced experi-
mentally in rodents and insects,and in the experiments
.was transmitted and became manifest as hereditary dis-
orders in their offspring,radiation has not been identi-
fied as a cause ofsuch effect in humans.Therefore,the
risk ofgenetic effects attributable to radiationexposure
is speculative.For example,no genetic effects have
been documented in any of the Japanese atomic bomb
survivors,their children,or their grandchildren.
7.Whatif][decide that I do not wantanyradiation
exposure ataU dming my pregnancy'?
You may ask your employer for a job that does not
involve any exposure at all to occupational radiation
dose,but your employeris notobligated to provideyou
with ajob involving no radiation exposure.Even ifyou
receive no occupational exposure at all,your embryo/
fetus will receive some radiation dose (on average 75
mrem (0.75 mSv»during your pregnancy from natural
background radiation.
The NRC has reviewed the available scientificlit-
era~e and concluded that the 0.5 fem (5 mSv)limit
8.13-4
provides an adequate margin of protection for the
embryo/fetus.This dose limitreflects the desire to lim-
it the total lifetime risk ofleukemia and other cancers.
Ifthis dose limit is exceeded,the total lifetime risk of
cancer to the embryo/fetus may increase incrementally.
However,the decision on what level oflisle to accept is
yours.More detailed information on potential risk to
the embryo/ferns from radiation exposure can be found
in References 2-10.
8.Whateffectwm fOl'mally dedall'ing my Ill11Jegmm.-
cy have on my job stams?
Only the licensee can tell you what effect awritten
declaration ofpregnancy will have on your job starns.
As part of your radiation safety training,the licensee
should tell you the company's policies with respect to
thejobstatus ofdeclared pregnant women.In addition,
before you declare your pregnancy,you may want to
talk to your supervisor or your radiation safety officer
and ask what a declaration of pregnancy would mean
specifically for you and your job status.
In many cases you can continue inyour presentjob
with no change and still meet the dose limit for the
embryo/fetus.For example,most commercial power
reactor workers (approximately 93%)receive,in 12
months,occupational radiation doses that are less than
0.5 rem (5 mSv)(Ref.11).The licensee may also con-
sider the likelihOod of increased radiation exposures
from accidents and abnormal events before malting a
decision to allow you to continue in your present job.
Ifyour current work might cause the dose to your
embryo/fetus to exceed 0.5 rem (5 mSv),the licensee
has various options.Itis possible that the licensee can
and will make areasonable accommodation that will al-
low you to continue performing your current job,for
example,by having another qualified employee do a
small partofthe jobthat accounts for some ofyourradi-
ation exposure.
9.What information must I provide in my written
dedaration of pregnancy?
You should provide,in writing,your name,adecla-
ration that you are pregnant,the estimated date of
conception (only the month and year need be given),
and the date that you give the letter to the licensee.A
form letter that you can use is included at the end of
these questions and answers,You may use that letter,
use a form letter the licensee has provided to you,or
write your own letter.
1l((}.10rrlledarre my fiJrregllilallil~:V~<do ]I Hn~ve ~o Hnave do:c-
mjfften~ed mediicaD iimof Haa~Kam Hla'egnlllllilf?
NRC regulations do not require that you provide
medical proofofyourpregnancy.However,NRC regu-
lations do not preclude the licensee from requesting
medical documentation of your pregnancy,especially
ifa change in your duties is necessary in order to com-
ply with the 0.5 rem (5 mSv)dose limit.
n.Can Jr teJi theiicensee orally rathertlum inwftHi·
iog that H:am pregnant?
No,The regulations require that the declaration
must be in writing.
12.Inhave notdedall'ed my IllregmUllcy in writing,
but the licensee suspects that I am pregnant,do
the Howell'dose limits apply?
No.The lower dose limits for pregnant women ap-
ply only ifyou have declared your pregnancy in writ-
ing.The United States Supreme Court has ruled (in
United Automobile Workers International Union v.
Johnson Controls,Inc"1991)that ''Decisions abolltthe
welfare of future children must be left to the parents
who conceive,bear,support,and raise them rather than
to the employers who hire those parents"(Reference 7).
The Supreme Court also ruled that your employer may
not restrict you from aspecificjob"because ofconcerns
about the next generation,"Thus,the lower limits ap-·
ply only if you choose to declare your pregnancy in
writing.
13.If!amplanning to becomepregnantbutamnot
yetpregnant and I inform the licensee ofthatin
writing,do the lower dose limits apply?
No.The requirement for lower limits applies only
ifyou declare in writingthat you are already pregnant.
14.What ifI have a miscarriage or find out thatI
am notpregnant?
If you have declared your pregnancy in writing~
you should promptlyinfOlm the licensee in writing that
you are no longer pregnant.However,if you have not
formally declared your pregnancy in writing,you need
not inform the licensee ofyour nonpregnant status.
15.How long is the lowel'dose limit in effect?
The dose to the embryo/fetus must be limited until
you withdraw your declaration inwritingor you infOlm
the licensee in writing that you are no longer pregnant.
Ifthe declaration isnotwithdrawn,the written decla-
ration may be considet;ed expired one year after
submission.
8.13-5
',,;;"
1l.~.UK linave lfllecHau-etil my Il}Jn,gffilaffilcy iHll wU'HiHllg?<c.m
1I [<evol~e lmy lfll<2dara~ioHll of ll:magffil21Hllcy eveHll if K
am stnn pi'll!gllilali1~?
Yes,you may.The choice is entirely yours.Ifyou
revoke your declaration ofpregnancy,the lower dose
limit for the embryo/fetus no longer applies.
17.What if K'Work undeR'contrad at a Aicellilsed
facility?
The regulations state that you should formally de-
clare your pregnancy to thelicensee in writing.The li-
censee has the responsibility to limit the dose to the
embryo/fetus.
18.Where can I get additionau information?
Thereferences to this Appendix containhelpfulin-
formation,especially Reference 3,NRC's Regulatory
Guide 8.29,"InstructionConcerningRisks from Occu-
pational Radiation Exposure,"for general information
on radiation ris1<s.The licensee should be able to give
tlus document to you.
Forinformation on legal aspects,see Reference 7,
"TheRock and the Hard Place:Employer Liability to
Fertile or Pregnant Employees and Their Unborn Chil-
dren-\VhatCanthe EmployerDo?"which is an article
in the journal Radiation Protection Management.
You may telephonethe NRCHeadquarters at (301)
415-7000.Legal questions should be directed to the
Office ofthe General Counsel,and technical questions
should be directed to the Division of Industrial and
Medical NuclearSafety.
You may also telephone the NRCRegional Offices
at the following numbers:Region I,(610)337~5000;
RegionII,[phone];RegionIII,[phone];
and Region IV,[phone].Legal questions should
be directed to the Regional Counsel,and technical
questions should be directed to the Division ofNuclear
Materials Safety.
8.13-6
1.National Council on Radiation Protection and
Measurements,Limitation ofExposure to Ioniz-
ing Radiation,NCRP Report No.116,Bethesda,
MD,1993.
2.International Commission on Radiological
Protection,1990 Recommendations ofthe Inter-
national Commission on Radiological Protec-
tion,ICRP Publication 60,Ann.ICRP 21:No.
1-3,Pergamon Press,Oxford,UK,1991.
3.USNRC,"Illstmction Concerning Risks from
Occupational Radiation Exposure,"Regulatory
Guide 8.29,Revision 1,February 1996.1 (Elec-
tronically available at www.nrc.gov/NRC/RG/
index.html)
4.Committee on the Biological Effects of Ionizing
Radiations,National Research Council,Health
Effects ofExposure to Low Levels of Ionizing
Radiation (BEIR V),National Academy Press,
WasWngton,DC,1990.
5.United Nations Scientific Committee on the Ef-
fects ofAtomic Radiation,Sources andEffects of
Ionizing Radiation,United Nations,New York,
1993.
tSingle copies of regulatory guides,both active and draft,and draft
NUREG documentsmay be obtained free ofcharge by writing the
Reproduction and Distribution Services Section,OCIO,USNRC,
Washington,DC 20555-0001,or by fax to [phone],or by
emailto <[e-mail]>.Activeguidesmayalso
be purchased from the National Technical Information Service on a
standingorderbasis.Detailson thisservicemaybeobtained bywrit.
ing NTIS,5285 Port Royal Road,Springfield,VA 22161.Copiesof
active and draftguides areavailableforinspectionorcopyingforafee
from theNRC Public Document Room at2120LStreet Nw.,Wash-
ington,DC;the PDR'smailing address is MailStop LL-6,Washing-
ton.DC 20555:telephone [phone]:fax [phone].
6.R.Doll and R.Wakeford,"Risk of Childhood
Cancerfrom Fetal 111"adiation,"The BritishJour-
nat ofRadiology,70,130-139,1997.
7.David Wiedis,Donald E.Jose,and Timm O.
Phoebe,"The Rock and the Hard Place:Employ-
erLiability to Fertile orPregnant Employees and
Their Unborn CWldren-What CantheEmployer
Do?"Radiation Protection Management,11,
41-49,JanuarylFebruary 1994.
8.National Council on Radiation Protection and
Measurements,Considerations Regarding the
Unintended Radiation Exposure ofthe Embryo,
Fetus,orNursingChild,NCRP CommentaryNo.
9,Bethesda,MD,1994.
9.National Counci~on Radiation Protection and
Measurements,Risk Estimates for Radiation
Protection,NCRP Report No.115,Bethesda,
MD,1993.
10.National Radiological Protection Board,Advice
on Exposure to Ionising Radiation During Preg-
nancy,National Radiological Protection Board,
CWIton,Didcot,UK,1998.
11.M.L.Thomas and D.Hagemeyer,"Occupational
Radiation Exposure at Commercial NuclearPow-
er Reactors and Other Facilities,1996,"1\venty-
Ninth Annual Report,NUREG-0713,Vol.18,
USNRC,1998.2
2Copies are available at current rates from the U.S.Government
PrintingOffice,P.O.Box37082,Washington,DC20402-932&(tele.
phone [phone]&00);orfrom theNational Technical Information
Service by writing NTIS at 5285 Port Royal Road,Springfield,VA
22161.Copies are available for inspection orcopying for a feefrom
theNRCPublicDocumentRoom at2120LStreetNw.,Washington,
DC;the PDR's mailing address is Mail Stop LL·6,Washington,DC
20555;telephone [phone];fax [phone].
8.13-7
A separate regulatory analysis was not prepared for tIus regulatory
guide.A regulatory analysis prepared for 10 CFR Part 20,"Standards for
Protection Against Radiation"(56 FR 23360),providesthe regulatory ba-
sis for tbis guide and examines the costs and benefits ofthe rule as imple-
mented by the guide.A copy ofthe "Regulatory Analysis for the Revision
of10 CFR Part 20"(pNL-6712,November 1988)is available for inspec-
tion and copying for a fee at the NRC Public Document Room,2120 L
Street NW,Washington,DC,as an enclosure to Part 20 (56 FR 23360).
8.13-9
APPENDIXJ
PRE-NATAL FORM
45
On this date,I was advised by my employer,Denison Mines (USA)Corp.ofthe White
Mesa Mill,Utah,ofthe possible risks associated with prenatal radiation exposure and of
the precautions that I should I become pregnant and continue to work.I was also advised
ofthe alternatives that I might consider in this regard.
I discussed this subject with my employer and understand the possible risks to children of
women who are exposed to radiation during pregnancy and the alternatives that I might
consider as explained bymy employer as contained in the appendix to Regulatory Guide
8.13 from the United States Nuclear Regulatory Commission,a copy ofwhich was given
to me for reference.
Employee
Employer Representative
Hire Date:-------
SSN:---------
Employee Number:_
Date
Date
;
"
This fomlletteris provided for your convenience.To make your written declaration ofpregnancy,you may
fiU in the blanks in this form letter,you may use afonn letter the licensee has provided to you,or you may write
your own letter.
DECLARATION OF PREGNANCY
To:_
In accordance with the NRC's regulations at 10CPR 20.1208,"Dose to an Embryo!Fetus,"I am declaring
that I am pregnant.I believe I became pregnant in (only the month and year need be
provided).
I understand the radiation dose to my embryo/fetus during my entire pregnancy will not be allowed to ex-
ceed 0.5 rem (5 millisievert)(unless that dose has already been exceeded between the time of conception and
submitting this letter).I also understand that meeting the lower dose limit may require a change in job orjob
responsibilities during my pregnancy.
(Your signature)
(your name printed)
(Date)
8.13-8