DRC-2009-001285 - 0901a06880112f2a

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DENISOr^i
MINES
February 12, 2009
Mr, Dane Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P,0, Box 144810
Salt Lake City, UT 84114-4810
Deniaon MIms (USA) Corjk
105017th Street Suite 990
Denver, CO 8026S
USA
Tel:303e28-7798
Fax: [phone]
vinww.denisoninine9.com
Dear Mr. Finerfrock:
Re: interrogatory. Renewal Application for Radioactive Materials License. (RML) No.UT1900479
Enclosed please find an electronic version of the above referenced material.
Please contact me at [phone] with any questions.
Yours very truly,
DENISON MiNks (USA) CORP.
D^\Xd C, Frydenlund
Vice President, Regulatory Affairs and Counsel
No. PBL-19
Rev. No.:R-O
Date: June 19,2008
1.0 Purpose
I DENISON MINES (USA) CORP.
I STANDARD OPERATING PROCEDURES
I,Title:Containerized Alternate Feedstock
Material Storaae Procedure
Page 1 of3
The purpose of this procedure is to assure that storage offeedstock material is conducted
in a manner so as to preclude the release ofMill feed material to the environment.
2.0 Scope
Feed materials delivered to the White Mesa Mill must be stored in a manner which
precludes the release of the materials to the environment. In the case of bulk materials,
such as unrefined natural ores and altemate feeds delivered in inter-modal containers,
these materials are offloaded from the truck or shipping container directly onto the
approved ore pad where migration of material is precluded by the pad's design and
operating procedures (i.e. low permeability pad material, dust control procedures and
limited stockpile height).However,certain feeds are received in drums or other
containers which serve to effectively contain the material during storage and, as such, are
amenable for storage either on the ore pad or at locations other than the ore pad.It is the
intent of this procedure to describe the environmental safety precautions utilized for
contained feed storage.
3.0 Procedure
3.1 Contained Feed Material Inspections
All contained feed materials received at the White Mesa Mill are inspected upon
arrival to determine that the containers are not leaking and to assure container
integrity prior to placing the material into storage. Each container will be
observed on all sides for damage or leakage ofcontents. All containers exhibiting
signs of leakage will be re-packed or placed in over-pack containers prior to
placing the materials into storage. Dented drums are acceptable ifthe dent is not
located near a seam or when the dent is not accompanied by a damage crease on
the drum surface.Drums damaged by dents near the seam, crease damaged
drums or containers that have been otherwise compromised during shipment are
re-packed or placed in over-pack containers prior to storage. Containers which
are not damaged at the time ofreceipt are transferred directly for placement at the
storage location.
3.2 Storage Locations
3.1.1 Defined Feedstock Storage
Feedstock materials stored at the defined storage location indicated on the map
attached hereto as Attachment A (the "Defined Feedstock Area") can be stored in
containers or in bulk form and are subject to the routine inspections described by
INo.PBL-19
I
i Rev. No.:R-O
Date: June 19, 2008
DENISON MINES (USA)CORP.
STANDARD OPERATING PROCEDURES Page 2 of3
Title:Containerized Alternate Feedstock
Material Storaze Procedure
the White Mesa Mill Tailings Management System Discharge Minimization
Technology (DMT)Monitoring Plan at Section 3.3. a)(the White Mesa Mill
Tailings Management System Discharge Minimization Technology (DMT)
Monitoring Plan is reproduced as Section 3.1 ofthe Mill's Environmental
Protection Manual).
3.1.2 Storage of Contained Feeds in Locations OtherThan the Defined
Feedstock Area
a)Over-pack Containers
Materials received or transferred into over-pack containers can be stored at
locations other than the Defined Feedstock Area absent a hardened ground surface
or containment berms due to the fact that the over-pack container provides a
secondary containment for the packaged material.Over-pack materials are
subject to the routine inspections described by the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT)Monitoring
Plan at Section 3.3. a).
b)Hardened Surface Storage Locations
Contained feed materials,including materials in containers which have not been
provided with over-pack protection,can be stored at locations other than the
Defined Feedstock Area when a hardened ground surface storage location is used
and has been provided with containment berms.These materials are subject to the
routine inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT)Monitoring Plan at Section
3.3. a).
c)Single Lined Containers Stored Outside the Defined Feedstock Area
Where Hardened Surfaces and Containment Berms Are Not Utilized
Contained feeds can also be stored at locations,other than the Defined Feedstock
Area, that have been selected to avoid impact by site drainage and/or pooling.
Prior to storage at these locations,planks or pallets are placed beneath the drum
storage locations in order to raise the container from the ground surface and avoid
corrosion from water which may accumulate during precipitation events (despite
site selection)and from rusting due to soil moisture when drums are stored
directly on the ground.These contained materials are subject to the more
particular storage protocols and inspections outlined below.
2
No. PBL-19
Rev. No.: R-O
Date: June 19,2008
STA~~~~~O~p~~~~~~S:ri~g:6tJRES 1-~a~e-3-0-f-;--'-
Title:Containerized Alternate Feedstock
Material Stora e Procedure____-'---=:.:c.:.::.::..:::..::::::....:c...::c.::...::..:.:..l:!.::-=-=...::...::..::..::::..::::.::....:=--__
3.3 Storage Protocol Single Lined Containers
In accordance with MSHA requirements,container storage must be implemented
in such a manner as to limit the potential for a container to tip or fall onto a
worker.For drummed materials,the agency limits such stacks to three drums in
height due to stability considerations.In keeping with these concerns,Denison
will configure single lined storage drums (stored off the Designated Feedstock
Area) in rows no more than two containers wide at the base and may place a one-
container row either on top of a single row or in the middle of a lower two-
container row, in each case so as to straddle the tops of drums in the lower
container row(s).This stacking configuration distributes the single upper row
across the bottom row(s)of containers in such a manner as to hold the bottom
row(s)from leaning and allowing for limited stacking on top of these lower
row(s).Accordingly,when stacking is necessary,this configuration minimizes
the risk of falling drums,limits stacking height for safety reasons and allows for a
thorough inspection of each of the individual containers from the outside of the
container row(s).
3.4 Single-lined Container Storage Area Inspections
The single-lined container storage area(s)that are offofthe Designated Feedstock
Area will be inspected on a weekly basis (and after significant precipitation
events)on both sides of any row in order to assure that the stored materials
remain intact,that standing water has not accumulated and that materials are not
leaking or migrating from the storage area.
3.5 Single-lined Container Storage Inspection Records
Denison will record all instances where single-lined containers are received
damaged (or leaking)and require re-packing or the provision of an over-pack
container.This information will be recorded on a container receipt form (see
Attachment B)which documents the receipt of drummed materials to be stored in
locations other than the Defined Feedstock Area.Similarly,each weekly
inspection shall be recorded on the inspection form referred to in the White Mesa
Mill Tailings Management System Discharge Minimization Technology (DMT)
Monitoring Plan at Appendix A and attached as Attachment C to this Procedure.
Such inspections require the documentation of container condition,the drainage
conditions in the storage location,the presence of leakage,if any, and any
corrective actions taken due to leakage of containers or standing water at the
storage location.
3
Attachment A
02J20101 8M
Denison Mines (USA)Corp.
Feedstock Storage Area Map
REVISIONS Counl)l:tale:liT
ocation:Dots B
Project WHITE MESA MILL
Attachment B
Containerized Alternate Feed Receipt
Inspection
Date:------------
Inspector:____
Number ofcontainers/drums in shipment:_
Radiation Activity Levels:------------
Location ofStorage:_
Observations (note dented or damaged drums):
Corrective Action Taken for Damaged Drums:
Inspector Signature
Attachment C
White Mesa Mill-Standard Operating Procedures
Book 11:Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
2/07 Revision: DUSA-3
Page 25 of25
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date ofInspection:_
Inspector:_
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no:_
comments:_
Are all altemate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes:no:._
comments (e.g.,conditions of containers):_
Conditions ofstorage areas for materials:
Other comments:
Scope
White Mesa Mill
Work Practice Standards for Control of Fugitive Dust
Ore Receipt and Front-end Loader Operations 8
The standards adopted by this procedure pertain to the control of fugitive dust during ore truck
off-loading activities at the ore storage pad and to ore pad operations during ore transfer and
storage.
Purpose
The purpose of this Work Practice Standard is to implement appropriate control measures and
monitoring of fugitive dust at the ore storage location.are to be processed at the White Mesa
Mill is received by truck from various mining operations where the moisture content has been
historically sufficient to control dusting during off-loading operations.On average, received ore
shipments retain approximately 4%moisture content and do not generate dust in excess of 15%
during off-loading operations.More specifically,observations of opacity during off-loading
have not been in excess of the standard and are typically less than 5%. However, while in
storage at the ore pad, and during front-end loader operations when the ore is being transferred
for processing,dusting is possible and is controlled by means of these procedures.
Ore Receipt Work Practices
Ore is received on a daily basis from various mines delivering to the Mill. At the beginning of
each day shift a trained opacity observer will monitor dust conditions during ore receipt to verify
that sufficient moisture is contained in the ore and that dusting in excess of the Approval Order
(DAQE-ANOI12050008-08)limit of 15% is appropriately controlled.While moisture content of
each shipment is eventually determined for processing purposes,representative data are not
immediately obtainable for each load prior to off-loading.Accordingly,dust controls must be
implemented on the basis of observed conditions.As such,opacity readings will be recorded in
a log book which will be retained onsite for review by the UDEQ Division ofAir Quality.Ifit is
observed that opacity is in excess of 10%during off-loading operations,the trained observer will
notify operations personnel and corrective actions will be determined and implemented by Mill
management (given the circumstances at the time) in order to reduce dust to below the 10%
threshold.
Ore Handling Work Practices
In conjunction with the daily observation of ore off-loading operations,the ore pad area will be
subject to monitoring ofopacity from stored ore and front-end loader operations.Accordingly, a
trained observer will monitor and record opacity readings on a daily basis at the ore pad in order
to assure that dusting in excess of the 15%opacity limit established by the Approval Order
(DAQE-ANOl12050008-08)is not exceeded. Daily opacity readings will be recorded in a log
book which will be retained onsite for review by the UDEQ Division of Air Quality.If it is
observed that dusting is in excess of 10%during ore handling activity, the trained observer will
notify operations personnel and ore handling operations will be slowed to control dust. In
addition to these controls, and as a general dust control measure,water spray is applied on an as
needed basis in the ore handling area (based upon the observations of the trained observer)in
order to control dust resulting from activity at the ore pad location.
No.:PBL-9 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.: R-O STANDARD OPERATING PROCEDURES Page 1 of6
Date:Oct 4,2002 Title: End Dump TrailerAcceptance,Handling &Release
1.0 Purpose
The following procedure applies to acceptance, handling, and release of end dump trailers
at the White Mesa Mill (the "Mill").International Uranium (USA)Corporation
("IUSA")receives material for processing,in either bulk or non-bulk packaging. This
procedure addresses one form of bulk packaging -end dump trailers. This procedure
may be amended, subject to approval by IUSA's Safety and Environmental Review Panel
(SERP), from time to time as appropriate to address the individual requirements of
specific feed materials, or projects.
2.0 Ore Receiving
1. Check truck scale for zero balance at the beginning ofeach shift.
2. When each truck driver enters the Restricted Area for the first time, the Scale
house operator will provide hazard training for the driver. The driver will be
provided with the Safety Training Form (copy attached). All drivers will be
required to read the Safety Training Form and sign and date the Safety Training
Form indicating that they understand and agree to foll~w IUSA's safety rules and
procedures while on company property. The Scale house operator will sign the
Safety Training Form as the instructor for IUSA.Completed Safety Training
Forms will be turned in to the Safety Department for future reference.
3.Inspect all copies of the Bill of Lading (BOL) to ensure that the shipment is
destined for the Mill and that all shipping documentation is in order (see Section
8.2).If any discrepancies are noted notify the Mill management
immediately. Do not empty the end dump trailer until all paperwork
discrepancies are corrected.
4.Assign next available shipment number and Mill load number to the inbound
shipment. Record the Mill load number, inbound date and both the truck and end
dump trailer numbers on the Scale house Weight Ticket (SWT).
5. Enter the loaded weight ofthe end dump truck and trailer on the SWT.
3.0 Ore Unloading
1.After weighing the truck and trailer, direct the driver to the specified ore storage
pad area where the material will be unloaded. Prior to unloading the tarp is
inspected for damage and then removed,if necessary. The driver is then directed
to unload the material,ensuring all personnel are clear of the trailer and the
immediate area.
(!
I
2.After unloading the material replace the tarp,unless the trailer IS being
decontaminated for unrestricted release.
P:\Admin\Master SOPs\Book 10]BL Sops\PBL-9\PBL-9End Dump SOP Rev 0 (lO.04.02).doc
No.:PBL-9 INTERNATIONAL URANIUM (USA)CORPORATION
Rev.No.:R-O STANDARD OPERATING PROCEDURES Page 2 of6
Date:Oct 4,2002 Title: End Dump TrailerAcceptance,Handling &Release
3. After the tarp has been replaced on the trailer, direct the driver back to the scales
for an empty weight.
4. Record the empty weight on the appropriate SWT.
5. Use a front-end loader or similar equipment to push material into the designated
ore lot pile.
4.0 Decontamination and Release ofEnd Dump Trailers and Trucks
All end dump trailers and trucks will be decontaminated after unloading prior to
leaving the Mill. Generators or transporters will notify IUSA whether a specific trailer is
to be released for restricted or unrestricted use. Any trailers that are to be released for
restricted use will be decontaminated according to the requirements contained in U.S.
Department of Transportation (DOT)Part 49 CFR 173.441(b) and 173.443 (copies
attached).Any trailers that are to be released for unrestricted use will be decontaminated
according to the requirements found in Table 1 ofthe Nuclear Regulatory Commission's
(NRC's)Policy and Guidance Directive FC-85-23,"Guidelines for Decontamination of
Facilities and Equipment Prior to Release for Unrestricted Use or Termination of
Licenses for Byproduct, Source, or Special Nuclear Material"issued May 1987 (copy
attached).Trailers requiring repair will be decontaminated for unrestricted release, to
facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired
without undergoing full decontamination if repaired within the Restricted Area of the
Mill.
5.0 Decontamination and Release ofEquipment for Restricted Use
1.After the tarp has been replaced on the trailer 'and the empty weight obtained, the
driver will be directed to the decontamination pad.
2.Decontaminate the exterior of each trailer, truck and tires thoroughly,using a
high-pressure water wash.
3.After the truck and trailer are decontaminated,the driver will be directed to the
gate, along the decontamination route. The decontamination route is a graveled
roadway specifically designed for decontaminated equipment to exit the
Restricted Area.If it becomes necessary due to environmental conditions or
residual mud in the tires etc., direct the driver to proceed along the
decontamination route to the secondary wash station.Wash any visual residual
mud off of the tires, or exterior surface ofthe truck and trailer.Otherwise,direct
the driver to proceed along the decontamination route to the tertiary
decontamination and final scanning area.
P:\Admin\Master SOPs\Book lO]BL Sops\PBL-9\PBL-9 End DumpSOP Rev 0 (lO.04.02).doc
No.:PBL-9 INTERNATIONAL URANIUM (USA)CORPORATION
Rev.No.:R-O STANDARD OPERATING PROCEDURES Page 3 of6
Date:Oct 4,2002 Title: End Dump TrailerAcceptance,Handling &Release
4. Contact a Radiation Technician to perform a radiological contamination survey
for restricted release ofthe truck and trailer.If the Radiation Technician indicates
areas on the truck or trailer that require further decontamination, decontaminate
those areas as necessary.
5. The Radiation Technician or RSO will scan the trailer, truck, and tires in various
locations as shown on the Equipment Survey for Restricted Release (copy
attached) and document the scan readings on the Equipment Survey for Restricted
Release. The contamination survey will be performed using appropriate
radiological instrumentation for total activity in accordance with nOT
transportation regulations. The release standards to be met for restricted release
are contained in U.S.Department of Transportation (DOT) Part 49 CFR
173.441 (b) and 173.443 (copies attached).
6.If the trailer, truck or tires do not meet the radiological release survey
requirements or shows visually observable contamination, the truck and trailer
will either be returned to the secondary decontamination pad for further
decontaminationor will be washed again at the tertiary decontamination area.
7. The Radiation Technician or RSO will fill out the Equipment Survey for
Restricted Release form (copy attached) to document that the truck and trailer has
been authorized for release for restricted use. These forms are filed in the
Radiation Department. The Radiation Technician or RSO will place a white
sticker on the trailer that says, "EMPTY" and "This package conforms to the
conditions and limitations specified in 49 CFR 173.428 for radioactive material,
excepted package -empty package, UN2910".
8. After a truck and trailer have been released, the driver will perform a visual
inspection ofthe truck,trailer and tires.
9. Leaving his truck outside ofthe Restricted Area, the driver will return to the Scale
House to pick up the documentation for the empty trailer.
6.0 Decontamination and Release of Equipment for Unrestricted Use
1. After the empty weight ofthe trailer has been obtained, the driver will be directed
to the decontamination pad. The tarp will not be replaced on the trailer or,if
necessary, the tarp shall be removed.
2. Open the trailer tailgate, elevate the trailer ensuring that there are no overhead
hazards and decontaminate the trailer using a high-pressure water wash. Make
sure to thoroughly wash the inside and outside ofthe trailer. The truck and tires
shall also be washed.
P:\Admin\Master SOPs\Book 10]BL Sops\PBL-9\PBL-9 End DumpSOP Rev 0 (10.04.02).doc
(.
No.:PBL-9 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.: R-O STANDARD OPERATING PROCEDURES Page 4 of6
Date: Oct 4,2002 Title: End Dump TrailerAcceptance,Handling &Release
3. After the truck and trailer are decontaminated, the driver is directed to follow the
decontamination route. The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the Restricted Area.
If it becomes necessary due to environmental conditions or residual mud in the
tires etc., the driver is instructed to proceed along the decontamination route to the
secondary wash station. Wash any visual residual mud offofthe tires, or exterior
surface of the container. Otherwise, the driver is instructed to proceed along the
decontamination route to the tertiary decontamination and final scanning area.
4. Contact a member of the Radiation Department staff to conduct the appropriate
radiological survey for unrestricted release of the truck, trailer and tires. The
release standards to be met for unrestricted release are contained in Table 1 of the
Nuclear Regulatory Commission's (NRC's)Policy and Guidance Directive FC-
85-23, "Guidelines for Decontamination of Facilities and Equipment Prior to
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source,
or Special Nuclear Material"issued May 1987 (copy attached). The RSO will
prepare a memorandum detailing the applicable standard on Table 1 for each
project. The RSO will also provide the training of the Radiation Technicians
required.
5. The Radiation Technician will perform a radiological contamination survey of the
truck and trailer.Ifthe Radiation Technician indicates areas that require further
decontamination, decontaminate those areas as necessary.
6.If the truck, trailer and tires meet the radiological release survey and visual
inspection requirements, the Radiation Technician will place a red sticker on the
trailer that says, "THIS CONTAINER HAS BEEN FULLY
DECONTAMINATED AND SURVEYED FOR "UNRESTRICTED USE" BY:
(FILL IN NAME OF RADIATION TECHNICIAN)". The RSO or Radiation
Technician that performed the release survey will then sign the red sticker and
date it. In addition, the RSO or Radiation Technician will fill out a
Decontamination Final Release Form (copy attached) to document that the truck
and trailer have been cleared for unrestricted release. The Decontamination
Release Form will be turned in to the Mill Administration Office daily for filing
and distribution.
7. After a truck and trailer have been released, the driver will do a visual inspection
of the truck and trailer.
8. Leaving his truck outside ofthe Restricted Area, the driver will return to the Scale
House to pick up the documentation for the empty trailer.
P:\Admin\MasterSOPs\Book lO]BL Sops\PBL-9\PBL-9End Dump SOP Rev 0 (lO.04.02).doc
No.: PBL-9 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.:R-O STANDARD OPERATING PROCEDURES Page 5 of6
Date: Oct 4, 2002 Title:End Dump Trailer Acceptance, Handling &Release
7.0 Hazard Identification and Safety
7.1 RequiredPersonal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required at a minimum. These must be worn in all areas of
the Mill with the exception ofthe Administration Building.
7.2 IndustrialHazards and Safety
1. Use cautionwhen the trailers are backing onto the Ore Pad.
2. Ensure that all personnel within 50 feet of the area where the end dump trailer are
aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
3. Drivers must use caution during the unloading process and be aware of any
overhead hazards.
4. Do not place any part of your body inside the trailer when the trailer is being
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
5. Be awareof high-pressure wash water.
6. Be aware of slippery conditions on the ore pad during periods of inclement
weather.
7. Be aware of the potential for ice build-up on and around the decontamination pad
during periods of cold weather.
8. Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails.Do not jump off of the equipment.
9. Always use a ladder when entering and/or exiting the interior of an end dump
trailer.
8.0 Paperwork Tracking
1.Each trailer will have a unique sequential project number assigned to it at the
generating facility. This number will be entered onto the Bill of Lading (BOL)
and attachedto the trailer prior to shipment from the generation site.
P:\Admin\Master SOPs\Book lO]BL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (lO.04.02).doc
No.:PBL-9 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.:R-O STANDARD OPERATING PROCEDURES Page 60f6
Date: Oct 4, 2002 Title:End Dump Trailer Acceptance, Handling &Release
2. Upon arrival at the Mill, the truck driver will turn in all of his/her paperwork to
the Scale House operator who will verify that the BOL number, trailer number
and project number assigned to the shipment match on all copies ofthe BOL. The
Scale House operator will also verify that the actual trailer number matches the
BOL Trailer Number.If there are any discrepancies in any of the numbers
notify Mill management immediately.Only original paperwork will be
accepted.If the original paperwork does not come with the trailer,notify Mill
management immediately.The Scale House operator will sign the BOL,
acknowledging receipt of the material at the Mill,if all of the paperwork is in
order.Depending on contractual and/or sampling requirements, final acceptance
or rejection of certain alternate feed materials may be contingent on analytical
results.
3. Each trailer will be transported across the scale at the Mill prior to and after being
unloaded. The appropriate information will be entered into the project database.
All copies ofthe SWTs and BOLs will be forwarded to the Mill Records Manager
on a daily basis or other frequency specified by Mill Management,from time to
time.
4. The Mill Records Manager will compile and reconcile the BOL's and SWTs for
distribution.
P:\Admin\Master SOPs\Book 10]BL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (lO.04.02).doc
SAFETY TRAINING FOR ALTERNATE FEED
DELIVERY PERSONNEL
Welcome to International Uranium (USA)Corporation's,White Mesa Mill. In order to assure
your safety while on our property,we would like to acquaint you with the safety rules and
procedures,which you will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the
cab ofyour truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in .the Mill restricted area
due to radiation hazards.
3. All mobile equipment will not exceed a speed limit of 5 miles per hour.
4. Be aware ofthe possibility of a truck turning over while dumping. Ensure that the truck
is on level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6.If material is hung up in the trailer bed, it is not permissible to work in the bed while it is
in the dump position.If it is necessary to get in the bed of the trailer to free a hang up,
the bed must be lowered.
7. Be aware of slippery conditions on the ore pad during periods ofinclement weather.
8. Be aware ofthe potential for ice build-up on and around the decontamination pad during
periods ofcold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill restricted
area.
2. All equipment,i.e,trucks and trailers, will be scanned for radiation prior to leaving the
Mill's restricted area.
(
Driver (Printed)
Driver (Signature)
-Scale House Operator
Date
P:\Admin\Master SOPs\Book lO_PBL Sops\PBL-9\PBL-9 End Dump SOP Art A (1O.04.02).doc
WAJ~Uocument KetneVaJ mrp:IIIIWeogale.access.gpo.goVlcgl-ollllg...11111 J..,c_l'OGr~~I =II.:I«;:)CI,..IlUI'l.......1(l(.1 Irc-
[Code of Federal Regulations]
[Title 49,Volume 2,Parts 100 to 185]
[Revised as of October 1,1999J
From the U.S.Government Printing Office via GPO Access
[CXTE:49C~73.441J
[Page 582-583J
TITLE 49--TRANSPORTATION
CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION,DEPARTMENT OF
TRANSPORTATION
PART 173--SHIPPERS--GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS--Table of Cont
Subpart I--Class 7 (Radioactive)Materials
Sec.173.441 Radiation level limitations.
(a)Except as provided in paragraph'(b)of this section,each
package of Class 7 (radioactive)materials offered for transportation
must be designed and prepared for shipment,so that under conditions
normally incident to transportation,the radiation level does not exceed
2 msv/hour (200 mrem/hour)at any point on the external surface of the
package,and the transport index does not exceed 10.
[[Page 583J J
(b)A package which exceeds the radiation level limits specified in
paragraph (a)of this section must be transported by exclusive use
shipment,and the radiation levels for such shipment may not exceed the
following during transportation:
(1) 2 msv/h (200 mrem/h)on the external surface of the package
unless the following conditions are met,in which case the limit is 10
msv/h (1000 mrem/h):
(i)The shipment is made in a closed transport vehicle;
(ii)The package is secured within the vehicle so that its position
remains fixed during transportation;and ..
(iii)There are no loading or unloading operations between the
beginning and end of the transportation;
(2) 2 msv/h (200 mrem/h)at any point on the outer surfaces of the
vehicle,including the top and underside of the vehicle;or in the case
of a flat-bed style vehicle,at any point on the vertical planes
projected from the outer edges of the vehicle,on the upper surface of
the load or enclosure if used,and on the lower external surface of the
vehicle;
(3)0.1 msv/h (10 mrem/h)at any point 2 meters (6.6 feet)from the
outer lateral surfaces of the vehicle (excluding the top and underside
of the vehicle);or in the case of a flat-bed style vehicle,at any
point 2 meters (6.6 feet)from the vertical planes projected by the
outer edges of the vehicle (excluding the top and underside of the
vehicle);and
(4)0.02 msv/h (2mrem/h)in any normally occupied space,except that
this provision does not apply to carriers if they operate under the
provisions of a state or federally regulated radiation protection
program and if personnel under their control who are in such an occupied
space wear radiation dosimetry devices.
(c)For shipments made under the provisions of paragraph (b)of this
section,the offeror shall provide specific written instructions for
maintenance of the exclusive use shipment controls to the carrier.The
instructions must be included with the shipping paper information.The
instructions must be sufficient so that,when followed,they will cause
the carrier to avoid actions that will unnecessarily delay delivery or
unnecessarily result in increased radiation levels or radiation .
exposures to transport workers or members of the general public.
,WAIS DocumentRetrieval http://frwebgate.access.gpo.gov/cgi-bin/.g...i?TITLE=49&PART=173&SECTION=441&TYPE=TI
(d)Packages exceeding the radiation level qr transport index
prescribed in paragraph (a)of this section may not be transported by
aircraft.
[Arndt.173-244,60 FR 50307,Sept.28,1995,as amended at 63 FR 48568,
sept.10,1998]
,WAISDocument Retrieval http://frwebgate.Bccess.gpo.gov/cgi·binlg...i?TITLE=49&PART=173&SECTION=443&TYPE=11
[Code of Federal Regulations]
[Title 49,Volume 2,Parts 100 to 185]
[Revised as of October 1,1999]
From the U.S.Government Printing Office via GPO Access
[CITE:49CF.R173.443]
[Page 583-584]
TITLE 49--TRANSPORTATION
CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION,DEPARTMENT OF
TRANSPORTATION
PART 173--SHIPPERS--GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS--Table of Cont
Subpart I--Class 7 (Radioactive)Materials
Sec.173.443 contamination control.
(a)The level of non-fixed (removable)radioactive contamination on
the external surfaces of each package offered for transport must be kept
as low as reasonably achievable.The level of non-fixed radioactive
contamination may not exceed the limits set forth in table 11 and must
be determined by either:
(1)Wiping an area of 300 square centimeters of the surface
concerned with an absorbent material,using moderate pressure,and
measuring the activity on the wiping material.Sufficient measurements
must be taken in the most appropriate locations to yield a
representative assessment of the non-fixed contamination levels.The
amount of radioactivity measured on any single wiping material,when
averaged over the surface wiped,may not exceed the limits set forth in
table II at any time during transport;or
(2)Using other methods of assessment of equal or greater
efficiency,in which case the efficiency of the method used must be
taken into account and
[[Page 584]]
the non-fixed contamination on the external surfaces of the package may
not exceed ten times the limits set forth in table 11,as follows:
Table 11--Non-Fixed External Radioactive contamination-Wipe Limits
------------------------------------------------------------------------
Maximum permissible limits
contaminant
Bq/cm<SUP>2</SUP>uCi/cm<SUP>2</SUP>
----------------~-------------------------------------- - --- - --- ---------
Beta and gamma emitters and low toxicity
alpha emitters...••....•...............
All other alpha emitting radionuclides ..
0.4
0.04
10<SUP>-5</SUP>
10<SUP>-6</SUP>
22
2.2
------------------------------------------------------------------------
(b)Except as provided in paragraph (d)of this section,in the.case
of packages transported as exclusive use shipments by rail or pUblic
highway only,the removable (non-fixed)radioactive contamination on any
package at any time during transport may not exceed ten times the levels
prescribed in paragraph (a)of this section.The levels at the beginning
of transport may not exceed the levels prescribed in paragraph (a)of
this section.
(c)Except as provided in paragraph (d)of this section,each
transport vehicle used for transporting Class 7 (radioactive)materials
as an exclusive use shipment that utilizes the provisions of paragraph
(b)of this section must be surveyed with appropriate radiation
detection instruments after each use.A vehicle may not be returned to
service until the radiation dose rate at each accessible surface is
WAJS Document Retrieval http://frwebg8te.access.gpo.gov/cgi.binlg...irrITLE=49&PART=173&SECTION=443&TYPE=TI
0.005 msv per hour (0.5 mrem per hour)or less,.and there is no
significant removable (non-fixed)radioactive surface contamination as
specified in paragraph (a)of this section.
(d)Paragraphs (b)and (c)of this section do not apply to any
closed transport vehicle used sol~ly for the transportation by highway
or rail of Class 7 (radioactive)material packages with .contamination
levels that do not exceed 10 times the levels prescribed in paragraph
(a)of this section if--
(1)A survey of the interior surfaces of the empty vehicle shows
that the radiation dose rate at any point does not exceed 0.1 msv per
hour (10 mrem per hour)at the surface or 0.02 msv per hour (2 mrem per
hour)at 1 meter (3.3 feet)from the surface;
(2)Each vehicle is stenciled with the words "For Radioactive
Materials Use Only'I in letters at least 76 millimeters (3 inches)high
in a conspicuous place on both sides of the exterior of the vehicle;and
(3)Each vehicle is kept closed except for loading or unloading.
[Arndt.173-244,60 FR 50307,Sept.28,1995,as amended by Arndt.173-
244,61 FR 20753,May 8,1996]
t
!(.
GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT
PRIOR TO RELEASE FOR UNRESTRICTED USE
OR TERMINATION OF LICENSES FOR BYPRODUCT,SOURCE,
· OR SPECIAL NUCLEAR MATERIAL
U.S.Nuclear Regulatory Commission
Division ofFuel Cycle,Medical,Academic,
and Commercial Use Safety
Washington,DC 20555
April 1993
~".
",,'
/
The instructions in thisguide, in conjunction withTable1,specify the
radionuclides and radiation exposure rate limits which should be used in
decontamination and surveyof surfaces or premises and equipment prior to
abandonment or release for unrestricted use. The limitsin Table 1 do not
applyto premises,equipment,or scrap containing induced radioactivity for
whichthe radiological considerations pertinentto theiruse may be
different.The release of such facilities or itemsfrom regulatory control is
considered ona case-by-case basis..~
1. The licensee shallmakea reasonable effortto eliminate residual
contamination.
2.Radioactivity on equipment or surfaces shallnot be coveredby paint,
plating,or other covering material unless contamination levels, as
determined by a survey and documented,are below the limits specified in
Table 1prior to the application of the covering.A reasonable effort
mustbe made to minimize the contamination prior to use of any covering.
3. The radioactivity on the interior surfaces of pipes,drain lines, or
ductwork shallbe determined by making measurements at all traps, and
other appropriate accesspoints,provided that contamination at these .
locations is likelyto be representative of contamination on the interior
of the pipes,drain lines, or ductwork.Surfaces of premises,equipment,
or scrap whichare likely to be contaminated butare of such size,
construction,or location as to make the surface inaccessible for purposes
of measurement shallbe presumed to be contaminated in excess of the limits.
4.Upon request,the Commission may authorize a licensee to relinquish.
possession or controlof premises,equipment,or scrap having surfaces
contaminated with materials in excessof the limits specified.This may .
include,but would not be limitedto,special circumstances suchas razing
of buildings,transferof premises to another organization continuing work
with radioactive materials,or conversion of facilities to a long-term
storage or standby status.Such requests must:
a.Provide detailed,specificinformation describing the premises,
equipment or scrap,radioactlve contaminants,and the nature, extent
anddegreeof residualsurface contamination.
b. Providea detailed healthand safety analysis which reflects that the
residual amounts of materials on surface areas,together withother
considerations suchas prospective useof the premises,equipment,
or scrap,are unlikelyto result in an unreasonable risk to the health
and safety of the public.
j
5.
2
Prior to release of premises for unrestricted use, the licensee shall
makea comprehensive radiation survey which establishes that contamination is
withinthe limits specified in Table 1. A copy-of the surveyreport shall be
filed with the Division of Fuel Cycle Safety and Safeguards,U.S.Nuclear
Regulatory Commission,Washington,D.C.20555,and also the Administrator
of the NRC Regional Office having jurisdiction.The reports should be filed at
least30daysprior to the planned dateofabandonment.The surveyreport shall:
a.Identify the premises.
b. Showthat reasonable effort has been madeto eliminate residual
contamination.
c.Describe the scopeof the surveyand general procedures followed.
d. Statethe findings of the survey in units specified in the
instructions.
Following review of the report, the NRC will consider visiting the
facilities to confirmthe survey.
pfH!l;""I ~""f;,
TABLE 1
ACCEPTABLE SURFACE CONTAMINATION LEVELS
"
Where surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting
nuclides should apply independently.
As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined 'by correcting the counts per
minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
Measurements of average contaminant should not be averaged over more than 1 square meter.For objects of less surface area, the average should be
derived for each such object.
The maximum contamination level applies to an area of not more than '100 cm
2•
The amount ofremovable radioactive material per 100 cm
2 ofsurface area should be determined by wiping that area with dry filter or soft absorbent
paper, applying moderate pressure,and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.
When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire
surface should be wiped.
The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0,2 mradlhr at
1 em and 1.0 mradlhr at 1 em, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.
,,
I
I
I
""I~~.;-
,,c:-,i
...........,..::..
NUCliDES'
U-nat, U-235,U-238,and
associated decay products
Transuranics,Ra-226,Ra-228,
Th-230, Th-228,Pa-231, Ac-227,
1-125,1-129
Th-nat,Th-232,Sr-90,Ra-223,
Ra-224,U-232,1-126,1-131,
1-133
Beta-gamma emitters (nuclides
with decay modes other than
alpha emission or spontaneous
fission) except Sr-90 and
others noted above.
d
AVERAGEbo f
5,000 dpm cdloo em"
100 dpm/100 em'
1,000 dpm/100 em'
5,000 dpm {3r/1OO cm2
MAXIMUMbdf
15,000 dpm ad100 cnf
300 dpm/100 cm
2
3,000 dpm/100 cnr'
15,000 dpm {3r/1OO cnr'
REMOVABLEbef
1,000 dpm 0'/100 cm2
20 dpm/100 cnf
200 dpm/100 cnr'
1,000 dpm {3r/1OO cnf
Date:
International Uranium (USA)Corporation
Equipment Survey for Restricted Release
Container ID:Surveyed By_:_
Outside Locations
28
Front Truck
27 37 29 and Tire Survey
34
26 36 30 0 0
2
33
35 3 00 00 4
25 31
32 5 00 00 6
24
(
PBL·9 (10.04.02)END DUMP(b).xls
Total Alpha!
Beta-Gamma
Location #cpm
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Instrument Data
Tota!Alpha/
Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Efficiency:
Total Alpha!
Beta-Gamma
Location #cpm
1:
2:
3:
4:
5:
6:
Truck Ext.:
TRAILER TIRES
7 00 00 8
9 00 00 10
11 00 00 12
Total Alpha!
Beta-Gamma
Location # cpm
7
8
9
10
11
12
Chassis Ext.
International Uranium (USA)Corporation
Equipment Survey for Unrestricted Release
Date:Container ID:---------
Inside Locations
Surveyed B..:yc...:_
Outside Locations
Front
19
L. Side 23 R Side
13 14 15 16 17 18
22
7 8 9 10 11 12
21
1 2 3 4 5 6
20
Tailgate
28
Front Truck
27 37 29 and Tire Survey
34
26 36 30 0 o 2
33
35 3 00 004
25 31
32 5 00 006
24
dpm/100cm'
anylocationexceeds1000 dpml100 cm2lotalalpha,aswearlwipe surveyforremovable alphamustbe performed.
Total Alphal
Beta-Gamma
TRAILER TIRES
7 00 008
9 00 0010
11 00 0012
Total Alphal
Beta-Gamma
Location cpm
Location #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Total Removable
Alpha Alpha
dpm/100cm'dpm/100cm'Location #
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Total Removable
Alpha Alpha
dpm/100cm'dpm/100cm
Tr
Location cprn
1:
2:
3:
4:
5:
6:
uck Ext.:
sever,additional removableaplha swipes,although notrequired,maybeperformed
(\
Total
Alpha
Instrument: ESP-1I AC-3
SN 02299 I 1
02286 I 2
Cal. Date:
Function Check (5 x 1 min.)
Th 230 @ 30300dpm
Bkg Average:_
Dpm Average:_
PBL-9 (10.04.02)END DUMP(a).xls
Instrument Data
Removable
Alpha
Model:
SN:
Cal. Date:
Function Check (5 x 1min.)
Alpha Bkg Ave,-:_
Alpha eff:
Alpha Factor:_
Total
Beta/Gamma
Model #:
SN:
Cal. Date:
Source:
Efficiency:
Cha
7
8
9
10
11
12
ssis Ext.
r
INTERNATIONAL URANIUM (USA)CORPORATION
DECONTAMINATION FINAL RELEASE
Container Number
authorized for final release.
I have verified that tractor NA and/or container
TractorNumber
__,----,---:-::---:-has been checked for any contamination and has been
Radiation Department
.Radiation Technician
Title Date
C:\windows\TE1.1P\decon SOP.doc
No.:PBL-2 INTERNATIONAL URANIUM (USA)CORPORATION
Rev.No.: R-3 STANDARD OPERATING PROCEDURES Page 1 of7
Date:July 25,2002 Title:Intermodal ContainerAcceptance,Handling &Release
1.0 Purpose
The following procedure applies to acceptance, handling, and release of intermodal
containers from International Uranium (USA) Corporation (IUSA) White Mesa Mill
(Mill). IUSA receives material for processing, in either bulk or non-bulk packaging.
This procedure addresses one form of bulk packaging -intermodal containers (IMCs).
This procedure may be amended, subject to approval by IUSA's Safety and
Environmental Review Panel (SERP), from time to time as appropriate to address the
individual requirements of specific feed materials, or projects.
2.0 OreReceiving
1. Checktruck scale for zero balance at the beginning of each shift.
2. Inbound IMCs will be dropped off in a designated staging area near the Scale
House outside the Restricted Area.
3. Inspect the inbound IMC for the items listed on the Intermodal Container
Inspection Form (copy attached). Notify Mill management of any discrepancies
as soon as practicable. The Intermodal Container Inspection Forms will be
turned in to the Mill office on a daily basis.
4. Inspect all copies of the Bill of Lading (BOL) to ensure that the shipment is
destined for the White Mesa Mill and that all shipping documentation is in order
(see Section 8.2).Ifany discrepancies are noted notify the Mill management
immediately. Do not dump the container until all paperwork discrepancies
are corrected.
5. Assign next available shipment number and White Mesa Mill load number to the
inbound IMC. Record the White Mesa Mill load number, inbound date and both
the truck and IMC numbers on the Scale house Weight Ticket (SWT).
6. A White Mesa truck will be used to retrieve the loaded IMCs stored in the
staging area, outside the Restricted Area, and transport them into the Restricted
Area. The Mill truck will be visually inspected and scanned prior to leaving the
Restricted Area to pick up a loaded IMC.
3.0 Ore Dumping
1. Prior to the dumping ofthe IMC the tarp and tarp support structures,ifapplicable,
are inspected for damage and then removed.
-2. Connect the Bartlett tipper to the loaded IMC chassis and transport across the
truck scales.
P:\Admin\Master SOPs\Book lO_PBL Sops\PBL-2IMC SOPRev3 (08.07.02).doc
No.:PBL-2 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of7
Date:July 25,2002 Title: IntermodaIContainerAcceptance,Handling&Release
3. Enterthe loaded weight ofthe IMC on the IMC SWT.
4. After weighing the IMC, proceed to the tarping and untarping station. Inspect the
tarp then roll the tarp forward. Report the conditions of the tarp and bows of the
IMC to the Scalehouse via radio. Then proceed to the designated ore storage area
and dump the material.
5. After dumping the material;return the IMC back to the tarping station and replace
the tarp and the bows, unless the IMC is being decontaminated for unrestricted
release.
6. After the IMC has been retarped, transport the empty IMC back across the scales
for an empty weight.
7. Recordthe empty weight on the appropriate IMC SWT.
8. At the end ofeach day, turn in outbound SWT to Mill Records Manager.
9. The Mill Records Manager will fill out a Daily Materials Receipts form to obtain
the net weight ofthe material in each IMC.
10. After weighing the IMC, the Bartlett tipper will deposit the IMC in a designated
area,within the Restricted Area, for decontamination.
11. Use a front-end loader or similar equipment to push material into the designated
ore lot pile.
12. Once an ore lot pile is complete, label the pile with the appropriate ore lot
number.
4.0 Decontamination and Release ofIMCs
All IMCs,chassis and tires will be decontaminated after dumping prior to leaving
the White Mesa Mill. Generators or transporters will notify IUSA whether a specific
IMC and chassis is to be released for restricted or unrestricted use. Any IMCs that are to
be released for restricted use will be decontaminated according to the requirements
contained in U.S.Department of Transportation (DOT) Part 49 CFR 173.441 and
173.443 (a copy ofwhich is attached). Any IMCs that are to be released for unrestricted
use will be decontaminated according to the requirements found in Table 1 of the Nuclear
Regulatory Commission's (NRC's)Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" issued May 1987 (a copy is attached}.IMCs requiring repair will be
decontaminated for unrestricted release, to facilitate repairs by the transporter at the
P:\Admin\MasterSOPs\Book lO]BL Sops\PBL-2IMC SOPRev3 (08.07.02).doc
No.:PBL-2 INTERNATIONAL URANIUM (USA)CORPORATION
Rev.No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of7
Date:July 25,2002 Title: Intermodal Container Acceptance, Handling &Release
transporter's own site. IMCs may be repaired without undergoing full decontamination if
repaired within the Restricted Area ofthe Mill.
5.0 Decontamination and Release ofIMCs for Restricted Use
1.A White Mesa Mill truck will pick up the empty IMC, from the staging area
within the Restricted Area, and transport it to the decontamination pad.
2.Decontaminate the exterior of each IMC, chassis and tires thoroughly,using a
high-pressure water wash. Put the chassis into the extended position to improve
access to the rear chassis tires.
3.After the IMC is decontaminated,use the White Mesa Mill truck or other
designated on-site equivalent equipment to move the IMC along the
decontamination route. The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the restricted area. Do
not leave the decontamination route.If it becomes necessary due to
environmental conditions or residual mud in the tires etc.,proceed along the
decontamination route to the secondary wash station. Wash any visual residual
mud offofthe tires, chassis or exterior surface ofthe container.
4.Proceed along the decontamination route to the tertiary decontamination and final
scanning area.
5.Contact a Radiation Technician to perform a radiological contamination survey of
the IMC.If the Radiation Technician indicates select areas on the IMC that
require further decontamination,decontaminate those areas as necessary.
6. The Radiation Technician or RSO will scan the IMC,chassis,tires and White
Mesa Mill truck in various locations as shown on the IMC Container Survey for
Restricted Release (attached)and document the scan readings on the Container
Survey for Restricted Release. The contamination survey will be performed using
appropriate radiological instrumentation for total activity in accordance with DOT
transportation regulations.The release standards to be met for restricted release
are contained in U.S.Department of Transportation (DOT)Part 49 CFR 173.441
and 173.443 (a copy ofwhich is attached).
7.If the IMC, chassis or tires do not meet the radiological release survey
requirements or shows visually observable contamination,the IMC will either be
returned to the secondary decontamination pad for further decontamination or will
be washed again at the tertiary decontamination area.
8. The Radiation Technician or RSO will fill out the IMC survey for Restricted
Release form (copy attached) to document that the IMC has been authorized for
release for restricted use. These forms are filed in the Radiation Department.The
P:\Admin\Master SOPs\Book lO]BL Sops\PBL-2IMC SOP Rev3 (08.07.02).doc
No.: PBL-2 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 4 of7
Date: July 25, 2002 Title:Intermodal Container Acceptance,Handling&Release
Radiation Technician or RSO will place a white sticker on the IMC that says,
"EMPTY" and "This package conforms to the conditions and limitations specified
in 49 CFR 173.428 for radioactive material,excepted package - empty package,
UN2910".
9. After an IMC has been released,the IMC will be delivered by a White Mesa Mill
truck to the designated staging area for empty IMCs, outside the Restricted Area.
After staging a loaded IMC in the designated area, the incoming driver will pick
up an empty IMC at the designated area. Prior to leaving the staging area the
driver will perform a visual inspection ofthe IMC, chassis and tires. Leaving his
truck outside of the Restricted Area, the driver will return to the Scale House to
pick-up the documentation for the empty IMC and sign the Intermodal Container
Inspection Form.
10.A Radiation Technician,or the RSO, will scan the designated decontamination
route and staging area(s) on a quarterly basis. The survey readings will be
recorded and kept on file in the Radiation Department.
6.0 Decontamination and Release of IMCs for Unrestricted Use
1. A White Mesa Mill truck will pick up the empty IMC, from the staging area
within the Restricted Area, and transport it to the decontamination pad.
2. Open the tailgate and decontaminate each IMC using a high-pressure water wash.
Make sure to thoroughly wash the inside and outside ofeach IMC, the chassis and
tires.
3. After the IMC is decontaminated,use the White Mesa Mill truck or other
designated on-site equivalent equipment to move the IMC along the
decontamination route. The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the restricted area. Do
not leave the decontamination route.If it becomes necessary due to
environmental conditions or residual mud in the tires etc.,proceed along the
decontamination route to the secondary wash station. Wash any visual residual
mud off of the tires,chassis or exterior surface of the container. Otherwise,
proceed along the decontamination route to the tertiary decontamination and final
scanning area.
4. Contact a member of the Radiation Department staff to conduct the appropriate
radiological survey of the IMC, chassis, tires and White Mesa Mill truck, as
delineated in Section 2.6 of the White Mesa Mill Radiation Protection Manual.
The release standards to be met for unrestricted release are contained in Table 1 of
the Nuclear Regulatory Commission's (NRC's)Policy and Guidance Directive
FC-85-23,"Guidelines for Decontamination of Facilities and Equipment Prior to
P:\Admin\Master SOPs\Book lO]BL Sops\PBL-2IMCSOPRev3(08.07.02).doc
No.:PBL-2 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 5 of7
Date:July 25,2002 Title:IntermodalContainerAcceptance, Handling &Release
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source,
or SpecialNuclear Material" issuedMay 1987 (Copy attached).
5. The Radiation Technician will perform a radiological contamination survey of the
IMC.If the Radiation Technician indicates select areas on the IMC that require
further decontamination, decontaminatethose areas as necessary.
6.If the IMC, chassis or tires do not meet the radiological release survey
requirements and/or has visually observable contamination, the IMC will either be
returned to the secondary decontaminationpad for further decontamination or will
be washed again at the tertiary decontamination area.
7.If the IMC, chassis and tires meet the radiological release survey and visual
inspection requirements, the Radiation Technician will place a red sticker on the
IMC that says, "THIS CONTAINER HAS BEEN FULLY
DECONTAMINATED AND SURVEYED FOR "UNRESTRICTED USE" BY:
(FILL IN NAME OF RADIATION TECHNICIAN)". The RSO or Radiation
Technician that performed the release survey will then sign the red sticker and
date it. In addition, the RSO or Radiation Technician will fill out a
Decontamination Final Release Form (a copy of which is attached) to document
that the IMC has been cleared for unrestricted release. The form includes a
schematic diagram of the IMC with points to be scanned and locations on the
schematic to fill in survey values for each IMC. The Decontamination Release
Form will be turned in to the Mill Administration Office daily for filing and
distribution.
8. After an IMC has been released, the IMC will be delivered by the White Mesa
Mill truck to the designated staging area for empty IMCs, outside the Restricted
Area. After staging a loaded IMC in the designated area, the incoming driver will
pick up an empty IMC at the designated area. Prior to leaving the staging area,
the driver will do a visual inspection of the IMC, chassis and tires. Leaving his
truck outside of the Restricted Area, the driver will return to the Scale House to
pick-up the documentation for the empty IMC and sign the Intermodal Container
Inspection Form.
7.0 Hazard Identification and Safety
7.1 Required Personnel Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required as a minimum. These must be worn in all areas of
the Mill with the exception ofthe Administration Building.
P:\Admin\MasterSOPs\Book lO]BL Sops\PBL-2fMC SOP Rev3 (08.07.02).doc
No.: PBL-2 INTERNATIONAL URANIUM (USA) CORPORAnON
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 6 of7
Date:July25, 2002 Title:Intermodal Container Acceptance, Handling &Release
7.2 Industrial Hazards and Safety
1. Use caution when chassis are backing onto the OrePad.
2. Ensure that all personnel within 50 feet ofthe area wherethe IMC is hooked up to
the Bartlett tipper are aware that dumping is about to commence.
3. Bartlett tipper operators must use caution during the dumping process. Move at
least 25 feet away from the rear ofthe IMC during the initialdumping operation.
4. Do not place any part of your body inside the IMC when the chassis is being
tipped and the tailgate is open. The IMC could be lowered or accidentally fall at
any time, which would cause the tailgate to close rapidly and result in injury.
Only work under the tailgate after it has been properly blockedopen.
5. Be aware of high-pressure wash water.
6. When the crane is in operation, make sure all personnel, except the persons in
charge of the tag lines, are 50 feet away from the IMC beingmoved. The persons
in charge of the tag lines should never be underneath the IMC that is being
moved.
7. Be aware of slippery conditions on the ore pad during periods of inclement
weather.
8. Be aware of the potential for ice build-up on and aroundthe decontamination pad
during periods of cold weather.
9. Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off of the equipment.
10.Always use a ladder when entering and/or exiting the interiorof an IMC.
8.0 Paperwork Tracking
1.Each IMC will have a unique sequential project number assigned to it at the
generating facility. This number will be entered onto the Bill of Lading (BOL)
and attached to the IMC prior to shipment from the generationsite.
2. Upon arrival at the White Mesa Mill, the truck driver will turn in all of his/her
paperwork to the Scale House operator who will verify that the BOL number,
IMC number and project number assigned to.the shipment match on all copies of
the BOL. The Scale House operator will also verify that the actual IMC number
matches the BOL IMC Number.If there are any discrepancies in any of the
numbers notify Mill management immediately.Only original paperwork will
P:\Admin\Master SOPs\Book IO]BL Sops\PBL-2 IMC SOP Rev3 (08.07.02).doc
No.:PBL-2 INTERNATIONAL URANIUM (USA)CORPORATION
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 7 of7
Date:July 25, 2002 Title: IntermodalContainerAcceptance,Handling &Release
be accepted.If the original paperwork does not come with the IMC,notify Mill
management immediately.The Scale House operator will sign the BOL,
acknowledging receipt of the material at the Mill,if all of the paperwork is in
order.Depending on contractual and/or sampling requirements, final acceptance
or rejection of certain alternate feed materials may be contingent on analytical
results.
3. Each IMC will be transported across the scale at the Mill prior to and after being
unloaded. The appropriate information will be entered into the project database.
All copies of the SWTs and BOLs will be forwarded to the Mill Records Manager
on a daily basis or other frequency specified by Mill Management, from time to
time.
4. The Mill Records Manager will compile and reconcile the BOL's and SWTs for
distribution. The accounting department will forward a summary ofall receiptsto
the International Uranium corporate office and the generator of the material at
least twice monthly, or at other frequencies as determined for the specificproject.
P:\Admin\MasterSOPs\Book lO]BL Sops\PBL-2 IMCSOPRev3 (08.07.02).doc
Number
Container Number
Chassis Number
1 Correct Paperwork
2 Decontaminated
3 Tarps
4 Tarp Tie Downs
5 Tarp Support Bows
Bow Attachment
6 Brackets
7 Lifting Lugs
8 Structural Damage
9 Latch Mechanisms
10 Tires
11 Mudflaps
Additional Comments
Date
IUC
Driver&Trk Num.
INTERNATIONAL URANIUM
WHITE MESA MILL
INTERMODAL CONTAINER INSPECTION FORM
Incoming
Incoming
Outgoing
Outgoing
,
INTERNATIONAL URANIUM (USA)CORPORATION
DECONTAMINATION FINAL RELEASE
NAI have verified that tractor ---"~and/or container
Container Number
authorized for final release.
TractorNumber
__.,__-:---:-::-----,,----has been checked for any contamination and has been
Radiation Department
Radiation Technician
Title Date
C:\windows\TEMP\decon SOP.doc
Date:
Ashland or Linde
International Uranium (USA) Corporation
Intermodal Container Survey for Restricted Release
Container ID:Surveyed By:_
Outside Locations
28
Front IUSATruck
27 37 29 and Tire Survey
34
26 36 30 0 0 2
33
35 3 00 00 4
25 31
32 5 00 00 6
24
ASH2(b)
Total Alpha!
Beta-Gamma
Location # cpm
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Instrument Data
Total Alpha/
Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Efficiency:
Total Alpha!
Beta-Gamma
Location #cpm
1:
2:
3:
4:
5:
6:
Truck Ext.:
IMC CHASSIS TIRES
7 00 00 8
9 00 00 10
11 00 00 12
Total Alpha!
Beta-Gamma
Location #cpm
7
8
9
10
11
12
Chassis Ext.
International Uranium (USA)Corporation
Intermodal Container Survey for Unrestricted Release
Date:Container 10:--------Surveyed B.;!..y..:...:_
Inside Locations Ashland or Linde Outside Locations
Front
19
L.Side 23 RSide
13 14 15 16 17 18
22
7 8 9 10 11 12
21
1 2 3 4 5 6
20
Tailgate dpm/100cm'
27
26
25
28
Front
37
34
36
33
35
32
24
29
30
31
IUSA Truck
and Tire Survey
0 o2
3 00 004
5 00 006
fany location exceeds 1000 dpm/100 cm2 total alpha, a swear/wipe survey for removable alpha must be performed.
awever.additionalremovable aplha swipes,although not required, may be performed.
1:
2:
3:
4:
5:
6:
uck Ext.:
Total Alpha!
Beta-Gamma
Location i cpm
Tr
IMC CHASSIS TIRES
7 00 008
9 00 0010
11 00 o012
Total Alphal
Beta-Gamma
Location i cpm
Total Removable
Alpha Alpha
Location #dpm/100cm2 dpm/100cm2
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Total Removable
Alpha Alpha
Location #dpm/100cm'dpm/100cm'
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Cal. Date:
FunctionCheck(5 x 1min.)
Th 230@ 30300 dpm
Bkg Average:_
Dpm Average:_
Total
Alpha
Instrument:
SN
ESP-11 AC-3
02299 I 1
02286 I 2
Instrument Data
Removable
Alpha
Model:
SN:
Cal. Date:
FunctionCheck(5 x1min.)
Alpha Bkg Ave~:_
Alpha eft:
Alpha Factor:_
Total
Beta/Gamma
Model#:
SN:
Cal. Date:
Source:
Efficiency:
Cha
7
8
9
10
11
12
ssis Ext.
ASH2(a)
WAJI)UocumentKetneval nnp:lIlrweogale.access.gpo.goVlcg.·D1ll1g...1t IIIJ..C-<f:;.«rftK1-I,,:)«O)C,",1IUI"I........1DC.1 IrC-1c.
[Code of Federal Regulations]
[Title 49,Volume 2,Parts 100 to 185]
[Revised as of October 1,1999]
From the u.s.Government Printing Office via GPO Access
[C~~:49C~73.441]
[Page 582-583]
TITLE 49--TRANSPORTATION
CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION,DEPARTMENT OF
TRANSPORTATION
PART 173--SHIPPERS--GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS--Table of Cont
subpart I--Class 7 (Radioactive)Materials
Sec.173.441 Radiation level limitations.
(a)Except as provided in paragraph'(b)of this section,each
package of Class 7 (radioactive)materials offered for transportation
must be designed and prepared for shipment,so that under conditions
normally incident to transportation,the radiation level does not exceed
2 msv/hour (200 mrem/hour)at any point on the external surface of the
package,and the transport index does not exceed 10.
[[Page 583]]
(b)A package which exceeds the radiation level limits specified in
paragraph (a)of this section must be transported by exclusive use
shipment,and the radiation levels for such shipment may not exceed the
following during transportation:
(1) 2 msv/h (200 mrem/h)on the external surface of the package
unless the following conditions are met,in which case the limit is 10
msv/h (1000 mrem/h):
(i)The shipment is made in a closed transport vehicle;
(ii)The package is secured within the vehicle so that its position
remains fixed during transportation;and
(iii)There are no loading or unloading operations between the
beginning and end of the transportation;
(2) 2 msv/h (200 mrem/h)at any point on the outer surfaces of the
vehicle,including the top and underside of the vehicle;or in the case
of a flat-bed style vehicle,at any point on the vertical planes
projected from the outer edges of the vehicle,on the upper surface of
the load or enclosure if used,and on the lower external surface of the
vehicle;(3)0.1 msv/h (10 mrem/hl at any point 2 meters (6.6 feet)from the
outer lateral surfaces of the vehicle (excluding the top and underside
of the vehicle);or in the case of a flat-bed style vehicle,at any
point 2 meters (6.6 feet)from the vertical planes projected by the
outer edges of the vehicle (excluding the top and underside of the
vehicle);and
(4)0.02 msv/h (2mrem/h)in any normally occupied space,except that
this provision does not apply to carriers if they operate under the
provisions of a State or federally regulated radiation protection
program and if personnel under their control who are in such an occupied
space wear radiation dosimetry devices.
(c)For shipments made under the provisions of paragraph (b)of this
section,the offeror shall provide specific written instructions for
maintenance of the exclusive use shipment controls to the carrier.The
instructions must be included with the shipping paper information.The
instructions must be sufficient so that,when followed,they will cause
the carrier to avoid actions that will unnecessarily delay delivery or
unnecessarily result in increased radiation levels or radiation .
exposures to transport workers or members of the general public.
WAfS DocumentRetrieval http://frwebgate.access.gpo.gov/cgi.binl.g...imTLE=49&PART=173&SECTION=441&TYPE=TE
(d)Packages exceeding the radiation level 9r transport index
prescribed in paragraph (al of this section may not be transported by
aircraft.
[Arndt.173-244,60 FR 50307,Sept.28,1995,as amended at 63 FR 48568,
Sept.10,1998]
(
WAIS Document Retrieval http://frwebgate.access.gpo.gov/cgi-binlg...i?TITLE=49&PART=173&SECTION=443&TYPE=TE
[Code of Federal Regulations]
[Title 49,Volume 2,Parts 100 to 185]
[Revised as of October 1,1999]
From the U.S.Government Printing Office via GPO Access
[CI~:49CFR173.443]
[Page 583-584]
TITLE 49--TRANSPORTATION
CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION,DEPARTMENT OF
TRANSPORTATION
PART 173--SHIPPERS--GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS--Table of Cont
Subpart I--Class 7 (Radioactive)Materials
Sec.173.443 Contamination control.
(a)The level of non-fixed (removable)radioactive contamination on
the external surfaces of each package offered for transport must be kept
as low as reasonably achievable.The level of non-fixed radioactive
contamination may not exceed the limits set forth in table 11 and must
be determined by either:
(1)Wiping an area of 300 square centimeters of the surface
concerned with an absorbent material,using moderate pressure,and
measuring the activity on the wiping material.Sufficient measurements
must be taken in the most appropriate locations to yield a
representative assessment of the non-fixed contamination levels.The
amount of radioactivity measured on any single wiping material,when
averaged over the surface wiped,·may not exceed the limits set forth in
table 1~at any time during transport;or
(2)Using other methods of assessment of equal or greater
efficiency,in which case the efficiency of the method used must be
taken into account and
[[Page 584])
the non-fixed contamination on the external surfaces of the package may
not exceed ten times the limits set forth in table 11,as follows:
Table Il--Non-Fixed External Radioactive Contamination-Wipe Limits
Maximum permissible limits
Contaminant
Bq/cm<SUP>2</SUP>uCi/cm<SUP>2</SUP>
----------------~----------------------------------------- - - ---- --------Beta and gamma emitters and low toxicity
alpha emitters..•.........••.......••..
All other alpha emitting radionuclides..
0.4
0.04
10<SUP>-5</SUP>
10<SUP>-6</SUP>
22
2.2
(b)Except as provided in paragraph (d)of this section,in the.case
of packages transported as exclusive use shipments by rail or pUblic
highway only,the removable (non-fixed)radioactive contamination on any
package at any time during transport may not exceed ten times the levels
prescribed in paragraph (a)of this section.The levels at the beginning
of transport may not exceed the levels prescribed in paragraph (a)of
this section.
(c)Except as provided in paragraph (d)of this section,each
transport vehicle used for transporting 'Class 7 (radioactive)materials
as an exclusive use shipment that utilizes the provisions of paragraph
(b)of this section must be surveyed with appropriate radiation
detection instruments after each use.A vehicle may not be returned to
service until the radiation dose rate at each accessible surface is
ni:/IAl?nnn 11.1~J
NAIS Document Retrieval http://frwebgate.access.gpo.gov/cgi-binlg...i?TITLE=49&PART=173&SECTlONz0443&TYPE=m
0.005 mSv per hour (0.5 mrem per hour)or less,.and there is no
significant removable (non-fixed)radioactive surface contamination as
specified in paragraph (a)of this section.
(d)Paragraphs (b)and (c)of this section do not apply to any
closed transport vehicle used solely for the transportation by highway
or rail of Class 7 (radioactive)material packages with contamination
levels that do not exceed 10 times the levels prescribed in paragraph
(a)of this section if--
(1)A survey of the interior surfaces of the empty vehicle shows
that the radiation dose rate at any point does not exceed 0.1 mSv per
hour (10 mrem per hour)at the surface or 0.02 rnSv per hour (2 mrem per
hour)at 1 meter (3.3 feet)from the surface;
(2)Each vehicle is stenciled with the words "For Radioactive
Materials Use Only"in letters at least 76 millimeters (3 inches)high
in a conspicuous place on both sides of the exterior of the vehicle;and
(3)Each vehicle is kept closed except for loading or unloading.
[Arndt.173-244,60 FR 50307,Sept.28,1995,as amended by Arndt.173-
244,61 FR 20753,May 8,1996)
06/14/2000 II ~13 Al
',"'",
GllI0FL::;ES FOR DECm!Tft~rN.AT!r.rJ OF FACILITiES ftND EOll!F~ENT
PRIOR TO RELEA~E FOR UNRESTRICTED USF.
CP TERMINATION OF LICEN~ES FOR BYPRODUCT,SOURCF,
OR SPECIAL NUCLEAR MATERIAL
",":.':
~,"
"".:;',
i,~,U.S.Nuciear Regulatory COlmlission~~~;Division of Fuel Cycle, Medical.Academic,
"'~i.:':,and COl11Tlercial Use Safety
Washington,DC 20555
i:'-;:'<.
J
i~l ,
,:;,
. : t .~
-z.~
',..:::.'..:,t'·-·
r:"'.
-'.'~:'::
",.".,
'•.<.
May 1987
-'~.'.
if'~.,~·t·.
...,f':'/,<f'~¥.-'..
~.
I
Thp 'nstructions in this cu'de.in conjunr.tion w;t~Table 1.spEc'fy thp
radil'lr1fJclides and r~diati('1n exposure riltp limits which should be 'ised in
rlp.contarr'nation and surve....of St!rraces or preni ses and ecuipment orior ~('l
~bandonment or r~lease for unrestr~rted use.The limits in Te~le 1 do not
apply to premis~~,equipment,or scrap ccr.taining induced radioactivity fDr
which the radiological considerations pertinent to their use may be
different.The re'~ase of such facilities or items from regulatory ccr.trol ;s
cr~sidered on a case-by-case.
1.The licensee sh~ll make a reasonable effort to eliminate resir.ual
contamination.
2.Radioactivity on p.quipment or surfaces shall not ~e covered by paint.
plating,or other covering material unless contamination levels,as
determined by a survey and rl~cumented.are below the limits specified in
Table 1 prior to the application of the covering.A reasonable effort
must be made to minimize the contamination prior to use of any covering.
3.The radioactivity on the interior surfac~s of pipes,drain linp.s.or
ductwork shall be dete~ined hy makin~measurements at all traps,and
other appr~priat.e uccess points.provirlpd ~hat contamination at.these
locations is likely to be rp.present.ative of contam~~ation on the interior'
o~the pipes.drain lines.or ductwork.Surfaces nf premises.eouipmentk,/
or scrap which are l;~ply to be contaminated but are of such size,
construction,or loc~tion as to make the surf~ce inaccessihle for purposes
of measurement shall be presumed to be contaminat~d in excess of the limits.
4.Upon request.the Commi~sion may authorize a licensee to relinquish
possession or contr~l of premises,equipment.or scrap haVing surfaces
cont~minated with ~aterial~in excess of the limits ~pecified.This may
include.but would not be limited to.special circumstances such ~s razinQ
of buildings.transfer to premises tn ~nother organization cnntinuing ~ork
with radioactive ~aterials.or conversation of facilitie~to a long-term -
storage or standby ~tatus.Such requests ~ust:
a.Provide detailed.specific info~ation describin~the premises,
equipment or scrap,radioactive contami~ants,and the nature,extent,
and degree of residual surface contamination.
b.Provide a detailed health and safety analysis which reflpcts that the
residual amounts of mater1~ls on surface areas,t0gether with other
consideratio~s such as prospective use of the premises,equirMent.
or scrap.are unlikely to result in an unreasonable risk ~o the
heal~h and safety of the public.
LJ
I
5.
'J
Prior to relPnse of premises for unr~~tricte'd use,~~e licp.nsp.p.shall
make a comprehensive radiatinr survey which establisrps that r.ontaminaticr.i-
wit~in the limits specified in Table 1.A ccpy Of the ~urvey rp.Dort shall he
filer .,..ith the l"iv1~ion Of Fuel Cycle, Medical,Academic,and (OM"'f'rcial l!se
Safety.lJ.S.Nur.'p.ar Regulatory COlT'fl1ission,Washin9t.on.DC 21"555,and also
the Administrator of the NRC Rp.r,ional Office having jurt sdtct ton.The repor t
$hould be filed at least 30 days prior to the planrcd date of abandonMent.
The survey rp.port shall:
a.Irentify the premises.
b.Show that reasonable effort has been made to eliminate residual
contamination.
c.Describe the scope of the survey and qeneral procedures followed.
d.State tht findinos of thfl!survey in units specified in the
instructiun.
Followif'9 review Of the repovt ,t.he 'IJ:lC will consider vfsiting the
facilities to conff~the survey.
~(~"
(...
1I!Ilw""-••••"••"'...••••-•••••-I _..,..,.~_,~.._..__01 __.Ao_____.•'!'.:_.,"""'.....-:".._ .
TABLE 1
ACCEPTABLE SURFACE CONTAMINATION LEVELS•
NU(110(~a AVEAAG(b c f HAXltUtb d f REI'()VABU.b e f
U-nat.U-235.U-230.and
~ssociated dcc~y products
Transuranic~.Ra-226.Ra-228.
Th-2l0.Th-2~8.Pa-2l1.
Ac-221.1-125.1-129
Th-nat.Th-232.Sr-90.
aa.22l.R,-22~.U-2ll.1-126.
1-131.1-13l
Ceta-~d~a ~~itters (nuclides
with decay r.orles other than"
alph3 e~issi~n or spontaneous
fission)except Sr-90 and
others n~te4 above.'
5.000 d~0/100 c.z
100 d~lOO cm'l.
1000 dpml100 c:m2
5000 d~8y/IOO cmZ
15.000 d~01100 c.Z
300 dpm/IDO c.~
3000 dpm/100 0112
15.000 d~By/IOO cmZ
1 .000 dpm all00 cmZ
20 dpmll 00 cllll
ZOO dpm/l00 0Il2.
1000 dpm By/IOO cmZ
------------------------------------:---
~hhCre surface cor-tamination by both alpha-and beta-gamma-emltting nuclides exists.the limits established for alpha-and beta-gamma-emlttlo1
nuclides should ~pply independently.
bAs used in this table.dpm (disintegrations per minute)-eans the rale of emission by radioactive material &S determined by correctlnq the
counts per minute observed by an appropriate detector for b,ckground.efficiency.and geometric factor\associated with the instrumentation.
c:~~surc~ents of average contaminant should not be averaged over more than 1 square -eter.For objects of less surface area.the average
should be derived for each such object.
dihe ~~ximum contamination level applies to an area of not more than 100 cm2•
ejhe amount of removable radioactive material per 100 cml of surface area should be determined by wiping that area with dry filter Or soft~hsoru~nt raper.applying moderate pressure.and asse~slng the amount of radioactive material on the wipe with an appropriate instrument ofk~~~n efficiency.When removable contamination on objects of less surface area is determined.the pertinent levels should be reduced
prcportionally and the entire surface should be wiped.
fTh~averaqe and ma~irnurn radiation"levels associated with surface contamination resulting from beta-gamma e-itters should not exceed
O.l mrad/hr at 1 em and 1.0 mrad/hr at I em.respectively.measured through not more th~n 7 milligrams per square centimeter of
to ta 1 absorber.
r:r:
r
INTERNATIONAL URANIUM (USA)CORPORATION
DECONTAMINATION FINAL RELEASE
Container Number
authorized for final release.
I have verified that tractor NA and/or container
TractorNumber
___--:-__----has been checked for any contamination and has been
Radiation Department
Radiation Technician
Title Date
C:\windows\TEMP\decon SOP.doc
Training Outline for Newly Hired Employees
Inexperienced
This outline meets the requirements of the MSHA approved training plan for the White
Mesa Mill,Dated September 1,2005.
Day One
7:00 A.M.
9:00A.M.
9:15 A.M.
Introduction:
•Introductions ofinstructor and employees.
•Pass around the course outline.
•Explain who the regulatory agencies are that govern our
activities.
.,Hand out Rulebook and sign offSheet.
•Hand out urine sample cups and explain purpose.
•Pass around the Training Attendance Sheet.
•BriefHistory ofthe Mill.
•Explain the milling process.
e Discuss Emergency Escape &Fire Evacuation Procedures.
e Instruction in the Statutory Rights ofminers
Break
Mill Tour
•Introduce the Alpha Survey and demonstrate the proper frisk.
•Go to the warehouse and get safety glasses and hard hats.
e Walk through the plant following the flow chart.Point out
hazards, chemical storage,eyewash stations, fire extinguishers,
and revisit the emergency evacuation procedures.
11:00 A.M.Lunch
11 :30 Class: Radiation Training and Respiratory Protection
•Show the Video,Practical Radiation Safety
•Have a general discussion about radiation.Including but not
limited to such topics as the health affects ofradiation,
benefits ofradiation,types ofradiation, and explain internal
and external dose.
•5 rem
•Explain what the radiation department's responsibility is and
how we measure radiation and monitor exposures.
• Annual Exposure letter.
1:15P.M.
1:30P.M.
Break
Class
•Previous employment at a radiation regulated site for exposure
history.
•Discuss D.A.C. and radiation postings.
•Importance ofUrine samples.
•RWP's
•Defme ALARA
•Explain what the employee's responsibility is in regards to
radiation protection.
•Restricted Area and the alpha frisk. Sign the "Training on the
Proper use ofPersonnel Alpha Monitor form.
•Go over and explain the importance ofthe exposure time
cards.
•Respirator Protections Program. Discuss when we wear them,
what limitations they may have and selecting the proper
cartridge, where they are stored, how they are cleaned, and
how to check them out.
•Demonstrate how to properly field inspect, don, and perform
the positive and negative pressure test.
•Explain the importance of using the proper respirator and
cartridge for the job and wearing only the size you are fitted
for.
•Respirator care.
..Fit test employees and fill out the proper documentation. Note
any need for spec kits and explain. Answer any questions,
review, and then give the radiation quiz.
Note: Any women need to have the Radiation Exposure to Pregnant Women
Training.
End ofthe first day.
Day Two
7:00A.M.Class:Transportation Controls &Communication Systems.
•Organization Chart
•Foreman's Report oflnjury.
It Reporting accidents, near miss incidents, and unsafe
conditions.
It Review direct and indirect costs ofaccidents.
•MSDS.
• NFPA
• Reviewpages 1&2 ofthe rulebook.
Break
•Human Resource Director or designated representative:Time
Cards and explanations of benefits.
10:00A.M. Class:Hazard Recognition
..Discuss the hazards ofthe mill.
..Discuss the SafeWorkPermit
•Video
11 :00A.M. Lunch
11 :30A.M. Class:FirstAid
• Pretest#1,MedicalEmergencies inthe Workplace.
•Video and review.
..Pretest #2,Choking Emergencies
•Video andreview
1:15P.M.
1:30P.M.
Break
Class:FirstAid continues
•Pretest#3, Controlof Bleeding.
•Video,reviewandpractice.
•Pretest#4, Shock-The silentKiller.
•Videoand review.
End SecondDay
DayThree
7:00A.M.
9:00A.M.
Class:First Aid-continue
..Pretest#5,ProperTreatment ofFractures.
•Video,reviewandpractice.
• Pretest#6, Bum Emergencies.
•Video and review.
• Gothroughthe ambulance.
Break
9:15 A.M.Class:Electrical Hazards &Ground Control,Water Hazards, Night
Work,Elevated Work Areas.
It Review rulebook page 29, Electrical Safety Rules.
It Review page 3, Electrical Lock out Procedure.
•Show one ofthe Training videos iftime allows.
..Discuss site traffic rules.
It Vehicle pre-shift inspections.
41}Equipment operator training requirements.
..Safety Rules for Tails page 34.
1\Ladder &Scaffolding rules page 9.
11 :00 A.M. Lunch
11 :30 A.M. Class: Industrial Hygiene,Health and Safety Aspects of Task to which
new miner will be assigned.
1\Show the Training Video 'Nurse Vera knows it all."
It Discuss PPE
It Housekeeping page 13
It Sound Levels
It Dust Sampling
..Chemical Hazards and monitoring.
1:15 P.M.
1:30 P.M.
Break
Class:
It Review
•Questions &Answers.
•Collect all paper work and complete the 5000-23 form.
e Introduce employees to their supervisors. Let the employees ask
specific questions about their job assignments,go get PPE,
lockers, get lockers and prepare for the first day of work.
On the job Training.
Rev. No.: R-11
Date: December 01, 2008
Denison Mines (USA) Corp.
WHITE MESA Mill
SOP MASTER CONTROL LIST
Page 1 of9
Date of
Revision Revision SERP Location
Book No. SOP No.DOCUMENT TITLE No. Date Approval of SOP
1 N/A Ore Receiving &Grind DUSA 1 2/25/07 2/25/07 A---J
B--.~,---,
--1 I PBl·7 Debris leach and Trommel Operation R-1 2/25/07 II
----j .__..
I ---1---_._]BI---'._--
\i D_._.,,-
~re-leaCh &Leach
G
2 N/A DUSA 1 11/13/08 09/29/08 A
-_.'-"-''''---,--SI!_"_,,.w.'···~D,
-'-'->-
I ,G
,
iCC?D DUSA 1 09/29/08 i A3N/A 11/13/08 J -r-zr-r-rr--I I I B-------i I I
I DI--'I I DUSA 1 l G---luranium SX -4 N/A 11/13/08 09/29/08 A
I -,I B--I I I DI,I G
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Date:December 01, 2008
Denison Mines (USA) Corp.
WHITE MESA MILL
SOP MASTER CONTROL LIST
Page 2of9
Book No.
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Date:December01 t 2008
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WHITE MESA MILL
SOP MASTER CONTROL LIST
Page 30f9
IIBookNo.:SOP No.--1
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Date: December 01, 2008
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WHITE MESA Mill
SOP MASTER CONTROL LIST
Page 4 of9
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Date:December 01,2008
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WHITE MESA MILL
SOPMASTER CONTROL LIST
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Date: December 01, 2008
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WHITE MESA MILL
SOP MASTER CONTROL LIST
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Rev. No.: R-11
Date: December 01, 2008
Denison Mines (USA) Corp.
WHITE MESA MILL
SOP MASTER CONTROL LIST
Page g of9
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Date ·-'--'-----'----1
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No.DOCUMENT TITLE80(~~_No.; SOP No.
I I .I800kNo.Reference ILocation Reference
1. Ore Receiving &Grind IA.White Mesa Mill Central Files--'--'---.-....---I2.Pre-Leach &Leach lB.White Mesa Mill Manager's Office
3. CCD ----..-.--....-..--.-.----------fc.White Mesa RadiationSafe-ty--C:-O-=ffi:-lc-e-cr's-OC:-ffice---
4. Uranium Solvent Extraction j'i5~'-White Mesa Mill Control Room .-
5.Yellowcake Precipitation iE.White Mesa Mill Radiation Technician Office
6.'\I8iiadiums-oiVe-ni-Extra;;t~--------of.While Mesa Mill Scai;;l!1ouse-
7. Vanadium Precipitation -----------....-----.--~-.Denver Office Central Fiie·-s-------'-
8. Vanadium ~':!~i~.~_~..Packaging _.,H. Mill 1991 LicenseApplic_a~ion_:_-----_
9. Radiation Protection Manual "1.Denver 1991 License Application
10. Performance Basecl'Manua!--J.NRC Public Document Ro-om--------
11. Environmental Protection Manual ------·----·..--------1 ----
~"-,,,"-,_.-
18. UDEQ Procedures and Plans
SOP Master Control List {R-11).xls
Kespirator Issuance and Fit..estlnq Log
NAME
DATE DATE
OUT IN
FIELD TESTED FITTESTED RESPIRATOR
TYPE YES NO BY : NUMBER
COMMENT
sftor ContR -J
Respirator WIPE COUNT TOTAL BKG.EFF.Net
Number DATE NUMBER TIME COUNTS COUNTS FACTOR dpm/1002 Tech Initials Comments
If removable contamination is greater than 100dpml100cm
2 the area needs to be cleaned and resampled prior to use.
Name,_
RevOI-Q7-09
Date-----
Respiratory ProtectionQuiz 2009
Select the correct answerfromthe possible choices.
1.Ifyou weara respiratorfor only a few minutes,how often must you exchange?
a. Daily
b. Weekly
c. Monthly
d. Quarterly
2.Ifyou are experiencingwarm air blow backwhatis the likely cause?
a. Warmweatherconditions.
b. Cartridgesarestartingto plug up.
c. No needfor alarm.
d. All oftheabove.
3. When issueda cleanrespirator you must:
a. Fill out a respiratorissuance log.
b. Fit test withirritantsmoke.
c. Performa fieldinspection ofthe respirator.
d. All ofthe above.
4. Who mayissuea respirator?
a. Any supervisor.
b. I can checkoutmy own respirator.
c. A member oftheRadiation/Safety Department.
d. My directsupervisor.
5. When you are notwearing your respiratorwheremust your respirator bestored?
a. In the zip lockedplastic bag that comeswiththe device.
b. In your circuit.
c. In the CentralControlRoom.
d. Wherever youwant.
6. A field inspectionconsists of:
a. Inspectingfor cracks, wear marks and splitrubber.
b. Checkingthe seals.
c. Checkingthe faceshield.
d. All ofthe above.
7.Ifyou wearyourrespirator for more than fourhoursa shift, how often must youexchange the
device?
a. Daily.
b.Weekly.
c. Monthly.
d.Quarterly.
8. To wear a respirator,which ofthe followingmust be done?
a. Be cleanshaven.
b.Ifyouwearglasses,make sure youhave a spectaclekit for the device.
c. Performa smoketest.
d. All ofthe above.
9. A full facerespiratorhas what protection factor?
a.10
b. 50
c.1,000
d.10,000
10. A PAPR (PoweredAir Purifying Respirator)is good for which environments?
a. All environmentson site.
b. Dustyenvironment.
c. Chemicalmist environment.
d. None ofthe above.
11. An area postedas "Caution Airborne Radioactivity Area" means?
a. Airborneuranium concentration is above25%ofDAC.
b. Beta-Gamma Levels are at or above 2 mrem/hr.
c. You must weara respirator when youworkinthe area.
d. BothA and C.
12.Ofthe followingwhich areas are mandatoryrespiratorareas?
a. YellowcakeDryers.
b. VanadiumPackaging Area.
c. YellowcakePackaging Area.
d. Any arealabeled as an airborne radioactivityarea.
e. All ofthe above.
13. Occasional respiratoruse requires device exchange:
a. Daily.
b. Weekly.
c. Monthly.
d. Quarterly.
14. A fieldtestis notrequired every time the sealisbroken during usage:
a. True.
b. False.
15. Whattypeof respiratorprotection is availableat this facility?
a. Fullface
b. PAPR
c.SCBA
d. Allofthe above.
!FitTest Results
Last Name
Personnel ID
Medical EvalDate
Denison Mines (USA)Corp
6425 S.Hwy 191
Blanding,Utah 84511
FirstName
Department
Middle Initial
Job Code
FitTrack 3000
Test Date
Mask Mfg.
Mask Type
Notes
IProtocol Name i
MSA
Full Mask
Test Time
Mask Model
Work Rate
Challenge Pressure
Min FitFactor
Mask Size
CartType
RespiratorRate
!step Num ,'Step Description
Don &Face Forward
2 Bend at the Waist &FaceForward
3 Shake Head &Face Forward
4 Redan &Face Forward
5 Redon &Face Forward
Test Results
II FitFactor I
I Equivalent Fit Factor I
Operator:
Subject :
I Average Leak Rate ~
I Leak Rate I
Daily Respirator Check
Date:_
Inspector:_
1. CleanRespirators _
2. Dirty Respirators _
3. Number ofOutstanding Respirators _
4. Number of Cartridges that are available _
5. Number of Respirators in the Washer _
6. Number ofRespirators in the Dryer _
Respirator Protection Program Procedure Review/Training
Date:------
I have read and been trained in the Radiation Protection Manual Procedure.
Name Signed _
Instructor
Name Signed _
Denison Mines (USA)Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel:303 628·7798
Fax:303 389·4125
www.denisonmines.com
February 5, 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
In accordance with the Executive Secretary's correspondence of November 24, 2008, and
received by Denison Mines (USA) Corp.("Denison")on November 26, 2008, we have reviewed
the first round of Interrogatories pertaining to the White Mesa Mill's (the "Mill's")February
2007 License Renewal Application (the "2007 License Renewal Application") and compiled
necessary information in response to the Executive Secretary's request.Accordingly,each
Interrogatory is shown in italics below,followed by Denison's response to the question and/or
request for information.
1. Provide an organizational chartfor the Mills Radiation Safety Department. Include the
RSO's designee,if the RSO is not available;and the specific responsibilities ofstaff
members.
Denison Response:
The following is an organizational chart for the Mill's Radiation Safety Department:
The Lead Radiation Technician is responsible for day-to-day radiation monitoring at the
Mill and takes a more senior role, under the supervision of the Mill's Radiation Safety
Officer ("RSO") in assisting the RSO in implementing the Mill's radiation safety
programs. The Lead Radiation Technician will direct and oversee the specific task
assignments of the Radiation Technicians,all subject to the overall supervision of the
RSO.In addition, Because of the Lead Radiation Technician's experience and aptitude,
he or she is also provided more advanced radiation training at the radiation safety officer
level.
The Lead Radiation Technician reports to the Mill's RSO, who ensures that the Lead
Radiation Technician is doing his or her job in performing such monitoring and in
performing his or her role in implementing the Mill's radiation protection programs.The
RSO is responsible for ensuring that the Mill's radiation safety programs are adequate to
meet all applicable regulatory requirements and to satisfy the requirements of the Mill's
licenses and permits and are implemented appropriately.
The Mill's Radiation Technicians assist the RSO and Lead Radiation Technician in
ensuring that the Mill's radiation safety programs and requirements are implemented.
The Radiation Technician performs specific tasks under the direction of the RSO and
Lead Radiation Technician.As the Radiation Technician gains more experience,he or
she is given more responsibility in his or her tasks and is subject to less direct supervision
by the RSO and Lead Radiation Technician.The Crew Radiation Technicians'
responsibilities are mainly limited to release surveys of personnel and equipment out of
the Mill's restricted area. As Crew Radiation Technicians gain more experience they
may be given additional responsibilities.However,the RSO maintains ultimate
responsibility to ensure that the Mill's radiation safety program is proper!y implemented
in accordance with all applicable laws,regulations,permits and licenses. The Lead
Radiation Technician and the other Radiation Technicians serve mainly to assist the RSO
in performing that function. The levels of responsibility given to the Lead Radiation
Technician and each Radiation Technician is commensurate with his or her qualifications
and level of experience.
OENISOJ)~~
MINES
2
During the absence of the RSO, the Lead Radiation Technician is the RSO's "designee"
and will fill in for the RSO on radiation issues. The designee will have the responsibility
of oversight of the other Radiation Technicians and any other radiation issues that come
up during that time. In order to ensure that non-routine or unusual circumstances are
handled appropriately, the RSO is available by telephone or email 24-hours a day when
not at the Mill, in order to provide any required guidance to the Lead Radiation
Technician. If necessary,in the absence ofthe RSO, the Radiation Technician will
perform certain of the Lead Radiation Technician's routine functions, such as supervising
radiation monitoring etc. The Crew Radiation Technicians will continue on their
assigned tasks with no additional assignments.
2. Explain the training program that has been establishedfor the mills Radiation Safety
Technicians to qualify them to the NRC Regulatory Guide 8.31 Section 2.4.2 Standard.
Also explain, how this training will continue to maintain a level ofcompetence.
Denison Response:
The training program that has been established for the Mill's Radiation Safety
Technicians consists of a number of different stages, as described below:
Familiarization with Applicable SOPs,Permit and License Conditions,and Laws.
For all new trainee employees into the Radiation Safety Department, the trainee must first
read and study the Mill's Standard Operating Procedures ("SOPs"),license and permit
conditions and rules,regulations and guidance that are applicable to his or her duties and
responsibilities.
Side by Side Training.After studying the applicable SOPs, license and permit
conditions and rules and regulations,the trainee is paired with an existing Radiation
Technician who walks the trainee through the procedures and shows the trainee how to
apply the written procedures to day-to-day operations. During this side-by-side training,
the trainee will begin performing some tasks under the oversight of the Radiation
Technician or other qualified radiation safety personnel.
Radiation Safety Quiz.After radiation safety staff have determined that the employee is
confident in the tasks he or she is performing (e.g., scanning) the trainee is given a
written examination.The employee must pass the examination with a score of 70% or
higher.
Probationary Period.The individual will continue to work on a monitored basis during
a probationary period. The duration of the probationary period will vary from individual
to individual,and will generally be longer for individuals with less educational
background.During this period, the employee will be limited to the performance of
certain specified activities.By limiting these activities,the employee will have a better
understanding of the activities and will become equipped to perform the activities and
operate the required instrumentation.The probationary period will end when senior
OENISOJ)~~
MINES
3
radiation safety staff are satisfied that the employee has demonstrated competence in and
an aptitude for his or her assigned activities.
Monitoring of Performance on Additional Duties.After the successful completion of
the probationary period, the trainee will be given more duties. Each additional duty will
also be monitored by radiation safety staff to determine the trainee's competence in the
activity before the trainee will be assigned further activities.
Offsite and Specialized Onsite Training.After the successful completion of his or her
probationary period,the trainee will be sent offsite to attend a training course. The
course curricula will vary.However,concepts of study will include,but not be limited
to, basic radiation,instrumentation,effects of radiation,dosimetry,rules and regulations,
radiological surveys and documentation.Offsite training will take place every two years,
or more frequently when required by changes in policies and procedures.These offsite
courses will also be supplemented by specialized training by senior radiation Staff, held
on site. This training will include,but not be limited to,radiation work permits
("RWPs")issuance,alternate feed materials,personal protective equipment ("PPE")
usage,respiratory protection and basic radiation.
Performance Reviews.Each year the Radiation Department employees will be rated as
to their performance during the previous year. If an employee has a deficient rating, that
employee will be placed on probation and then re-evaluated after 90 days. If the
deficiency is not rectified after 90 days, the employee will be discharged from service.
Satisfaction of Reg Guide 8.31 Requirements.The Lead Radiation Technician will
satisfy the qualifications for a Health Physics Technician under Section 2.4.2 ofNRC
Regulatory Guide 8.31,Information Relevant to Ensuring that Occupational Radiation
Exposures at Uranium Recovery Facilities will Be as low as is Reasonably Achievable,
Revision 1, May 2002 ("Reg. Guide 8.31")based on a combination of education and
experience.The Lead Radiation Technician will have satisfied the training and
experience requirements of Section 2.4.2 of Reg. Guide 8.31 by having gone through the
training program set out above for at least one or two years,depending on his or her
educational background.During this training period, the Lead Radiation Technician will
have been provided a combination ofon-the-job training and specialized training in
radiation protection applicable to the Mill. In addition, once qualified as a Health Physics
Technician in accordance with Section 2.4.2 ofReg. Guide 8.31, the Lead Radiation
Technician will take additional training to prepare to become a Radiation Safety Officer
in the future,should the need arise.
Denison believes that the combination of on-the-job training under the tutelage of
experienced radiation safety personnel,combined with offsite specialized training once
the trainee has enough practical experience on the job to fully understand such
specialized training,provides the best environment for training inexperienced personnel.
This has been proven to be a successful method of training new personnel in the
Radiation Safety Department at the Mill over the years.
DENISOJ)~~
MINES
4
In addition, all radiation safety personnel,not just the RSO and the Lead Radiation
Technician,are required to take offsite refresher training on Mill facility health physics
every two years, and all radiation safety staff participate in periodic internal training
sessions. Denison believes that this combination of internal and offsite training ensures
that all radiation safety staff personnel maintain or improve their levels of competence.
3.According to the Mills Organizational Chart the RSO is also responsible for the
Occupational Safety Department. Provide an organizational chartfor the Mills
Occupational Safety Department. Include the RSO's designee in the Occupational Safety
Department,if the RSO is not available, and specific responsibilities ofstaffmembers.
Denison Response:
The following is an organizational chart for the Mills Occupational Safety Department:
The Safety Coordinator is responsible for day-to-day oversight of occupational safety at
the Mill. He or she is responsible for ensuring that the Mill's safety programs are
implemented and that all occupational safety requirements of applicable regulations are
satisfied at the Mill.
The Safety Coordinator reports to the Mill's RSO, who ensures that the Safety
Coordinator is doing his or her job in enforcing such safety programs and requirements.
The RSO is responsible for ensuring that the Mill's safety programs are adequate to meet
all applicable regulatory requirements,and is ultimately responsible for the
implementation of the program.In the absence of the Mill's Safety Coordinator,the RSO
is responsible for ensuring that the Mill's safety programs and day-to-day requirements
are implemented.
The Mill's Safety Technicians assist the Safety Coordinator in ensuring that the Mill's
safety programs and requirements are implemented.The Safety Technicians perform
specific tasks under the direction ofthe Safety Coordinator or RSO. As the Safety
OENISOrJ)~~
MINES
5
Technician gains more experience,he or she is given more responsibility in his or her
tasks and is subject to less direct supervision by the Safety Coordinator.
During the absence of the RSO,the Safety Coordinator is the RSO's "designee"and is
responsible for all aspects of the Occupational Safety program at the Mill,including the
responsibility of oversight of the Safety Technicians and any other occupational safety
issues that may come up during that time.In order to ensure that non-routine or unusual
circumstances are handled appropriately,the RSO is available by telephone or email 24-
hours a day when not at the Mill,in order to provide any required guidance to the Safety
Coordinator.In the absence of the RSO,the Safety Technicians will continue on their
assigned tasks under the supervision ofthe Safety Coordinator.
Depending on the qualifications and experience of a particular Safety Coordinator and the
qualifications and experience of a particular RSO in occupational safety matters, the
relative responsibilities of the Safety Coordinator and RSO may change over time. For
example,it is possible in the future that a highly qualified and experienced Safety
Coordinator may be given full responsibility for the Mill's occupational safety program
and may not report to or be supervised by the RSO on occupational safety matters.
4.Explain the training program that has been established for the mills Occupation Safety
Technicians. Also explain, how this training will continue to maintain a level of
competence.
Denison Response:
The Mill's occupational Safety Technicians are required to meet set minimum
educational/experience requirements,on the job training requirements,and specialized
training requirements as described below:
EducationallExperience Requirements.The qualifications standards for a Safety
Technician are as follows:
1) One year of service in an industrial setting in an operational or maintenance position;
and
2)Either:
a. One year of service in the Mill's Safety Department as a trainee,or
b. An Associate's degree or higher from an accredited institution.
The Mill's Safety Coordinator and RSO are also required to have met these requirements
or the equivalent.
Probationary Training Period.Each new hire in the Safety Department is subject to a
probationary period. The length of the probationary period varies from individual to
individual and continues until such time as the Safety Coordinator has determined that
the individual has the required skills and experience to perform the required tasks.
a)ENISOJ)~
MINES
6
During the probationary period,the technician in training will work side by side with
experienced members of the Safety Department.During this time, the trainee will be
expected to read and understand the applicable standards for the site. The Safety
Coordinator will verify the technician's comprehension ofthe rules and requirements
prior to presenting the trainee for full technician status. If the trainee is unable to fully
understand the rules,regulations,inspections and other items needed by a technician, that
employee will either be discharged or the probationary period will be extended until such
time as the trainee has demonstrated the required competence.
Offsite Training.After completion of the probationary period,the new technician will
attend an offsite training course.These courses will pertain to Occupational Health and
Safety issues, and will include but not be limited to,MSHA and OSHA style course
work. These offsite training courses will be taken by every Safety Technician initially
after the end of the technician's probationary period and thereafter once every two
calendar years of service, or more frequently when required by changes in policies and
procedures.These trainings will also be supplemented with MSHA's annual
informational courses.
Performance Reviews.Each year the Safety Department employees will be rated as to
their performance during the previous year.If an employee has a deficient rating, that
employee will be placed on probation and then re-evaluated after 90 days.If the
deficiency has not been rectified,the employee will be discharged from service as a
Safety Technician.
Maintaining Competence.Denison believes that the combination of on-the-job training
under the tutelage of experienced occupational safety personnel,combined with offsite
specialized training, once the trainee has enough practical experience on the job to fully
understand such specialized training,provides the best environment for training
inexperienced personnel. This has been proven to be a successful method of training new
personnel in the occupational safety department at the Mill over the years.
In addition,all occupational safety personnel,not just the Safety Coordinator,are
required to take offsite refresher training every two years, and all occupational safety
staffparticipate in periodic internal training sessions.Denison believes that this
combination of internal and offsite training ensures that all occupational safety staff
personnel maintain or improve their levels ofcompetence.
5.According to the Mills Organizational Chart the RSO is also responsiblefor the
Environmental Department. Provide an organizational chartfor the Mills
Environmental Department. Include the RSOs designee in the Environmental
Department,if the RSO is not available,and specific responsibilities ofstaffmembers.
Denison Response:
The following is an organizational chart for the Mill's Environmental Department:
OENISOJ)~J
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7
The Environmental Coordinator is responsible for day-to-day environmental monitoring
at the Mill and implementation of the Mill's environmental programs,under the
supervision of the RSO.
The Environmental Coordinator reports to the Mill's RSO, who ensures that the
Environmental Coordinator is doing his or her job in performing such monitoring and
implementing such environmental programs. The RSO is also responsible for ensuring
that the Mill's environmental programs are adequate to meet all applicable regulatory
requirements and to satisfy the requirements ofthe Mill's licenses and permits. The RSO
is ultimately responsible for the implementation of the Mill's environmental program.In
the absence of the Mill's Environmental Coordinator, the RSO is responsible for ensuring
that the Mill's day to day environmental programs and requirements are implemented.
The Mill's Environmental Technician(s)assist the Environmental Coordinator in
ensuring that the Mill's environmental monitoring is performed and that the Mill's
environmental programs and requirements are implemented.The Environmental
Technician(s)perform specific tasks under the direction of the Environmental
Coordinator or RSO. As the Environmental Technician(s)gain more experience, they are
given more responsibility in their tasks and are subject to less direct supervision by the
Environmental Coordinator.
During the absence of the RSO, the Environmental Coordinator is the RSO's "designee"
and is responsible for all aspects of the environmental programs at the Mill, including the
responsibility of oversight of the Environmental Technician(s)and any other
environmental issues that may come up during that time.In order to ensure that non-
routine or unusual circumstances are handled appropriately, the RSO is available by
telephone or email 24-hours a day when not at the Mill, in order to provide any required
guidance to the Environmental Coordinator.The Environmental Coordinator will also
have the responsibility of shipping and receiving of hazardous materials and product in
the absence of the RSO.In the absence ofthe RSO, the Environmental Technician(s)
will continue on their assigned tasks under the supervision of the Environmental
Coordinator.
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Depending on the qualifications and experience of a particular Environmental
Coordinator and the qualifications and experience of a particular RSO in environmental
matters,the relative responsibilities ofthe Environmental Coordinator and RSO may
change over time. For example,it is possible in the future that a highly qualified and
experienced Environmental Coordinator may be given full responsibility for the Mill's
environmental program and may not report to or be supervised by the RSO on
environmental matters.
6. Explain the training program that has been establishedfor the mills Environmental
Technicians.Also explain, how this training will continue to maintain a level of
competence.
Denison Response:
The qualifications standards for an Environmental Technician are as follows:
1) One year of service in an industrial setting, and
2) Either:
a. One year of service in the Mill's Environmental Department as a trainee, or
b. An Associate's degree or higher from an accredited institution.
In addition, the Mill's Environmental Coordinator and RSO are required to have also met
these requirements or the equivalent.
Probationary Period.During the probationary period,the technician in training will
work side by side with an experienced member of the Environmental Department.
During this time, the technician in training will be expected to read and understand the
applicable rules,regulations,license and permit conditions and applicable SOPs. The
Environmental Coordinator will verify the technician's comprehension ofthese rules and
requirements prior to presenting the technician in training for full technician status.Ifthe
technician in training is unable to fully understand the rules,regulations,inspections and
other items needed by a technician,that employee will either be discharged from the
Environmental Department or the probationary period will be extended.
Offsite Training.After the completion of the probationary period, the new technician
will attend an offsite training course.These courses will pertain to environmental
sampling,equipment maintenance,and or other areas of environmental concern as
deemed necessary by the RSO.These offsite training courses will be taken by every
Environmental Technician initially after the end ofthe technician's probationary period
and thereafter once every two calendar years of service,or more frequently when
required by changes in policies and procedures.
Performance Reviews.Each year the Environmental Department employees will be
rated as to their performance during the previous year.Ifan employee has a deficient
rating, that employee will be placed on probation and then reeevaluated after 90 days. If
OENISOJ)~~
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the deficiency is not rectified,the employee will be discharged from service in the
department.
Maintaining Competence.Denison believes that the combination ofon-the-job training
under the tutelage ofexperienced occupational safety personnel,combined with offsite
specialized training, once the trainee has enough practical experience on the job to fully
understand such specialized training,provides the best environment for training
inexperienced personnel. This has been proven to be a successful method of training new
personnel in the environmental department at the Mill over the years.
In addition, all environmental staff are required to take offsite refresher training every
two years, and all environmental staff participate in periodic internal training sessions.
Denison believes that this combination of internal and offsite training ensures that all
environmental staffmaintain or improve their levels of competence.
7.Explain how the RSO can effectively manage the extra Radiation Safety needs and
requirements during an emergency if he is also acting as the mills Fire Chief
Denison Response:
The RSOlFire Chiefs responsibilities are primarily in preparing for potential
emergencies and in coordinating activities during an actual emergency.Denison believes
that the RSO is the best qualified person at the site to coordinate activities in the event of
an emergency,because ofhis knowledge of all aspects of safety at the site.Because the
RSOlFire Chief will have established qualified teams to assist in an emergency,he or she
will be able to effectively manage all ofthe radiation and safety needs during an
emergency.
The RSOlFire Chief has a number of responsibilities.The first is to create and train a fire
team that is able to act professionally during an emergency event. The RSOlFire Chief
works with the Safety Department and the Safety Coordinator under 30 CFR 56.4330
firefighting,evacuation,and rescue procedures.The RSO/ Fire Chief makes sure that the
team or crew has been established,equipped and properly trained every six months.
The RSOlFire Chiefs second responsibility is to ensure that, during an actual emergency,
the appropriate crew or team has the available members needed to respond to the
emergency.After the team or crew has responded and is in the process of handling the
situation,the RSOlFire Chiefs third primary responsibility is to ensure that the Radiation
and Safety Departments maintain scene safety. Scene safety includes,but is not limited
to,crowd control,outside emergency assistance requests and any decontamination.
As indicated in the Appendix D -Emergency Response Plan, under the Section 5
organizational chart, the RSOlFire Chiefis responsible for the Emergency Response
Teams.The key personnel who will be team leaders and assist the RSOlFire Chief in the
event ofan emergency are the Safety Coordinator,the Lead Radiation Technician and the
OENISOJ)J,A.
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10
other members of the Radiation Safety Department,who are all trained in their
responsibilities in the event of an emergency.
During an emergency situation,the Safety Coordinator will be present and receive
direction from the RSO/Fire Chief as to how to proceed.If the RSO is present during the
emergency,the Safety Coordinator will act as the Assistant Fire Chiefto free up the
RSO's time to deal with radiation decontamination or other issues that may arise. If the
RSO is not present,the Safety Coordinator will be the acting Fire Chief and the radiation
designee will act as the Assistant Chief, but will only deal with radiation related issues.
Ifthe Safety Coordinator is not present,those responsibilities fall to the next senior
member ofthe Safety Department.Scheduled time off at the Mill is worked around the
RSO's and Safety Coordinator's time off. At no time will both individuals be given time
off,thereby ensuring supervised coverage in the event ofan emergency.
One ofthe Emergency Response Teams includes the Radiation Technicians,led by the
Lead Radiation Technician.That team is responsible for decontamination and surveys as
needed during an emergency.The Mill has established an emergency call sheet that will
require notification throughout the Radiation Safety Department.When an emergency
occurs,the RSO/Fire Chiefis notified and then the Lead Radiation Technician and/or
Crew Radiation Technicians notify the off-shift Radiation Technicians.The Crew
Radiation Technicians will maintain scene security until directed by the RSO to do
otherwise.When the off-duty Radiation Technicians arrive,they will report immediately
to the RSO and receive their instructions,
So,during an emergency,the RSOlFire Chief works as a coordinator of his subordinates
to maintain the proper flow of needs at this critical time.The RSOlFire Chief is not
acting as a fireman or necessarily performing radiation surveys himself,but as a manager
of the scene to make sure all required activities are performed.
8. Explain how the Radiation Safety needs at the mill are being managed if the RSO is
responding offsite to a transportation accident.
Denison Response:
The RSO manages the radiation safety needs at the Mill on a dailybasis.He has been
provided a staff of Radiation Safety Technicians,and ofthose technicians,one is the
Lead Radiation Safety Technician who serves as a designee for the RSO.If the RSO
must report to an offsite location,such as the scene of a transportation accident (or must
be offsite for any other reason)the lead Radiation Safety Technician acts as his designee
in his absence and has responsibility for radiation safety matters at the Mill.The RSO is
equipped with a cell phone for direct contact while offsite should a question or other
situation arise that is beyond the capability of the designated personnel.
If the RSO determines that there are more pressing radiation safety needs at the Mill at
that time that require his personal attention,then the RSO will send one or more of his
OENISOJ)~~
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staffto attend to any offsite needs such as a transportation accident. For most
transportation to and from the Mill, the transportation contractor is required to have an
emergency response/accident plan that usually provides for a qualified offsite contracting
party to provide first response to a transportation accident.Mill personnel usually attend
the accident site to assist,if necessary, and to provide specialized radiation safety
monitoring and clean-up supervision.Radiation safety staff, other than the RSO, are
trained to be able to provide such assistance to first responders in the event of an offsite
transportation accident.
9. Describe how the RSO allocated his time for his Radiation Safety,Occupational Safety,
Environmental duties and any other duties assigned.
Denison Response:
As is contemplated by Reg. Guide 8.31 at Section 2.1,"The RSO may be have other
safety-related duties,such as responsibility for programs ofindustrial hygiene and fire
safety, but should have no direct production-related responsibility."The scheduling of
the RSO's time to accommodate these functions is undertaken on a daily basis,and how
this time is allocated is directly related to the daily tasks at hand. The RSO is assisted in
day-to-day operations by the Lead Radiation Technician,the Environmental Coordinator
and the Safety Coordinator.It is the intention of Denison to advance the training ofthese
three subordinate positions over time, but to still maintain the current RSO as the overall
manager of the three departments.
Denison believes that it is fortunate at this time to have an RSO who has experience in
radiation safety,occupational safety and environmental protection matters and who has
the knowledge and experience to oversee all of these departments.Denison believes that
this is better than having three separate and compartmentalized departments, each with its
own department head.IfDenison did not have an RSO with these qualifications,then it
would be forced to go to a more compartmentalized structure,but Denison sees this as a
disadvantage and not as a first choice given the current personnel.
However,depending on the qualifications and experience of a particular Safety
Coordinator and/or Environmental Coordinator,the relative responsibilities of the Safety
Coordinator,Environmental Coordinator and RSO may change over time. For example,
it is possible in the future that a highly qualified and experienced Safety Coordinator
and/or Environmental Coordinator may be given full responsibility for the Mill's
occupational safety program or environmental program,as they case may be, and may
not report to or be supervised by the RSO.
10. The submitted Emergency Response Plan does not sufficiently address all ofStaff
Emergency Assignments that should be covered. These include but not limited to
Radiological Surveys and Assessments,Decontamination ofthe mills Personnel and
Facility, First Aid and etc. Explain how the mill plans on addressing these and other
issues in the event ofan emergency.
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The Mill's current Emergency Response Plan was intended to comply with the portions
of NRC Reg. Guide 3.67 Standard Format and Contentfor Emergency Plans for Fuel
Cycle andMaterials Facilities that are applicable to a site such as the Mill site in a level
of detail that Denison believed was adequate for the Mill site. The Emergency Response
Plan does not follow the format, or contain the level ofdetail on all matters, set out in the
Reg. Guide,because it was thought that such detail and format was more suited to a site
such as a nuclear power reactor and was overly complicated for a site such as the Mill.
However,Denison has reviewed its Emergency Response Plan against NRC Regulatory
Guide 3.67, in light of your questions. We agree that the details cited above could be
spelled out in more detail in the Plan.Currently,all assignments are given through the
Fire ChieflRSO and he will assign available Radiation Safety Technicians,safety
personnel and response teams to functions commensurate with their particular expertise.
Given that these assignments are not fully described in the Plan and because a more
formal codification ofthese functional assignments could be set out in the Plan,Denison
proposes to re-evaluate its Emergency Response Plan and update the plan in accordance
with the general guidelines of NRC Regulatory Guide 3.67.In so doing,Denison will
change the format ofthe Emergency Response Plan to better track the requirements of
Reg Guide 3.67,thereby making it easier for the Executive Secretary to determine,and
consider,any differences between the provisions of the Mill's Emergency Response Plan
and the guidance provided by Reg Guide 3.67.Denison will revise and re-submit its
Emergency Response Plan within 60 days after the date of this letter.
11.Provide the inspection procedure that discusses the inspection requirements ofthe
alternate feed material that are stored in containers other than drums from when the mill
takes acceptance ofthe material until they process the material.
Denison Response:
Attached to this letter as Exhibit A is the Mill's Containerized Alternate Feedstock
Material Storage Procedure,No. PBL-19, Rev.: No.:R-O,June 19,2008.That procedure
applies to all containerized feedstock material,whether contained in drums or other
containers,and provides the inspection requirements from when the Mill takes
acceptance of the material until it is processed.Therefore,it applies to super sacks as
well as drums.
However,Section 3.1.1 of that procedure states that feedstock materials stored at the
defined storage location (i.e. on the ore pad) can be stored in containers or in bulk form
and are subject to the routine inspections described by the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT)Monitoring Plan as
Section 3.3 a).
So,materials contained in super sacks, drums or any other container off of the Mill's ore
pad are subject to specific controls and inspections as set out in PBL-19.However,any
alternate feed materials stored,in super sacks or otherwise,on the ore pad are subject to
the controls and inspections applicable to bulk materials stored on the ore pad.
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At present, there are no alternate feed materials contained in super sacks off of the Mill's
ore pad.
12. Provide the procedure that discusses how alternate feed material that arrives in super
sacks,placed on the ore storage pad and is exposed to the wind will be containerized.
Denison Response:
The purpose of the super sack is to provide containment of the material during transport.
While the sacks remain generally intact during off-loading,they can be tom or damaged
as they are transferred to storage on the Mill's ore storage pad.Accordingly,super sacks
are only stored on the ore pad where bulk material storage is contemplated.Such
materials are managed on the ore pad in a manner similar to conventionally mined ores
and bulk alternate feed materials,and are subject to the normal procedures applicable to
bulk materials stored on the ore pad. These procedures include the airborne dust control
measures described in Section 5.1.2 of the Mill's 2007 License Renewal Application and
the procedures set out in Section 3 of Tab 3-3.Tailings Dust Minimization,in Appendix
A to the 2007 License Renewal Application.
In addition to these procedures,and in accordance with the Mill's Approval Order issued
by the State of Utah Air Quality Division (the "Air Approval Order"), the Mill has
proposed to the Executive Secretary of the State of Utah Air Quality Board an additional
work practice dust control program for the control of emissions during the handling and
storage of bulk ore material,including transfer from the pad to process (see White Mesa
Mill Work Practice Standardsfor Control ofFugitive Dust-Ore Receipt and Front-End
Loader Operations,attached as Exhibit B hereto).
At present,FMRI materials are delivered to the Mill in super sacks and are stored in the
super sacks on the ore pad.Some ofthe super sacks have been compromised in the
unloading process and while managed on the ore pad.However,those materials are
typically hardened and do not contain much in the way of fines that would be overly
susceptible to dispersion by wind. The normal dust control measures applicable to bulk
materials stored on the ore pad have therefore been considered to be more than adequate
for those materials.
13. Provide the procedure used to determine how and when alternatefeed is to be processed
through the mill.
Alternate feed materials are "ores"and are stored on the Mill's ore storage pad, or in
containers elsewhere on the site,pending processing,just like conventional ores are
stored on the Mill's ore pad pending processing.This is a reality of uranium milling that
has been contemplated in Mill design and approvals.Protections are in place,through
facility design,license conditions and standard operating procedures,to ensure that any
ores stored at the Mill pending processing are managed in a safe manner,with no
significant threat to public health,safety or the environment.
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The determination as to when a particular alternate feed material will be processed
through the Mill will depend on a number of factors specific to each alternate feed
material, including, the quantity of the material in stockpile at the site, the rate at which
the materials are to be received at the site, the quantity and timing of receipt of other ores
or feed materials available for processing at the time, the timing of scheduled Mill runs,
the coordination of processing the materials in conjunction with or in logical sequence
with other alternate feed materials or conventional ores in order to provide for a Mill run
of sufficient duration,the compatibility of the materials with other materials,any process
adjustments that must be made in order to process the materials and the extent to which
such process adjustments coordinate with other ores being processed or scheduled for
processing,economic conditions at the time, the availability of qualified personnel,the
availability of tailings capacity,the need to perform maintenance on or make capital
improvements to the Mill, etc. All of these factors vary from feed to feed and ore to ore
and can change from year to year, depending on the overall status ofMill operations.
The Mill has operated on a campaign basis for both conventional ores and alternate feed
materials since its start up in 1980, and there can be no certainty in the timing of the start
or finish of any particular Mill run. For these reasons, it is not possible to have a set
procedure to determine when an alternate feed material or conventional ore is to be
processed.
As to how an alternate feed material will be processed through the Mill, this will be
determined on a feed-by-feed basis. If an alternate feed material can be processed
through the Mill in accordance with existing Mill SOPs, or portions thereof, then no new
procedures are required.Ifminimal changes are required to existing SOPs, and the
processing run is short, then these changes can be accommodated through an RWP and/or
a Safe Work Permit.If substantial changes are required to existing Mill SOPs in order to
process the alternate feed material,and/or the processing run will be of significant length,
then the Mill may develop new SOPs for a particular alternate feed material.Examples
of such new standard operating procedures are Heritage Alternate Feed Management
PBL-6 Rev. No.:R-l,Feb 14,2003;Potassium Fluoride (KF) Processing,PBL-5, Rev.
No.:R-O,April 20, 2005;Standard Operating Proceduresfor Calcine Material Uranium
Extraction Process PBL-17,Rev. No.:R-O,October 25,2005;and Standard Operating
Proceduresfor Re-Generation Uranium Extraction Process,PBL-18, Rev. No.:R-O,
April 30, 2007.These new procedures are generally developed through the Mill's Safety
and Environmental Review Panel ("SERP") process.
14.Release Surveys for Ore Trucks: Explain how the survey techniques, the release
standards used and documentation ofsurveys ofore trucks are sufficient to demonstrate
regulatory compliance and maintain public health and safety. Explain why surveying
techniques such as the use ofLarge Area Wipes to look for removable contamination are
not being used in surveys for release.
OENISOJ)~~
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15
Denison Response:
Denison's release survey procedure for ore trucks is consistent with NRC Regulatory
Guide 8.30,Health Physics Surveys in Uranium Recovery Facilities ("Reg. Guide 8.30")
at Table 2 and Section 2.7, which specifies that "Surface contamination surveys should
be conducted before potentially contaminated equipment is released to unrestricted areas.
The surface contamination limits listed in Table 2 are recommended".
Section 4.0 of the Mill's End Dump Trailer Acceptance,Handling and Release,
procedure PBL-9, Rev. No.:R-O,a copy of which is attached to this letter as Exhibit C,
provides that:
"All end dump trailers and trucks will be decontaminated after unloading
prior to leaving the Mill. Generators or transporters will notify [Denison]
whether a specific trailer is to be released for restricted or unrestricted use.
Any trailers that are to be released for restricted use will be
decontaminated according to the requirements contained in U.S.
Department of Transportation (DOT) Part 49 CFR 173.441(b) and
173.443 (copies attached). Any trailers that are to be released for
unrestricted use will be decontaminated according to the requirements
found in Table 1 of the Nuclear Regulatory Commission's (NRC's)Policy
and Guidance Directive FC-85-23, "Guidelines for Decontamination of
Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" issued May 1987 (copy attached). Trailers requiring repair will
be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without
undergoing full decontamination if repaired within the Restricted area of
the Mill."
Restricted Release.At the Mill the ore trucks are consigned as "exclusive-use" vehicles
for the shipment of Low Specific Activity Material (LSA-1). As such, these vehicles are
used for uranium ore shipments only, and their use is restricted accordingly. As
exclusive use shipments, the trucks remain marked in accordance with the requirements
of the U.S. Department of Transportation ("DOT") until they are no longer used for that
purpose, at which time each buck is subjected to a survey for unrestricted release.
During the exclusive use arrangement, the interior of the transport trailer is not
decontaminated between shipments;however, the trailer must remain closed by means of
its protective cover to preclude access and preclude release of material from the interior
surface. These exclusive use vehicles are subjected to a restricted release survey until
such time that they are no longer shipping uranium ore.
As statedin the excerpt above, any trailers that are to be released from the Mill's
restricted area for restricted use will be decontaminated according to the requirements
contained in DOT Part 49 CFR 173.441(b) and 173.443. Section 173.443provides that a
OENISOJ)~
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determination ofwhether or not the applicable release limits have been achieved can be
accomplished in one of two ways:
a) By taking 300 square centimeter swipes in a sufficient number of areas in the
most appropriate locations to yield a representative assessment; or
b) By using other methods of assessment ofequal or greater efficiency.
Restricted release surveys for exclusive use vehicles involve a survey ofthe exterior of
the vehicle prior to release on public roadways.This survey occurs after routine
decontamination of the vehicle's exterior and is conducted by means ofportable alpha
detection equipment.The portable meters measure combined removable andfixed
contamination directly from the monitored surface and, as such, the measurement does
not discern removable from fixed contamination.Alternately,the "Large Area Wipes"
referred to in paragraph a) above measure only the removable contaminants.resulting
performing its release surveys,Denison applies the more restrictive limits applicable to
removable contamination to the combined fixed plus removable measurement attained by
this particular monitoring method. Using portable alpha detection equipment that
measures the combined fixed and removable contamination is therefore "another method"
contemplated by paragraph b) above of "equal or greater efficiency",because the Mill
applies the removable contamination standard to a combined reading offixed and
removable contamination.If the trailer passes the survey, then the combined fixed and
removable contamination levels must be less than the standard for removable
contamination,and hence the removable contamination must also be less than that
standard.
In applying this more conservative approach,all contamination on the exterior ofthese
vehicles is maintained below 1000 dpm/100 cm2,even though the Table 2 limits would
allow up to 15,000 dpm/lOOcm
2 on an individual fixed contamination reading and an
average fixed reading of up to 5,000 dpm/lOO cm
2 for areas up to 1m
2.Denison's
practice is conservative in that it limits contaminants to the more restrictive removable
limit for all contamination and is therefore ALARA and in compliance with the
requirements of49 CFR 173.443 and the Mills SOPs.
Unrestricted Release.Release surveys for ore trucks that are being released for
unrestricted use,include the same procedures as those for restricted release,except that
the interior of the ore transport trailer is included in the survey and all DOT markings are
removed from the vehicle. The applicable standards are those set out in Table 1 ofthe
NRC Reg.Guide referred to above.Again,since the ore truck will only be released if the
combined fixed and removable contamination is less than the standard set out in Table 1
of the Reg.Guide for removable contamination alone, the Mill's approach is ALARA
and in compliance with the requirements of the Reg Guide and the Mill's SOPs.
15.Release Surveys for Intermodals:Explain how the survey techniques, the release
standards used and documentation ofsurveys ofInterrnodals that contain, may contain or
have contained radioactive material are sufficient to demonstrate regulatory compliance
and maintain public health and safety.Explain why surveying techniques such as the use
OENISOJ)~~
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17
ofLarge Area Wipes or Swipes to lookfor removable contamination are not being used
on Intermodals being surveyedfor release.
Denison Response:
Intermodal containers are treated in the same fashion as the 'exclusive use" ore trucks
referred to in Item 14 above.
Section 4.0 ofthe Mill's Intermodal Container Acceptance,Handling and Release,
procedure PBL-2, Rev. No.: R-3 contains similar language to Section 4.0 of the Mill's
End Dump Trailer Acceptance,Handling and Release procedure referred to above. A
copy of the Mill's Intermodal Container Acceptance,Handling and Release procedure is
attached as Exhibit D to this letter.
Please see the discussion in Item 14 for an explanation as to how the survey techniques
are sufficient to demonstrate regulatory compliance and maintain public health and
safety.
16.Release Surveys for Product Drums:Explain how the survey techniques, the release
standards used and documentation ofsurveys ofProduct Drums that contain radioactive
material are sufficient to demonstrate regulatory compliance and maintain public health
and safety. Explain why surveying techniques such as the use ofLarge Area Wipe or
swipes to look for removable contamination are not being used on all Product Drums
being surveyedfor release.
Denison Response:
Product drum surveys are performed in the same fashion as the surveys performed for
'exclusive use" ore trucks referred to in Item 14 above, with the additional requirement to
perform alpha swipes in certain circumstances.Please see the discussion in Item 14 for
an explanation as to how the survey techniques are sufficient to demonstrate regulatory
compliance and maintain public health and safety.
The procedures applicable to product drum release surveys are set out in Section 2.7 of
the Mill's Radiation Protection Manual for uranium product shipments and in the Mill's
procedure "Release and Shipping ofVanadium Blacliflake"No.PBL-15 Book 10 for
vanadium product shipments.
As with ore trucks and intermodal containers,the procedures require that a survey of total
fixed and removable contamination be performed using a hand-held meter. If the
measurement for combined fixed and removable alpha exceeds the standard for
removable alpha alone, than an alpha swipe must also be performed.To this extent, the
procedures are similar to the procedures applicable to the release of ore trucks and
intermodal containers,and satisfy the Mill's ALARA goals and applicable regulatory
requirements,for the reasons discussed in Item 14 above.However,in addition to these
requirements,the procedures also require that, even if the measurement for combined
OENISOJ)~~
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18
fixed and removal alpha contamination does not exceed the standard for removable
contamination,a swipe test must be performed on at least 25% of the product drums.
This additional test is intended to provide quality assurance that the primary surveying
method provides the required outcome.
It is not correct to say that a removable survey will only be performed on 25%of the
product drums. As discussed above,if the measurement for total alpha activity exceeds
the standard for removable alpha activity on all drums, then a removable survey must
also be performed on all drums.
It should be noted that Section 2.8 of Reg Guide 8.30 states that:
"After being filled,yellowcake packages should be washed down to
remove surface contamination.Surveys of external surfaces of
yellowcake packages prepared for shipment should be carried out before
shipment.The surveys conducted should be adequate to ensure that the
wash-downs are reducing surface contamination levels to less than
Department of Transportation (DOT) limits,but do not necessarily include
a survey ofeach package.The bottoms of all barrels should be surveyed
to determine the effectiveness of the wash-downs."[Emphasis added]
17. Release Surveys for Equipment: Explain how the survey techniques, the release
standards used and documentation ofsurveys ofEquipment are sufficient to demonstrate
regulatory compliance and maintain public health and safety. Explain why surveying
techniques such as the use ofLarge Area Wipes and swipes to look for removable
contamination are to being used on all items being surveyedfor release.
Denison Response:
Release surveys for equipment are performed in a similar fashion as the surveys
performed for 'exclusive use" ore trucks referred to in Item 14 above, with the additional
requirement to perform beta gamma surveys in certain circumstances.
The procedures applicable to equipment release surveys are set out in Section 2.6 of the
Mill's Radiation Protection Manual,which is included in the Mill's 2007 License
Renewal Application.
Please see the discussion in Item 14 for an explanation as to how the survey techniques
are sufficient to demonstrate regulatory compliance and maintain public health and
safety.
18.Designated Eating Areas within the RestrictedArea: Explain the justification ofhaving
designated eating areas and the number ofeating areas within the restricted area.
OENISOJ)JJ
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19
Denison Response:
Reg. Guide 8.30, at Section 2.5,Surveys for Surface Contamination in RestrictedArea,
page 12,contemplates that uranium recovery facilities may designate non-production
rooms within the facility's restricted area for eating purposes.In this regard the NRC
states:"In rooms where work with uranium is not performed,such as eating rooms,
change rooms,control rooms, and offices, a lower level of surface contamination is likely
to be present.These areas should be spot checked weekly for removable contamination
using smear tests."
In accordance with the NRC's recommendation,designated eating areas in the Mill are
spot checked on a weekly basis, and removable contamination is limited to 1000 dpm/lOO
crrr', with an ALARA goal of 200 dpm/l00 cm2 (one fifth ofthe limit applied to materials
to be released for unrestricted use).
Because it has been observed that these designated areas can be kept within the limits
prescribed by the NRC and within Denison's ALARA goal,construction of offsite
facilities is unwarranted.
The number ofeating areas within the Mill's restricted area is kept to a minimum,in
order to minimize the number of locations that require added management to ensure that
contamination levels are ALARA and within regulatory limits. The criteria for
determining designated eating areas is discussed in the following Item.
19.Designated Eating Area within the Restricted Area: Define the criteria usedfor
determining designated eating areas within the Restricted Area.
Denison Response:
Designated eating areas within the restricted area must first fulfill the criterion prescribed
by Reg. Guide 8.30 referenced in Item 18 above (i.e. those areas "where work with
uranium is not performed").In addition to this overriding criterion,the Mill requires that
each designated eating area be in a location where there is little likelihood of
contamination and where controls can be established to ensure that any chance of
contamination can be managed in a way that satisfies the Mill's ALARA goals and
applicable regulatory requirements.
Section 2.2.2 Policy for Eating-Restricted Area in the Mill's ALARA Program lists nine
locations that may be designated by the RSO from time to time as eating areas. That list
is not intended to be exhaustive,and other areas that meet the foregoing criteria may be
designated from time to time by the RSO as eating areas.Which of the possible suitable
locations are designated by the RSO at any particular time as eating areas will depend on
the operations and activities at the Mill at the time. The RSO will generally designate the
minimum number of areas needed to efficiently accommodate the needs ofworkers at the
Mill, without requiring workers to leave the restricted area or venture too far from their
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work areas.Because additional effort is required to manage eating areas, any areas that
are not needed to accommodate workers will be designated as non-eating areas, until such
time as they may be re-designated as eating areas, if the need arises.
Currently, the Mill has established one area in the restricted area that is designated
primarily for eating (i.e., the lunch/training room, located on the second floor of the
warehouse building).The only other locations in the restricted area where eating may
occur at this time are in the supervisors'offices and in the Scalehouse.In addition to
these locations in the restricted area, the main office administrative building,which is not
located in the Mill's restricted area, is also an eating location.Uranium work is not
conducted at any of these locations,and spot surveys confirm that contamination of
eating surfaces is being maintained ALARA and within regulatory requirements.
20.Breathing Zone Sampling Sheet:Explain why the sampling form does not have the name
ofthe individual wearing the air sampler and why the names ofthe individuals working
with the assigned employee are not on theform.
Denison Response:
Section 1.1.2.6 ofthe Mill's Radiation Protection Manual (Appendix E to the 2007
License Renewal Application)states that the data maintained "on file" includes the
"Individual's name,identification number,etc."It does not specifically require that such
information be contained on the sampling form itself, nor does it state that the names of
the individuals working with the assigned employee must be included on the form.
On the Breathing Zone Sampling Sheet,there is a comment section. In the comment
section, the Radiation Technicians have the choice of either indicating the individual's
name or other information that will allow Mill radiation safety staffto track the
individual wearer or others associated with the sampling event. For example,rather than
stating an individual's name, the form may record an RWP number or it may be labeled
as to which crew and location was involved in the sampling. In either case, Mill radiation
staff is able to use that information to tie back to the individuals involved.To the extent
possible, the Mill has deliberately tried to limit the inclusion of names on the forms in the
Monthly Radiation folders. Instead, Mill staff has tied numbers to samples that can be
tracked to other paperwork where more detailed information,such as names of affected
individuals can be found.
If an RWP is referred to on the form, the RWP will indicate the Breathing Zone number
which will track to paperwork showing the readings collected. The RWP form will list
all parties involved with that air sampling,and each employee will be attributed that
direct reading into his or her exposure record.
The Mill has found that by applying this technique,it is possible to manage the
information in the Monthly Folders while not creating documentation that is cluttered and
confusing.
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As for random samplings,such as periodic Breathing Zones during normal activities, it is
easy to track the sample results to the individual working in that area without having to
assign his or her name to a document. This is because each area will have only one
assigned operator to a given circuit during that shift.Ifa maintenance activity requires a
Breathing Zone sample, then that activity will be documented with an RWP or other
permits that will contain the information needed to track the names of the affected
individuals.
21.Provide [the] SOP for using the DRY CAL or equivalent for calibrating air sampling
equipment.
Denison Response:
The following has been added to the Mill's Radiation Protection Manual:
"3.2.3 Electronic Calibration Method
The electronic primary gas flow calibration is the primary calibration method and does
not require corrections to or from standard conditions for temperature and pressure.
Personal air samplers are calibrated for the flow rate for the sampling being performed,
typically 2 -4 liters per minute.
The equipment utilized is as follows:
1) UltraFlo Primary Gas Flow Calibrator, or equivalent
2) Soap solution
3)Tubing
4) Small screwdriver
5)Sample pump
The procedure proceeds as follows:
1)Remove the two nipples on the back of the UltraFlo Primary Gas Flow Calibrator.
2)Attach the connection tubing from the top nipple to the sample pump.
3)Tum calibrator on
4)Tum sample pump on
5) Press the plunger style button on top ofthe soap dispensing portion of the device.
6) Write down the digital reading from the calibrator device.
7)Repeat steps 5 and 6 three times.
8) Take an average of the three readings.
9)If the sample pump requires adjustment,take the screwdriver and adjust the set
screw on the face of the sample pump and then repeat steps 5 through 7.
10) After the sample pump is calibrated,document the calibration on the Breathing
Zone/Radon Calibration Sheet, in the Radiation department.
11)Replace nipple caps on the back on the calibrator."
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22. Dust Control: Explain the site inspection interval and the standard used to implement
dust control measures on the ore pad.
Denison Response:
The procedures applicable to dust control on the ore pad are described in Section 5.1.2 of
the Mill's 2007 License Renewal Application and in Section 3 of Tab 3-3,Tailings Dust
Minimization,in Appendix A to the 2007 License Renewal Application.
Under these procedures,a daily inspection of the ore stockpile area for dusty conditions
will dictate if dust suppression measures are necessary. If dusty conditions are present,
the roadways and/or stockpiles will be sprayed with water or stabilized to minimize
dusting. If dusting is observed while transferring ore to the Grizzly from either roadways
or stockpiles,water applications will be applied to minimize dusting. The number of
applications,time of application,and location ofapplication is documented and kept on
file in the Radiation Office.Weekly inspections of the stockpile area are conducted to
evaluate the effectiveness of dust control measures.
The standards applicable to, and additional procedures used to implement,these dust
control measures on the ore pad are set out in Sections 15 through 26 of the Mill's Air
Approval Order, under the heading "Roads and Fugitive Dust". Those sections require
the Mill to abide by all applicable requirements ofR307-205 for fugitive emission and
fugitive dust sources.They also require that visible fugitive dust emissions from haul
road traffic not exceed 20%opacity and set out detailed procedures for determining
opacity. The Air Approval Order also sets limits on drop distances for front-end loaders
and truck dumping operations and for the speed of scrapers while loading and dumping.
In recent consultations with the Executive Secretary of the Division of Air Quality, the
Mill has proposed an additional work practice dust control program for the control of
emissions during the handling and storage of bulk ore material,including transfer from
the ore pad to process (see the White Mesa Mill Work Practice Standards for Control of
Fugitive Dust-Ore Receipt and Front-End Loader Operations,which is attached as
Exhibit B to this letter).
23.Explain why a new employee is not always issued an external monitoring device prior to
being allowed to work inside the restricted area.
Denison Response:
Prior to the May 28,29,2008 inspection,the Mill provided every employee an OSL
device after they were hired at the Mill.Because it takes some time to order and receive
OSL badges,there were circumstances where the new employee's OSL badge was not
available until some period of time (up to a few weeks) after the employee started work at
the Mill.In those circumstances,for the period of time that the worker did not have his
or her own OSL badge, the worker was assigned a dose equal to the highest dose
measured for workers in his or her area of the Mill or job description.
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However,after the May 28,29,2008 inspection, the Mill changed its practice. Now, the
Human Resources department at the Mill is required to provide the Radiation Safety
Department with the required information for OSL purchase two weeks prior to the
training period for new hires. By doing this, the OSL devices are on site when the new
hires start their training period.
However,if an emergency hire situation occurs, the new hires are each given a generic
extra badge that the Mill maintains on site. These extra badges are maintained in their
shipping packages and away from all radiation emitting sources. The badges are also
stored at the Mill with control badges to verify that the area of storage is proper. The
extra badges will then be issued to the new employees until their permanent badges
arrive. Once the permanent badges arrive, the Radiation Department will change out the
badges and then send off the extra badges for reading. Any exposure that is recorded on
an individual's extra badge is then assigned to that individual's personnel exposure
record.
As a result of the foregoing,the statement in Volume 1 Section 6.4.1 Mill external
Radiation Monitoring of the 2007 License Renewal Application,which states that an
OSL badge or equivalent will be issued to new employees that will be working in the
Restricted Area within 30 days ofemployment is no longer accurate.Section 1.3 ofthe
Mill's Radiation Protection Manual,which deals with Beta-Gamma Surveys, does not
refer to such a 30-day period.
24.Explain why external monitoring devices are allowed to be worn on the hard hats of
individuals working inside the restricted area.
Denison Response:
The question as to whether or not it is appropriate for Mill workers to wear their OSL
badges on the back oftheir hardhats,as opposed to on their torsos, was under discussion
between the Executive Secretary and Denison for some time. This resulted in tests being
performed by Denison to see if there were any significant differences in the dose
measurements to workers depending on whether the badge was worn on the torso or on
the back of the hardhat.While the results from these tests did not indicate a significant
difference,Denison agreed that it would change its practice to require all workers to wear
their OSL badges on the torso. This change was implemented on September 12,2007.
However,although this change has been implemented and training sessions have
reflected this change since that date, Section 1.3.1 ofthe Radiation Protection Manual
and the Training Manual have not been amended to reflect this change. At this time,
those procedures are being changed to indicate that all OSL devices must be worn on the
torso of the body as required in R313-15-503(l).All employees have been instructed as
to the proper location of the individual monitoring device and the associated disciplinary
actions for the failure to wear the device in the proper location.
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25.Demonstrate that the Radiation Safety Program covers all ofthe material that is outlined
in NRC Reg. Guide 8.31 Section 2.5 Radiation Safety Training.Explain indetail how
this training is documented.
Denison Response:
The training for all employees,consists of material presented in Appendix J Training
Manual Addendum 9:Radiation Protection and in the White Mesa Mill Safety Handbook.
The actual outline of the training is spelled out under the Training Outline for Newly
Hired Employees.The outline set out in Appendix J Training Manual Addendum 9 is the
outline for annual refresher training. The breakdown of the training session is attached as
Exhibit E to this letter.
The training session begins with the introduction of the Mill,regulatory agencies that
govern the Mill's activities, milling process, history of the facility, emergency escape and
evacuation procedures, rights of employees and bioassay sampling. During this
introduction the staff also introduces the White Mesa Mill Safety Manual.In the White
Mesa Mill Safety Manual starting on page 13, issues with "RADIATION AND YOUR
WORK"are discussed.
Topics covered under the White Mesa Mill Safety Manual are as follows:
1) What is Radiation?
2) Why are we concerned about radiation?
3) What are the different types of radiation?
4) Posting of specific areas
5) Radiation Safety Procedures
6) Radiation Work Permits
7) Radiation Exposure Monitoring
The next area of coverage is the introduction of the Alpha Survey and importance of a
proper frisk. An explanation is given as to why the survey is required. Each employee
must demonstrate that he or she understands and can perform a proper survey.
A video is then shown:Practical Radiation Safety.This video covers health effects of
radiation,benefits of radiation, types of radiation and an explanation of internal and
external dose. The video also discusses PPE usage for the different kinds of radiation,
natural sources of radiation, dose limits for the public and occupationally exposed
individuals,ALARA and precautions to reduce dose.
After the video there is a general discussion about the following:
1) Radiation - such as health effects ofradiation,benefits of radiation, types of
radiation, and explanation of internal and external dose,including pathways to
exposure;
2)Different alternate feed materials and the makeup and exposure potential with
each;
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3) Designated eating,drinking and smoking areas;
4) Exposure limits mandated by NRC;
5) The Radiation Department's responsibility and how Radiation Safety Staff
measures radiation and monitor exposures;
6) Annual reporting to each employee on exposures received;
7) Requests for previous exposure history from other sites;
8) DAC and radiation postings;
9) Importance of Bioassays samples;
10)RWP's;
II)ALARA;
12)The employee's responsibility with regard to radiation protection;
13)Restricted Area and a proper alpha frisk;
14)OSL's;
15)TEDE;
16)Ways to reduce exposure - time, distance and shielding;
17)The importance ofthe exposure time sheets;
18)The use and types ofPPE (i.e. respiratory protection,cleanliness,eating areas);
and
19)If applicable,discussion with any women regarding the Radiation Exposure to
Pregnant Women Training.
During the training, there are several forms that are used to document the process. Those
forms are:
1) Attendance sheet to document that an individual was in the class;
2) Previous exposure history request for employees that worked at other sites having
exposure monitoring;
3) Sign off sheet for women on the Radiation Exposure to Pregnant Women
Employees;
4)Sign off sheet for Personal Alpha Monitoring scan training; and
5) Radiation Protection Quiz.
Throughout the training sessions,oral questions are posed to each employee to verify that
the employees are understanding topics
Other topics referred to in Section 2.5 of Reg. Guide 8.31 under the heading F.acility-
Provided Protection,such as ventilation systems and effluent controls,cleanliness of the
work place, features designed for radiation safety for process equipment,security and
access control to designated areas,electronic data gathering and storage, and automated
processes,to the extent not covered above, are included in other topics covered during the
24-hour training session for new-hires,of which the radiation training is a part.
Denison is confident that its current training program covers all ofthe topics required
under Reg. Guide 8.31 and provides thorough training for its employees in order to
ensure their safety and the safety of the public and the environment.However, Denison
agrees that the Mill's radiation safety training program is currently not structured so as to
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allow for an easy comparison of the topics covered and the requirements of Reg. Guide
8.31. Therefore, Denison will 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.Denison will submit the revised training program to the Executive
Secretary for review within 90 days after the date of this letter.
26.Demonstrate that the Respiratory Protection Program covers all ofthe material that is
outlined in NRC Reg. Guide 8.15 Section 5.2 Training.
Denison Response:
The Mill's Respiratory Protection training program is intended to cover all of the material
that is outlined in NRC Reg.Guide 8.15 Section 5.2 Training.In the following
paragraphs,the seven bullet points set forth in Section 5.2 of Reg. Guide 8.15 are
reproduced,followed by a statement that indicates which paragraphs of the 2007 License
Renewal Application Appendix J:Training Program Addendum 10:Respiratory
Program,address these bullet points:
Ii "Be informed of the hazard to which the respirator wearer may be exposed,
the effects of contaminants on the wearer if the respirator is not worn
properly, and the capabilities and limitations of each device that may be
used."
This information is contained in Items Band D ofAppendix J,Addendum 10.
Ii "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."
At the Mill, we only use the spectacle adapters.During training, the use of
spectacle kits is only mentionedfor those needing eye wear. Once an individual
has presented a prescription for eye wear,Denison will purchase the kit for them.
When the spectacle kit arrives on site, the Safety Department will instruct the
wearer individually and go over the proper maintenance,care and installation of
the spectacle kit before the employee is allowed to leave with the device.
Ii "Be able to demonstrate competency in donning,using, and removing each
type of respiratory protective device that may be used."
This information is contained in Items D and E (2)ofAppendix J,Addendum 10.
Ii "Be instructed in how to inspect each type of respiratory device that may be
used and be instructed to perform such an inspection before donning any
device."
This information is contained in Items D and E ofAppendix J,Addendum 10.
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• "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."
This information is contained in Item E ofAppendix J,Addendum 10.
• "Be informed that any respirator user may leave the work area at any time for
relief from respirator use in the event of equipment malfunction,physical or
psychological distress,procedural or communications failure,significant
deterioration ofoperating conditions,or any other condition that might
necessitate such relief."
This information is contained in Item G ofAppendix J,Addendum 10.
• "Be advised that in case ofrespirator malfunction or wearer distress, the
respirator may be removed as the respirator user exits the airborne
contamination area."
This information is contained in Item G ofAppendix J,Addendum 10.
Denison is confident that the topics required under Reg. Guide 8.15 are covered by the
Mill's respiratory training program,as summarized in Appendix J of the 2007 License
Renewal Application.However,Denison agrees 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.Therefore,Denison will rewrite
the Mill's respiratory protection training program so that the topics covered line up better
with the topics outlined in Section 5.2 ofReg. Guide 8.15, to allow for a more direct
comparison of the training program to those requirements.Denison will submit the
revised training program to the Executive Secretary for review within 120 days after the
date of this letter.
The summary of respiratory protection training program set out in Section 2.3 of the
Mill's Respiratory Protection Program included as Appendix L to the 2007 License
Renewal Application will also be amended accordingly to reflect the changes to the
respiratory protection training program.
27. Explain what is considered a passing score for tests (i.e.Radiation Safety,Respiratory
Protection,standard Operating Procedure, etc.). Explain what is done when an
employee fails a test.Explain how many times an employee is allowed to fail a test
before they are not allow!ed] to perform the task. Explain in detail how this testing is
documented.
Denison Response:
At the Mill, a passing score on any written test or examination is 70% or higher.
Anything less than that is considered a fail.
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If an employee fails a test, the employee must be re-trained on the subject matter ofthe
test. The employee is authorized to take the examination only three times.Ifthe
examination is failed for the third time, the employee will be discharged.
In special circumstances,if an employee cannot read or is unable to understand the test
questions in English,the test can be administered orally to the individual.Responses are
gathered from the oral examination on the test sheet and the employee will make his or
her mark.The same pass/fail criteria will apply in these circumstances.A passing score
is 70%, and if the employee fails three times he or she is discharged from service.
Each employee must demonstrate that he or she is able to don, use and remove each type
of respiratory device that may be used at the Mill.This demonstration is performed in
front of the trainer,and is a pass/fail situation.No written statement is required for this
demonstration.If the instructor does not feel the employee has successfully performed
these steps, the employee is sent to another instructor for remedial assistance.
All tests taken,including failed examinations are maintained in the appropriate employee
records.Examinations administered by the Radiation and Safety Departments are
maintained in the records housed in those Departments.All SOP examinations,or other
examinations required for an employee's assigned operational duties, are maintained in
the records housed in the various other departments that administered the examinations.
These records are maintained throughout the employee's tenure at the Mill.
Training is given to employees on each applicable SOP.This training is documented by
the signed acknowledgement ofthe employee that he or she attended the training session
and understands the subject matter.These acknowledgment sheets are also signed by the
supervisor that administered the training session.These sign off sheets on the SOPs are
completed by operations personnel on all circuits.Disciplinary action will be taken
against any employee who fails to gain the understanding of an SOP/circuit prior to
engaging in activities that are covered by the SOP.This documentation is maintained in
the Mill Superintendent's office.
28.Provide a complete list and copies ofall operating procedures used at the mill. Explain
how employees are trained on the procedures they use.Explain where procedures arkept
and how employees have access to the procedures that they use.
Denison Response:
Attached to this letter as Exhibit E is a list of all standard operating procedures at the
Mill.The list also indicates where copies of each procedure are maintained at various
locations around the Mill. The locations are determined based on the needs of employees
and supervisors to have ready access to the various procedures.Only procedures that are
relevant to the particular locations are located at or near those locations.All supervisors
have access to the procedures.Operators have access to the SOPs that pertain to their
jobs.
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As mentioned in Item 27,training is given to employees on each applicable SOP. This
training is documented by the signed acknowledgement of the employee that he or she
attended the training session and understands the subject matter. These acknowledgment
sheets are also signed by the supervisor that administered the training session.These sign
off sheets on the SOPs are required by operations on all circuits.Disciplinary action will
be taken against any employee who fails to gain the understanding of an SOP/circuit prior
to engaging in activities that are covered by the relevant SOP. This documentation is
maintained in the Mill Superintendent's office.
Also enclosed with this letter as Exhibits C and D are copies of the following SOPs,that
are referred to in the 2007 License Renewal Application or the Appendices thereto:
II End Dump Trailer Acceptance,Handling and Release,PBL-9, Rev No R-O;
and
II Intermodal Container Acceptance,Handling and Release,PBL-2, Rev No R-
3.
These SOPs, along with the SOPs appended to the 2007 License Renewal Application,
relate to or have provisions that relate to radiation safety,environmental protection,
release of materials and other matters specifically directed toward maintenance ofpublic
health, safety and protection of the environment.They should properly have been
included with the 2007 License Renewal Application.However, the remainder of the
procedures referred to in the attached list relate to Mill operations and should not be
considered part of the 2007 License Renewal Application.They are not intended to be a
part of the public record,but are maintained at the Mill for inspection by the Executive
Secretary (see also the discussion in Item 36 below).As a result, copies of those SOPs
are not included with this letter.
29. Define an occasional respirator user and the infrequent respirator user.Explain why
respirators are not issued as needed and turned in at the completion ofthe day or
assignment.
Denison Response:
After the completion of the inspection conducted on May 28,29,2008,Denison changed
its policy regarding respiratory protection.The Mill no longer recognizes the concepts of
occasional user and infrequent user.
As a result, there is now no difference between an individual who wears a respirator for
five minutes or one who wears a respirator for four hours. All respirators are required to
be issued only when needed and must be turned in at the end of the day. A training
session was performed where all employees were trained on this new policy and signed
off on the procedure.
As a result of these changes to Mill procedures,when an individual needs respiratory
protection,he or she must now be issued a numbered respirator by the Radiation/Safety
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Department. The Radiation/Safety Staff will then perform a visual inspection of the
employee to make sure that the employee is clean shaven and will also perform a smoke
test on the individual.The respirator information is then documented on the Respirator
Issuance Log.When the respirator is returned,the Respirator Issuance Log is updated
showing the return of the device.Morning and afternoon checks are performed on the
log to make sure respirators are being returned. If a device is not returned,the Radiation
Technicians will seek out the device and the employee.Repeated failure to return the
device will cause the employee to face disciplinary action.
30. Provide the procedure for performing a quantitative fit test.
Denison Response:
The following has been added to the Mill's Respiratory Protection Program:
"2.4 Fit Testing
Frequency -annually for every employee who is required to wear a respiratory protective
device.
Quantitative fit testing will be performed using the FitTester 3000, or equivalent.
a.Quantitative fit testing measurements will be performed as follows on the Fit
Tester 3000,or equivalent:
1)Input the employee's name, style ofrespirator and size
2)Select "perform fit test" - the computer program will then walk you
through a series of five tests.
3)During the testing program,the computer will evaluate the employee
4) If there is a failure during any test, the employee will adjust the respirator
and try again.
5)If after several attempts to pass a test and the employee still fails, try a
different size respirator
6)Once the employee passes each of the five tests, a document will be
printed certifying the successful completion of the examination
7) The document will then be signed by both the employee and the facilitator
of the examination
8) The document will then be filed with the employee's other safety
documents in the Radiation Safety Department"
31.Ifa respirator user is allowed to keep their respirator longer than a day,explain the mills
procedure to check if respirator users are clean shaven.
Denison Response:
Please refer to Item 29.Employees are no longer allowed to have a respirator for more
than one day.
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32. Provide examples ofthe forms used to document the Mills Respiratory Protection
Program.
Denison Response:
See attached Exhibit G,which contains examples of the forms used to document the
Mill's respiratory protection program.
33.Explain why swipe samples are not taken on respirators to evaluate removable alpha
contamination.
Denison Response:
Section 2.3.3.1 of the Mill's Radiation Protection Manual currently requires that
respirators are monitored using a sensitive alpha meter.
However,Denison agrees that it would be an improvement to perform removable surveys
on cleaned respirators.Therefore,a removable survey on all respirators being cleaned
will be performed.Changes to Book 14-Respiratory Protection Program,under 2.9.1
and Book 9 -Radiation Protection Manual,under 2.3.3.1 will be made to mirror NRC
Reg. Guide 8.30 Section 2.10.
34.Explain how the respirator technician, who issuers] respirators, knows if someone has
met all ofthe prerequisites (i.e.fit test,respirator training,and medical clearance)and is
authorized to wear a respirator.
Denison Response:
It is the practice ofDenison that all new hire employees must receive medical clearance
prior to attending new hire orientation.If an employee is not able to obtain medical
clearance, for health reasons,then Denison will make a determination ifthat individual is
suitable for a position that does not require the use of a respirator. As part of new hire
orientation,every employee who is to work in the Mill process (i.e.maintenance,
operation, utility, and radiation/safety)must also be fitted prior to proceeding to the on-
the-job portion ofthe orientation.
The fit test given during the orientation is a quantitative test and will determine the size
of the device the employee needs to wear. This information is located in the
Radiation/Safety Department personnel files and can be accessed by the technician to
determine the proper size.
At the beginning ofeach year, and on initial hire,spirometry examinations are gathered
on all employees who could potentially need to don a respirator. Also, at the beginning
of each year, annual fit testing is performed on all employees.
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So, during the year,ifan employee needs a respirator,the technician knows that the
employee has been cleared for use of the device. Office personnel,such as administrative
assistants are not authorized to wear respiratory protection because they are not classified
as individuals authorized to work in areas that could require the donning of such a device.
If there is any change in the status of any employee,that information is relayed to the
Radiation/Safety Staff and that individual is blocked from being allowed to use such a
device until the change in status has been addressed.
35. Explain how the Chain ofCustodies for air monitoring andenvironmental monitoring are
being kept as part ofyour record keeping system.
Denison Response:
All Chain-of-Custody (COC)forms consist of a three part color coded document.The
white copy is the original form and accompanies the samples throughout the process.It
is returned by the laboratory to the Mill, with all signatures,along with the final
analytical report from the laboratory.The yellow copy accompanies the samples but is
maintained by the contract laboratory for its records.The pink copy does not accompany
the shipment.It is maintained by the Mill for its records, to indicate collection and
shipment of the sample.
The COC records for a sampling event are maintained in a yearly file in the Mill
department that was responsible for the sampling event. At the end of the year, the files
are transferred from the responsible department to the Radiation/Safety Department for
longer term storage.
36. Provide all revisions to procedures and programs that have been added or revised since
February 2007 License renewal application was submitted.Also provide all procedures
andprograms that were not included with the February 2007 License renewal
application.
Denison Response:
As mentioned in Item 28 above, Denison does not consider all of its standard operating
procedures to be a part of the 2007 License Renewal Application.Only those standard
operating procedures included with the 2007 License Renewal Application,together with
the two standard operating procedures included with this letter as Exhibits C and D
should be considered to form part of the 2007 License Renewal Application (the latter
two standard operating procedures include provisions that relate to the release of
equipment from the site and are referred to in other procedures included with the
application,and should properly have been included with the application.Their omission
was an oversight on the part of Denison). The remainder ofthe standard operating
procedures,however,relate to Mill operations, are not part ofthe public record, and are
maintained at the Mill for inspection at any time by the Executive Secretary.
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It is a requirement of the Mill's Safety and Environmental Review Panel,No.:PBL-l
Rev. No.: R-4 procedure that the Mill's SERP may make changes to procedures
presented in the license renewal application,provided certain conditions are satisfied and
steps followed.Section 5.0 (3)of that procedure requires the Mill to submit an annual
SERP report to the Executive Secretary within 60 days after the end ofeach calendar
year,together with any pages of the license renewal application that have been changed
by any SERP actions throughout the year.The annual SERP report for 2008 is due to be
filed with the Executive Secretary on or before March 2,2009.Denison proposes to
provide the Executive Secretary with any revisions to the standard operating procedures
that are included with the 2007 License Renewal Application that were made during
2008,at that time.Any such changes made in 2007 would have been included with the
annual SERP report for 2007.
This is one reason why Denison does not consider all of the Mill's operational SOPs to be
a part of the 2007 License Renewal Application.It would be impractical,and Denison
believes of little benefit to the Executive Secretary,for Denison to submit every change
to every procedure to the Executive Secretary every year.While it makes sense for the
Executive Secretary to have annual updates to the key SOPs that have health,safety or
environmental protection implications,it is not realistic for the Executive Secretary to try
to have an up-to-date copy of every Mill procedure.The Mill cannot keep a full set ofits
SOPs up-to-date with the Executive Secretary.For the operational procedures,and all
other SOPs,up-to-date copies are maintained at the Mill on a real-time basis and are
available for inspection at any time by the Executive Secretary.
If you should have any questions or require additional information,please contact the
undersigned.
Yours very truly,
DENISON MINES (USA)CORP.
By:if
David C.Fr denlund
Vice President,Regulatory Affairs and Counsel
cc:Ron F.Hochstein
Harold R.Roberts
Steven D.Landau
David E.Turk
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