DRC-2008-002121 - 0901a0688025aa80

State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
JON M H^SMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
RC
MEMORANDUM
TO: roC02 .06 (1st Quarter 2008 Radiation Safety Inspection)
THROUGH: John Hultquist
FROM:
DATE:
Kevin Camey
April 2, 2008
SUBJECT: Denison Mines WM
On March 26, 2008, Inspection Module RADMOD-ALARA-04 was performed at the
Denison Mines White Mesa Mill, located near Blanding, Utah, hy Ryan Johnson and Kevin
Camey representatives of the Utah Division of Radiation Control (DRC). The inspection focused
on the mill's Annual ALARA Report, SERF Committee and the radiological instrumentation and
respiratory protection programs. In addition, other observations were made during the visit. The
inspection was unannounced and consisted of documentation review, field observations, and
interviews with selected personnel. David Turk, the Site Radiation Safety Officer, was unavailable
during the visit. The DRC inspectors were assisted by Ronnie Nieves and Mike Spillman of
Denison Mines and we were afforded every courtesy during the inspection. Photos were taken at
the facility during the inspection and are available for viewing at: <U:\rad\COMMON\Uranium
millsM le(2)UTl900479 Denison Mines - White Mesa UMill\Photos\White Mesa 3-2008>. A
discussion of the inspection and noted deficiencies are summarized as follows:
Annual ALARA Report
The inspectors reviewed the 2006 Annual ALARA Report that was subniitted May 10^ 2007. The
2007 Annual ALARA Report was under review and is expected to be available in April or May,
2008.
• The Inspectors examined the report for included personnel bioassay results. Section 18 of
the report summarized these bioassay results and noted that three (3) results were in the
20-30|Lig/L range. At that time, urinalysis was being performed by the Mill. The
individuals were re-tested and the samples sent to an outside laboratory. All subsequent
results were <5|ig/L. Mr. Nieves informed the Inspectors that all samples are currently sent
168 North 1950 West • PO Box 144850 - Salt Uke City, UT 84114-4850 - phone [phone] - fax [phone]
T.D.D. {m) 536A4\4 'www.deq.utah.gov . ;
Page 2
to an outside laboratory and that the Mill no longer analyzes urine samples. Mill
management attributes the initial elevated results to possible cross-contamination due tor
mishandling of the samples by Mill personnel. Although the Inspectors did not perform a
detailed investigation of this incident, the Mills conclusions appear to be reasonable in
light of the results from re-testing of the involved individuals.
• The Inspectors examined the report for the included list of procedures that were reviewed
during the report period. Section 5 of the report provides a list of reviewed procedures. A
total of twenty-one (21) procedures were reviewed covering Operations, Security,
Transportation, Safety, Environmental Monitoring, Disposal, SERP and Radiation
Protection. The list included recommendations for improvements to the listed procedures.
No target dates for when these improvements would be implemented were given.
• The Inspectors examined the report for recommendations on ways to reduce personnel
exposure from uranium and its daughters. The recommendations are listed in Section 23.3
of the report. However, the Hst is an exact copy of the list of procedures that were
reviewed during the report period in Section 5 of the report noted in the paragraph above.
Recommendation
The inspectors recommend that the Mill put forth the effort to specifically identify areas and make
detailed proposals on how to reduce exposures. Although the Mill generally sees exposures well
below applicable limits, effort must be made to pursue ways to reduce exposures further. This is
key to a sound ALARA program. The inspectors also recommend the Mill include a date when
they come up with recommendations for improvement lists based on their review.
SERP
Near the end of the inspection, the inspectors were given the documentation ofthe last three SERP
Committee meetings. These documents were: SERP No. 2007-01, SERP No. 2007-02 and SERP
No. 2007-03. The documents were reviewed to verify that the SERP committee included the
personnel required by Radioactive Materials License #UT 1900479, License Condition 9,4 C. The
committee included:
• David Turk, Mill RSO;
• Rich Bartlett, Mill Manager;
• Harold Roberts, Executive Vice President U.S. Operations;
• David Frydenlund, Vice President and General Counsel; and
• Steven Landau, Manager, Environmental Affairs.
These members are appropriate as per the License Condition.
Instrumentation
• Radiation Instruments
The inspectors reviewed documentation to verify radiological instrument calibrations and
performed field observations of instruments currently in use in the mill. The calibration
certificates, (calibrations are performed by Ludlum Measurements, Inc.), were in order and
the calibrations were performed in accordance with Ludlum procedures, satisfying License
Condition 9.6 which requires calibration procedures be established. However, during field
Page 3
observations, it was found that three (3) in-service field instruments had probes which had
the serial numbers wom off, making it impossible to tell whether the attached probe was
the one the instrument was calibrated with. Two of the instruments were alpha detectors
used for persormel exit monitoring and one was a dose rate instrument used for releasing
vehicles from the restricted area.
A follow up call was made to Ludlum Measurements Calibration Shop Manager Kent
Boatright to inquire as to how the probes without legible serial numbers were handled
when documenting the numbers for the calibration certificates. Mr. Boatright informed me
that a new serial number is given to the probe preceded by the letters RN, denoting
'Replacement Number'. This number may be placed on the probe either using a laser
printed label or by simply adding it to the existing label with a permanent marker.
However, the markers are usually less than permanent or, depending on the location of the
laser printed label, the number will again wear off
Recommendation
The DRC and Ludlum Measurements both recommend that Denison Mines permanently etch the
serial numbers onto all probes by the use of an engraving tool. This will assure the serial numbers'
durability and preclude Ludlum Measurements from having to re-number the probes during
calibration.
• Air Samplers
The inspectors requested calibration certificates for three (3) randomly selected general
area air samplers. Mr. Nieves, one of the technicians who perform the calibrations,
informed the inspectors that these documents do not exist. The Mill's Radiation Protection
Manual, Section 3.0, Equipment/Calibration, provides an example of the 'Area Air
Sampler Calibration Record'. This form is for use when air samplers are calibrated using
the Wet Gas Meter method. However, the generally used method for calibrating area air
samplers at the Mill is the Bubble Tube Calibration Method. The inspectors were told that
the calibration of area samplers is only documented on the form: 'Pump Calibration for
Area Airbomes', (a copy of the latest form is attached at the end of this memo). The form
consists of three (3) columns: Pump No., Date and Name. The name column lists the flow
rate the pump was calibrated to and the technician's initials. The pumps have been given
number designations 1 through 5. There are no serial numbers listed on the form
associated with these pumps, so there is no way to verify their calibration. No
documentation is kept to verify that the calibration was performed correctly. No record of
repairs made or parts replaced are maintained.
In the letter to Mr. David C. Frydenlund, Vice President and General Council, dated
November 19, 2007, the DRC outlined findings from a previous inspection on October 16
and 17, 2007. One of the findings and associated recommendation was: "The calibration
documentation for both breathing zone and area air samplers is inadequate in its detail of
the calibration process. The DRC recommends that the licensee develop calibration
documents that are reviewable for compliance with calibration procedures."
Page 4
Recommendation
The White Mesa Mill needs to develop an air sampler calibration certificate for any and all
methods of calibration performed at the Mill so that pertinent information can be recorded. This
form should be completed for each calibration performed and the actual pump serial number as
well as the assigned number should be documented on the form.
Respiratory Protection Program
The inspectors reviewed documentation associated with respirator use at the Mill and conducted
interviews with Donnie Nieves, Abel Mendoza and Mike Spillman. Through this process, it was
concluded that the Respiratory Protection Program is inadequately administered as summarized
below:
• Medical surveillance and fit test records were in place although the personnel interviewed
could not produce proper training documentation for respirator users. It was stated by Mr.
Nieves and Mr, Mendoza that the users are instructed on proper respirator usage at the
time of their fit test. Appendix L, Respiratory Protection Program, Section 2.3 outhnes the
curriculum to be followed for respirator user training. Regulatory Guide 8.15 Section 5.2
outlines the requirements for training of respirator users prior to fit testing of face-sealing
respirators and lists the minimum requirements for training. This is considered by the
inspectors to be a violation of requirements of the Respiratory Protection Program.
• Mr. Mendoza, who is responsible for maintenance, repair and issuance of respirators at the
Mill, stated that there are no procedures associated with these duties. He and Mr. Nieves
also stated that there had been no formal training given to Mr. Mendoza prior to
performing these duties and that no formal training program exists. Appendix L,
Respiratory Protection Program, Section 2.9.1 states: Respirators shall be inspected in
accordance with NRC Regulatory Guide 8.15. Section 4.4 of Reg Guide 8.15 states:
Respirators and component parts of respiratory protection devices should be maintained
and repaired only by persons specifically trained to perfoim this work. Section 4.6 states:
Records of all the required activities in a respirator program should be kept in a manner
that shows compliance with the requirements of the applicable regulations. Section 3.2
states: According to 10 CFR 20.1703, written procedures must be in place. These
procedures should address and implement the following respiratory protection program
elements: Bullet #3 - Training and minimum quaUfications of respirator program
supervisors and implementing personnel; Bullet 10 - Maintenance, repair, testing, and
quality assurance of respiratory protection equipment. This is considered by the inspectors
to be a violation of requirements of the Respiratory Protection Prograni.
• Mr. Mendoza stated that personnel who use their respirators often, (i.e., personnel that
work in the yellowcake dryer), exchange their respirators weekly and that more infrequent
users exchange respirators when the filters or respirator fail to function properly.
Appendix L, Respiratory Protection Program, Section 2.8 states: The frequency that a dirty
respirator must be exchanged for a clean one will be determined by the amount of time it is
used. If the employee's use is greater than four hours per day, the exchange will be made
daily. Occasional use will require a weekly exchange. Infrequent use will require monthly
exchanges. This is considered by the inspectors to be a violation of requirements of the
Respiratory Protection Program.
Page 5
Recommendation
The inspectors recommend that the DRC issue a Notice of Violation (NOV)V Severity Level III
based on overall performance of the Mill in implementing the Respiratory Protection Program.
Other Noted Observations
1) Altemate feed materials contained in Supersacks that are stored on the ore pad have been
damaged after having been consohdated on the pad using heavy equipment. During the
inspection, the material appeared dry and no water suppression had been applied to the
material, only to the ore pad surface adjacent to the pile (see picture below). Mr. Spillman
informed the inspectors that the Mill will soon be processing uranium ore only and that
altemate feed materials will most likely remain on the ore pad for an extended period of
time. The Mill may process small amounts of altemate feed materials along with the ore,
but no plans for this have been finalized. The Environmental Protection Manual Section
3.3(3), requires dust control (water appHcation) on roadways. Dust control of the pre piles
is performed only if dusting is observed during transfer to the Grizzly. Weekly inspections
ofthe stockpile area are conducted to evaluate the effectiveness of dust control measures.
Page 6
Recommendation
The inspectors recommend that the Environmental Protection Manual Section 3.3(3) be revised to
include routine dust suppression on openly stored altemate feed materials on the Ore Pad.
Alternately, the openly stored altemate feed niaterial should be more frequently monitored or
covered to minimize dust dispersion during windy conditions. In either case, the inspectors
strongly recommend that the Mih install an environmental air monitoring station near the
boundary of the Ore Pad on the prevailing downwind side to evaluate the effectiveness of dust
control on the pad.
2) During the inspection, work to remove sludge firom the 100' Thickener Tank was
observed. Several observations pertaining to this job were noted:
o The RWP for this job called for the wearing of a 'mbber suit' as well as coveralls.
The Bobcat operator working inside the tank was not wearing the required 'mbber
suit'over his Tyvek^ coverahs (see picture below).
0 The opening through which the sludge was being transferred was not posted in any
way to alert personnel to the elevated hazard or PPE requirements inside the tank
(see picture below).
o Used PPE was left unbagged near the exit of the job site (see picture below),
o The RWP, Safe Work Permit and Confined Space Hazard Evaluation appear
incomplete.
Page 7
Recommendation
The Mill needs to demonstrate diligence in providing protection of their workers and, contractors
when special projects are undertaken. Work permits need to be completed prior to commencement
of the operation and technicians should be attentive in the oversight of these projects to ensure
workers'compliance arid commitment to safety.
3) Several workers at the guard shack access point were observed frisking improperly upon
exit from the restricted area. This included both surveying too fast and surveying with the
probe at a distance too far from the surface to adequately detect alpha contamination. The
inspector informed the Rad Tech in the area who then instmcted the workers to properly
resurvey.
Recommendation
Radiation Technicians at the Mill need to convey to workers the importance of monitoring prior to
exiting to ensure that radioactive material is not being removed from the site. Performance at the
Mill in this area has demonstrated a somewhat relaxed attitude. Workers need to be reminded of
the hazards of radioactive materials and should be held accountable for poor Health Physics
practices.
Summarv
The closeout meeting included Ryan Johnson and Kevin Camey ofthe DRC and Mike Spillman
and Ronnie Nieves of the White Mesa Mill. The discussion included the findings pertaining to the
inspection module and other nbted observations at the Mill during the inspection. Mr. Spillman
informed the inspectors that he would address the postings at the Thickener Tank immediately and
Page 8
instmct Rad Techs to be more diligent in identifying and correcting improper persormel frisking
practices. Additional documentation requested by the inspectors at this meeting has been received.
PUMP CALIBRATION FOR AREA AIRBORNES
(cal. at 40L/m)
Pump No. Date Name Pump No. Date Name
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UTAH DIVISION OF RADIATION CONTROL
Inspection Module RADMOD-ALARA-04
White Mesa Uranium Mill
Denison Mines RML # UT1900479
OPENING MEETING
INSPECTOR(s) Kevin Camev/Rvan Johnson . DATE
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Camey Utah DRC [e-mail]
Ryan Johnson Utah DRC [e-mail]
if\Aik^6'^idi/^
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UTAH DIVISION OF RADIATION CONTROL
Inspection Module RADMOD-ALARA-04
White Mesa Uranium Mill
Denison Mines RML # UT1900479
OPENING MEETING
MEETING MINUTES
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SITE STAFF COMMENTS
UTAH DIVISION OF RADIATION CONTROL
Inspection Module RADMOD-ALARA-04
White Mesa Uranium Mill
Denison Mines RML # UT1900479
CLOSEOUT MEETING
INSPECTOR(s) Kevin Camev/Rvan Johnson DATE 3/^^/^<
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Camey Utah DRC [e-mail]
Ryan Johnson Utah DRC [e-mail]
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UTAH DIVISION OF RADIATION CONTROL
Inspection Module RADMOD~ALARA-04
White Mesa Uranium Mill
Denison Mines RML # UT1900479
CLOSEOUT MEETING
DISCUSSION of FINDINGS
' / ^lA>c^JiC^^^uCr>^o^^ t^gjgi^ €:n<^ .
SITE STAFF COMMENTS
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-ALARA-04
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Radioactive Materials License UT1900479, NRC Regulatory Guide 8.31, License Renewal
Application Appendix L, Utah Administrative Code R313-15.
Annual ALARA Report
License Condition 11.6 requires the Licensee to perform an annual ALARA audit of the radiation
safety program in accordance with NRC Regulatory Guide 8.31.
1) Has the licensee submitted an annual ALARA report as required?
Yes ^ No
Date Submitted: f^(0( ^^^7
Comments: ^ ^ /f ^
2) Has the licensee included personnel bioassay results?
Yes No
Comments: " - - ^
dl^.^c^. f't^ ^o>ik^
3) Has the Hcensee included a Hst of procedures that were reviewed during this time period?
Yes ^ No
Comments:
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Page 1 of 5
4) Did the licensee include recommendations on ways to reduce personnel exposures from uranium and its
daughters?
Yes / No
Comments* ^ /) ' / *
r:imi^ ^ 5c^^^ L
SERP
License Condition 9.4 Section C requires the formation of a Safety and Environmental Review
Panel (SERP).
5) Did the SERF include the minimum 3 members?
Management/Financial
Operations/Constmction
Corporate Radiation Safety Officer (CRSO) or equivalent
Other Member (Titie) /IVL/^/FC^^ - ^A^t^. vd^i ArS
Other Member (Titie) V/ f / (^<j^n^^[
Other Member (Title)
Yes No
Yes \/ No
Yes No
Yes ^No
Yes \/^No
Yes No
Comments
U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines- White Mesa UMillXHP Inspection Modules\RADMOD-ALARA-04.doc
Page 2 of 5
Instrumentation
License Condition 9.6 requires that written procedures shall be established for non-operational
activities to include instmment calibrations. License Condition 11.1 requires that the results of
calibration of equipment be documented. License Condition 11.5 requires that in-plant air
sampling equipment shall be calibrated at least quarterly and air sampHng equipment checks shall
be documented.
6) Does the licensee have radiological instmment calibration procedures in place?
Yes / No
Comments:
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7) Has the licensee provided proper documentation of the results of calibration for the following
radiological instruments? / ^ / n \ ^ i m^L
Instrument L- ^ / S/N /r^S^^y/m^^^H^^^Yes V No /^/f'f/^?
Instmment L-Hl / HZ ^^ S/N J^l^/mlf^C- Yes ^ No ^ ^ ^^("^ ^
Instmment Z-r 77 / M'^"^ S/N Hu^^lf Pl^\ip+'^ Yes No 12-/3/
Cornments: ,
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8) Has the licensee provided proper documentation of the results of calibration for the follpwing in-plant
air sampling equipment?
Air Sampler S/N Yes No_
Air Sampler S/N Yes No_ \
Air Sampler __________ S/N _________ Yes No.
Comments
U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMilI\HP Inspection Modules\RADMpD-ALARA-04.doc
: Page 3 of 5
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Respiratory Protection
License Renewal Application Appendix L Sections 1.0, 2.3 and 2.4 describe the requirements for
respirator users' medical evaluation, training and fit testing, respectively. Section 2.9 requires
respirator maintenance and repair personnel be specifically trained for this task. Section 1.3
requires that employees who may at any time be required to wear a respirator will not have any
facial hair that will restrict the proper fitting of a respiratory device.
9) The licensee shall provide a list of four respirator users.
Do the following users meet the requirements of Sections 1.0, 2.3 and 2.4?
User Name Medical Training Fit Test
Jp^^ ^y/y.^ Yes No Yes No ^ Yes ^ No
J^Jf:^^^ l^udkp^ Yes ^ No. Yes No ... Yes ly-'^^o
^ Yes ^ No Yes No Yes '^"'"NO
/l^-fJA^^^ PlU'yyf- Yes ^ No Yes No ^ Yes ^' No
Comments:
— • ^—^
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10) Has the Hcensee provided documentation for training of personnel responsible for respirator
maintenance and repair?
Yes No_
Comments;^
U:\rad\COMMON\Uranium millsM Ie(2)UTl900479 Denison Mines - White Mesa UMillVHP Inspection Modules\RADMGD-ALARA-04.doc
Page 4 of 5
11) Of the respirator users observed, did any have facial hair that would restrict the proper fitting of a
respiratory device?
Yes _No .
Comments: . " . ,
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Page 5 of 5
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1 Complete items 3, 4a, and 4b. • Print your name and address on the reverse of this form so that we can return this
card to you. • Attach this form to the front of the mailpiece, or on the back if space does not
permit. a Write "Return Receipt Requested" on the mailpiece below the article number.
aThe Return Receipt will show to whom the article was delivered and the date
RE: NOV Dated 4/29/2008 and Enforcement Conf ,
Held 5/27/2008 at the White Mesa Mill FacilitY- RMLl
UT1900479/JH I' — —
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following services (for an
extra fee):
1. n Addressee's Address
2. • Restricted Delivery
Consult postmaster for fee.
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DENISON MINES (USA) CORPORATIOrij i fleceipt for Mliehandise 0 000
1050 17TH STREET STE 950 ^ ' '
DENVER CO 80265
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U.S.Tostal Service
CERTIFIED MAIL RECEIPT
(Dqrhestic Mail Only; No Insurance Coverage Provided)
\ 7000 2670 OOOO 0086 2778 - Date; 6/13/2008 i
'^DenisoLMin^JUmiCoro^^^^^ ' '
ATTN DAVIDC FRYDENLUND
VICE PRESIDENT AND GENERAL COtiNCIL
DENISON MINES (USA) CORPORATiqiV
1050 17TH STREET STE 950
' DENVER CO 80265
street, Apt. No.; or PO Box No.
City, State, ZIP+4
: PS- Form. 3800, February 2000 .See Reverse for Instructions
State of Utah
Department of
Envirorunental Quality
Richard W. Sprott
Executive Director
Division of Radiation Control
Dane L. Finerfrock
Director
JON M. WPfTSMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
June 13, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUIRED
David C. Frydenlund, Vice President and General Council
Denison Mines (USA) Corp.
1050 17th Street, Ste 950
Denver, CO 80265
Subject: Notice of Violation Dated April 29, 2008 and Enforcement Conference Held May 27,
2008 at the White Mesa Mill Facility - Radioactive Material License UTI900479
Dear. Mr. Frydenlund:
This letter is regarding the enforcement conference held on May 27,2008 and the Notice of
Violation dated April 29, 2008. Based on the Division of Radiation Control's (DRC) review of the
Notice of Violation (NOV) and the discussion held during the enforcement conference with you
and Dave Turk, Site Radiation Safety Officer (SRSO), the DRC will withdraw the violation.
However, we request you perform an in-depth review ofthe respiratory protection program with
emphasis on the control and issuance of respirators, repair and maintenance of respirators, user
training and the documentation of the training.
If you have questions conceming this letter, please contact Mr. John Hultquist at 801-536-4250.
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
DLF/JDH:jh
168 North 1950 Wesf PO Box 144850 • Salt Uke City, UT 84114-4850 • phone [phone] • fax [phone]
T.D.D. {^0\) 536-44]4'www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
Department of
Envirormiental Quality
Richard W. Sprott
Executive Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
JON M. J^prSMAN, JR.
Govemor
GARY HERBERT
Lieutenant Governor
MEMORANDUM
TO: File: 1^^ quarter 2008 Radiation Safety Inspection
THROUGH: John Hultquist
FROM: Ryan Johnson J0
DATE: June 12, 2008
SUBJECT: Denison Mines White Mesa Mill: Radioactive Materials License (RML)
UTI 900479
On March 26, 2008 representatives of the Division of Radiation Control (DRC) conducted an
inspection of the Denison Mines White Mesa Mill facility (the mill) located near Blanding, Utah.
During this inspection deficiencies were identified with the mills Respiratory Protection Program
and the DRC issued a Notice of Violation (NOV) dated April 29, 2008. The Licensee responded
to the NOV by telephone and discussed the NOV with the Executive Secretary. On May 12, 2008
a conference call was held with the Licensee, the Executive Secretary, DRC Inspectors and
Section Manager. In this call it was decided that an Enforcement Conference was necessary to
discuss the deficiencies outlined in the NOV. May 20, 2008 was originally scheduled for the
Enforcement Conference in Salt Lake City but due to scheduling conflicts mill officials were
unable to attend and the Enforcement Conference was rescheduled for May 27, 2008 at the mill
just prior to the next DRC inspection.
On May 27, 2008, an Enforcement Conference was held between representatives of the DRC and
members ofthe mills management to discuss deficiencies outlined in the NOV. The following
individuals were in attendance:
John Hultquist
Kevin Camey
Ryan Johnson
Dave Turk
David Frydenlund
DRC Section Manager
DRC Inspector
DRC Inspector
Mills Radiation Safety Officer (RSO) ^
Mills Vice President of Regulatory Affairs & Counsel.
Discussions during the Enforcement Conference focused on miscommunication problems that
168 North 1950 West • PO Box 144850 • Salt Lake City, UT 84114-4850 • phone [phone] • fax [phone]
T.D.D. (SOl) 536-44\4'www.deq.utah.gov
Page 2
occurred between the DRC Inspectors and the mills Radiation Safety staff. The mills RSO was
out of town and unable to assist the DRC Inspectors during the March 26, inspection. Therefore,
the Licensee argued that Radiation Safety staff did not fully understand the questions that DRC
inspectors were asking and were unable to provide the proper documentation or respond to the
questions with the correct answers. At this time the RSO provided the documentation that the
inspector was looking for and further explained that his staff uses different terminology to identify
procedures and other documentation and that is why his staff did not provide these documents or
answer his questions correctly. The DRC recommended that the RSO provide fiirther training to
his staff to minimize future miscommunication problems. The Licensee requested that fiature
inspection be announced so appropriate staff are available during the inspection. The DRC
representatives indicated that inspections will be either announced or unannounced and that the
expectation is that appropriate staff should be on site at all times.
In conclusion, due to the fact that the missing documentation was provided during the
Enforcement Conference, and the RSO agreed to train his staff in an attempt to minimize fiiture
miscommunication problems the NOV should be rescinded. Additional follow up regarding
procedure implementation and staff training on the procedures will be performed by DRC
inspectors during fiiture inspections.
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'4/29/08 RML UT 1900479 RADIATION SAFETY INSPECTION Jt
y ( Printed Name)
MODULE RADMOD-ALARA-04 RECOMMENDATIONS & NOVIivery addre^:dj|^n|fRm item 1?
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0. Date of Delivery
li
MR DAVID FRYDENLUND
VICE PRESIDENT AND GENERAL COUNSEL
INTERNATIONAL URANIUM (USA) CORPORATION
INDEPENDENCE PLAZA STE 950
1050 SEVENTEENTH STREET
DENVER CO 80265
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PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
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4/29/08 RML UT 1900479 RADIATION SAFETY INSPECTIOI^
MODULE Fj^ADMOD-ALARA-04 RECOMMENDATIONS & NOV
MR DAVIDjFRYDENLUND
VICE PRESIDENT AND GENERAL COUNSEL
INTERNATIONAL URANIUM (USA) CORPORATION
INDEPEND|ENCE PLAZA STE 950
1050 SEVENTEENTH STREET
DENVER CO 80265
maintenance.
personnel, verifying frequency of use and assuring respirators are being exchanged in a
timely manner as per the Mill's Respiratory Protection Program.
• Quahty Assurance; developing a sound written Respiratory Protection Quality Assurance
Program.
It was noted that not all of your activities were conducted in compliance with State requirements.
To aid you in correcting these non-compliant activities, a Notice of Violation is enclosed that
describes each problem. Please continue to remember that radiation safety is the responsibility of
the licensee.
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
T.D.D. [phone] • www.deq.utali.i^ov
PAGE 2 168 North 1950 We.st • PO Box 144850 • Salt Lake City, UT 841 14-4850 • phone [phone] • fax [phone]
Prinled on 100% recycled paper
UTAH RADIATION CONTROL BOARD
NOTICE OF VIOLATION
Denison Mines (USA) Corp.
1050 Seventeenth Street Suite 950 License Number UT1900479
Denver, Colorado 80265
During an inspection conducted by representatives of the Utah Division of Radiation Control, on
March 26, 2008, a violation of the Utah Radiation Control Rules was identified. Violations are
prioritized according to Severity Levels, with Severity Level V being the least significant. The
particular violation of the Utah Radiation Control Rules is set forth below:
la. Utah Radiation Control Rule R313-15-703(3)(d)(vii) states: "The licensee or registrant shall
implement and maintain a respiratory protection program that includes...Written procedures
regarding...Storage, issuance, maintenance, repair, testing, and quality assurance of
respiratory protection equipment."
Contrary to this requirement, the licensee was unable to provide written procedures pertaining to
the storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protectiofi
equipment. Personnel who are responsible for maintenance, repair and issuance of respirators at
the Mill stated that there are no written procedures associated with these duties.
lb. Utah Radiation Control Rule R313-15-703(3)(d)(viii) states: "The licensee or registrant shall
implement and maintain a respiratory protection program that includes...Written procedures
regarding.. .Recordkeeping."
Contrary to this requirement, the licensee was unable to provide training documentation, for
respirator users. Personnel responsible for implementing the Respiratory Protection Program
stated that the users are verbally instructed on respirator usage at the time of their fit test.
This violation is characterized as a Severity Level IV. There is no civil penalty proposed for this
violation.
A written response is required within 30 days after receipt of this Notice. The following
information is required: (1) The corrective actions which have been taken and the results
achieved; (2) the corrective steps which have been taken to prevent recurrence; and (3) the date
full compliance will be achieved.
Any response or written answer to this Notice of Violation/Notice of Proposed Imposition of Civil
Penalty should be addressed to Dane L. Finerfrock, Executive Secretary, Utah Radiation Controt
Board, 168 North 1950 West, P.O. Box 144850, Salt Lake City, Utah 84114-4850. The licensee's
attention is directed to the Administrative Procedures set forth in UCA 63-46b. If a hearing is
requested, the Executive Secretary of the Utah Radiation Control Board will designate the time
and place of the hearing.
Dated at Salt Lake City, Utah
This 30 ^ day of April 2008
UTAH RADIATION CONTROL BOARD
Dane L. Finerfpock, Executive Secretary
T.D.D. {W\)53(i-44\4* www.deq.utah.iiov
PAGES 168Norlh 1950 West • PO Box 144850 • Salt Lake Cily. UT 84114-4850 • phone [phone] • fax [phone]
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