DRC-2008-002122 - 0901a0688025a9f4

State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executive Director
Division of Radiation Gontrol
Dane L. Finerfrock
Director
JON M. llppSMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
C ™ 2i XJ
June 6, 2008
David Frydenlund, Vice President
Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17'^ Street, Suite 950
Denver, Colorado 80265
RE: Radioactive Material License Number UTI 900479
Dear Mr. Frydenlund:
On May 28 and 29, 2008, two inspections were conducted at yaur facility by Ryan Johnson and
Kevin Camey, representatives of the Division of Radiation Control of the Utah Department of
Environmental Quality. Observations from the inspections were discussed with Dave Turk, Mike
Spillman, Rick Bartlett and yourself at the close out meeting.
The inspections were an examination of the activities conducted in your facility as they relate to
compliance with the Utah Radiation Control Rules and the conditions of the Hcense. The
inspections consisted of selective examinations representative records, interviews of personnel,
and observations by the inspectors.
During this inspections, the inspectors identified multiple items that require your attention. The
particular areas of improvement are set forth below:
1. Respirator usage; respirators are to be exchanged for cleaning and maintenance as
specified in the site's Respirator Protection Program found in Appendix L ofthe 2007
License Renewal Application. Specifically, if a respirator is used for more than 4 hours^in
a day than it needs to be exchanged daily.
2. The information and documents that are outlined in UAC R313-18 ''Notice to Workers"
need to be posted on the two bulletin boards in the hallways of the main office building.
3. Control of employee dosimeters: several employee dosimeters were missing from the
boards on which they are kept. A few badges were missing from the board from employees
that are currently working at the mill who did not retum them at the end of their shift.
Employees need to follow procedures outlined in Appendix E (Radiation Protection
168 North 1950 West • PO Box 144850 • Sah Lake City, UT 84114-4850 - phone [phone] • fax [phone]
T.D.D. [phone] • www.i/e^.w/a/7.gov
Printed on 100% recycled paper
Page 2 .
Manual) sectionl.3.1 Monitoring Procedures: stateis that all dosimeter badges are to remain
at the mill. In Appendix I (ALARA Program) section 2.3.1 Daily Inspections: states that
storage areas will be inspected, there needs to be more emphasis on the dosimeter storage
boards to identify missing dosimeter badges.
4. Yellowcake and other materials that are spilled in the mill need to be cleaned up
immediately as defined in Appendix F (Ore Receiving, Feed & Grind) and Appendix G
(Yellowcake Precipitation). According to these procedures, mill operators are supposed to
be looking for spills as part of their job.
5. Training procedures; outlines and other documentation used for Radiation Safety Training
and Respirator Protection Training need to closely follow NRC Reg. Guide 8.31 for
Radiation Safety and NRC Reg. Guide 8.15 for Respiratory Protection. In addition, the
Respiratory Protection Program needs a separate exam for employees to pass.
6. New employees should have a dosimeter issued to them prior to working inside the
restricted area. The DRC recommends either have extra dosimeters onsite to assign new to
employees or order them with rush delivery when they start, so when they are done with
their initial training they have their badge.
7. This inspector discussed the minor deficiencies regarding postings at gated entrances to the
restricted area of the Mill.
Please find enclosed the inspection reports regarding these inspections and continue to remember
that radiation safety is the responsibility of the Licensee. Thank you for cooperating in this
matter. If you have any questions conceming this letter contact Mr. John Hultquist 801-536-4250.
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
DLF/RJ:rj
Cc: David Turk, Site Radiation Officer
Enclosures
INSPECTION REPORT
Inspection Module: RADMOD-PEM-01
Inspection Location: White Mesa Mill, Blanding, Utah
Inspection Items: Exit Surveys, Routine Surveys and Radiological Postings
Inspection Dates: May 28-29, 2007
Inspector: Kevin Camey, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk, Dave Frydenlund
Goveming Documents: Radioactive Material License UT1900479; License Renewal Application
dated February 28, 2007: Radiation Protection Manual, Appendix E,
Sections 1 and 2; ALARA Program Manual, Appendix I, Section 2;
10CFR20; and Utah Administrative Code R313-15; 49CFR173.
Opening Meeting
The Opening meeting was held in the Administration Building conference room at 08:30 a.m. on
May 28, 2008. Present were: John Hultquist, Ryan Johnson and Kevin Camey of the Utah Division
of Radiation Control; Dave Turk (RSO), Dave Frydenlund (V.P. Regulatory Affairs & Counsel),
Mike Spillman (Safety Manager) and Rick Bartlett (Mill Manager) of Denison Mines; Doug
Mandeville, R.K. Wild and Andrea Ferkile of the Nuclear Regulatory Commission.
The inspectors informed the Denison staff that there would be two inspections conducted and
discussed the items that would be included in the inspections. The inspectors also requested
documentation necessary to aid in the inspections. The NRC staff was present to observe the
inspections performed by the DRC inspectors as a follow up to the 2007IMPEP review.
Inspection Summarv
Inspection included document review of personnel exit monitoring logs, routine alpha survey results,
weekly and monthly inspections and daily instrument checks. A walk-through inspection of the
facility included spot checks by the inspector for alpha contamination in several areas included on
the Mill's routine survey logs, verification of postings for radiation areas, airbome radioactivity areas
and radioactive material postings at mill entrances. Observations of personnel perfonning exit
monitoring at several Mill exit locations was also performed.
1 of Page 5
Findings
During observations of personnel exit monitoring, a vast majority of personnel did not properly
monitor. Improper monitoring included: surveying at a rate of speed too fast to sufficiently detect
alpha contamination, surveying at a distance from the body too far to detect alpha contamination and
failure to completely survey all surfaces (i.e., hands, clothing and shoes).
Inspection Items
Itemi EXITSURVEYS
The inspector observed personnel exit monitoring at three separate exits from the restricted area of
the Mill during the lunch break and again at the end of the work day. Approximately 6 workers were
observed exiting the lab area at lunch time and approximately 25 workers were observed at the
"guard shack" at 1700 hours while leaving the Mill facility. Two were observed at the west Admin
Bldg door during the day's activities.
The inspector verified that the alarm set-points for the exit monitors at the three main exits from the
restricted area were set to alarm within 500 to 700 dpm/lOOcm^ alpha.
The inspector reviewed exit monitoring logs to verify that personnel were logging out when exiting
the restricted area.
Deficiencies:
The Mill's Radiation Protection Manual, Section 1.2.3 step 3, states: "An individual monitors
himself by slowly passing the detector over their hands, clothing and shoes, including the shoe
bottoms, at a distance from the surface of approximately inch. An area that is suspected of
possessing any contamination (i.e. hands, boots, visible spotting/stain on clothing etc.) should be
carefully monitored by placing the detector directly on the surface and note the measurement."
Contrary to the above requirerrient, all of the individuals exiting at the guard shack monitoring point
failed to properly monitor before exiting the restricted area. Monitoring deficiencies included
surveying at a rate of speed too fast to sufficiently detect alpha contamination; surveying at a
distance from the body too far to detect alpha contamination; and failure to completely survey all
surfaces (i.e., hands, clothing and shoes). Some individuals violated one of the above criteria while
others violated all or a combination of the three.
Item 2 ROUTINE SURVEYS
The inspector performed a walk through inspection of the Mill and performed spot check fixed and
removable alpha contamination surveys at several places during the inspecti oh. These surveys were
performed in areas that are listed in the Mill's Radiation Protection Manual Table 2.3.1-2. The Areas
included: Maintenance Lunchroom Tables, Warehouse Office Desks, Chemical Laboratory Desks
and Change Room Lunch Tables. No contamination above background was found.
2 of Page 5 V
The inspector reviewed weekly routine survey documentation for the months of March, April and
May 2008. These surveys included areas that are listed in the Mill's Radiation Protection Manual
Table 2.3.1-2. Section 2.3.2 of the Mill's Radiation Protection Manual states: "Fixed and removable
alpha surveys are made at those general locations on the Table 2.3.2-1, "Alpha Area Survey
Locations." Surveys are completed weekly during production periods. During non-production
periods, only those areas designated by the RSO as authorized lunchroom/breaks areas are
monitored." The RSO verified to the inspector that the Mill has been in a "production period" for the
period that documents were reviewed. Table 2.3.2-1 is as follows:
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Lunch Tables
Maintenance Lunchroom Tables
Mill Office Lunchroom Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
All survey records were in order with the following exceptions:
• In lieu of documented surveys for the weeks of March 17-21,2008 and March 24-28,2008, a
letter was posted in the survey log book stating that the surveys were not performed due to all
three of the Mill's alpha survey instruments either out for cahbration or otherwise non-
operational. The RSO was interviewed conceming this situation and informed the inspector
that steps were being impleniented to prevent recurrence of this problem. The steps include:
staggering instrument calibration periods, purchasing additional alpha survey instruments
and/or temporarily utilizing one of the exit monitoring survey instruments to perform the
routine surveys.
• The 'Locker/Change Room and New Lunch Room' survey forthe week of March 30 to April
4, 2008 was missing from the survey logs. The RSO informed the inspector that he would
search the survey files and try to locate the survey. '
The inspector reviewed weekly and monthly inspection repoits. The Mill's ALARA Program,
Section 2.3.1, requires the RSO or designee to perform daily inspections throughout the Mill and
document the results on the Daily Mill Inspection form. Section 2.3.2 requires the RSO and Shift
Foreman or designees to perform weekly inspections throughout the Mill and document the results
on the Weekly Mill Inspection form.
3 of Page 5
No problems other than minor typographical errors were identified. These errors were brought to the
RSO's attention.
Deficiencies: None
Item 3 RADIOLOGICAL POSTINGS
Utah Administrative Code R313-15-902(1) requires that the hcensee post each radiation area with a
conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIATION
AREA" and 10CFR20.1003 defines a Radiation Areas as an area, accessible to individuals, in which
radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem
(0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the
radiation penetrates.
The inspector performed a walk through inspection of the Mill and performed spot cheek gamma
radiation surveys to verify Radiation Area postings and boundaries. The inspection also included
verification of Airbome Radioactivity Area postings and postings at the Mill entrances required by
Utah Rule R313-15-902(4) stating, "Any area in this mill may contain radioactive materials."
All Radiation Area postings were appropriately placed and no un-posted radiation areas were
identified. All Airbome Radioactivity Areas were appropriately posted including the Yellowcake
Drying and Packaging areas and the SAG Mill.
The inspector identified three gated entrances to the restricted area of the Mill site that were not
posted in accordance with Utah Rule R313-15-902(4). The RSO informed the inspector that he
would have the gates posted as soon as possible.
Deficiencies: None
Item 4 SHIPPING CONTAINER LABELING
As a follow-up to a previous concem involving shipping container labeling, the inspector looked at
several shipping containers that were loaded onto outgoing tmcks for transportation out ofthe Mill.
The containers were being shipped as 'Empty' containers subject to the requirements of
49CFR173.428. All containers were properly labeled in accordance with 49CFR173.428.
Deficiencies: None
Closeout Meeting
The closeout meeting was held in the Administration Building conference room at 1:00 p.m. on May
29, 2008. Present were: John Hultquist, Ryan Johnson and Kevin Camey of the Utah Division of
Radiation Control; Dave Turk (RSO), Dave Frydenlund (V.P. Regulatory Affairs & Counsel), Mike
Spillman (Safety Manager) and Rick Bartlett (Mill Manager) of Denison Mines; Doug Mandeville,
R.K. Wild, Andrea Ferkile and Linda McClain of the Nuclear Regulatory Commission:
4 of Page 5
The inspectors informed the Denison Mines staff of the results of the inspections performed and
recommendations for improvement to the Mill's various radiological safety programs. This inspector
discussed the minor deficiencies identified pertaining to documentation, instrumentation issues and
postings at gated entrances to the restricted area of the Mill.
The inspector also discussed the finding related to personnel exit monitoring with the Mill staff.
Conclusion and Recommendations
The inspector is satisfied with the corrective actions cited by the Mill's RSO pertaining to the gate
signs and the weekly routine alpha surveys. However, the deficiencies in exit monitoring
demonstrated by Mill personnel are of significant concem. These deficiencies seem to be the status
quo among Mill personnel and in no way sufficiently demonstrates that no radioactive material is
being removed from the Mill in the form of personnel contamination. During a previous inspection
conducted at the Mill by DRC inspectors in October 2007, personnel were observed leaving the
restricted area without properly scanning. A Notice of Violation was issued to the Mill and a letter
dated November 28, 2007 from David Frydenlund of Denison Mines was sent to the Utah DRC
outlining corrective actions to circumvent recurrence of improper exit monitoring. Listed among the
corrective actions were, "On October 17, 2007, the RSO held a special training session for all Mill
employees relating specifically to this NOV and proper compliance with all scanning procedures."
"Reminding all employees that, as part of their new hire training, they signed an acknowledgement
that they had received training on proper scanning procedures and that failure to comply with these
procedures is cause for disciplinary action." The letter also states, "The Mill RSO and Mill Manager
have been reminded that strict adherence to scanning procedures and requirements is expected and
that it is incumbent upon them and other Mill management to ensure that the proper compliance
culture is maintained at the site." The inspector recommends a Severity Level EI Notice of Violation
with a base civil penalty of $2,500.00 be imposed.
Recommendation for Next Inspection
1. Observe exit monitoring at restricted area exits to verify compliance.
2. Inspect Mill entrances to ensure proper postings.
3. Review weekly alpha survey logs after May, 2008.
Prepared By: Kevin J Camey
(Print Name)
5 of Page 5
INSPECTION REPORT
Inspection Module: RADMOD-DMWM-01: Training
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Safety Training and Respiratory Protection Training
Lispection Dates: May 28, 2008 and May 29, 2008
Inspector: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (RSO), Dave Frydenlund (VP Regulatory Affairs and Counsel)
and Mike Spillman (Safety Manager)
Goveming Documents:
UACR313-15
NRC REG. Guide 8.15
NRC REG. Guide 8.31
RMLUT1900479
RML UTI 900479 License Renewal Application (2/28/07) Appendix J
(Training Manual) and Appendix L (Respiratory Protection Program)
Opening Meeting
Denison Mines: Dave Turk (RSO)
Dave Frydenlund (V.P. Regulatory Affairs & Counsel)
Mike Spillman (Safety Manager)
Rick Bartlett (Mill Manager)
Utah DRC: John Hultquist (LLW/Uranium Mills Section Manager)
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
NRC: Doug Mandeville (NRC Headquarters Geotech Engineer)
R.K. Wild (Inspector General: Audit Manager)
Andrea Ferkile (Inspector General: Analyst)
The DRC opened the meeting with introductions and then a general overview of the
inspection and discussed the inspection modules that Ryan Johnson and Kevin Camey
were going to be doing during this inspection. (John Hultquist is accompanying this
inspection as part of an annual audit of the inspector) (The NRC is accompanying this
inspection as part of the 2007 IMPEP review follow-up.)
1 ofPage 6
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\Inspection Report RADMOD-DMWM-01 5-28-08 RJ.doc
Inspection Summarv
• Employee Interviews:
Carl Tahnazani (CCD Operator)
Ricky Gillis (Decon Operator)
Tyler Johnson (Maintenance)
April Arthur (Lab)
Treg Parrish (Utility Crew)
The inspector asked the same questions to each employee. The questions related to their
initial training and refresher training, with specific questions related to Radiation Safety,
Respirator Protection, Dosimetry and each individual was asked to demonstrate proper
frisking techniques. (Interview responses are documented in the RADMOD-DMWM-01
inspection module).
• Site Documentation: The inspector reviewed the training documentation
of the employees that were interviewed.
• RSO Interview: The inspector discussed how the mills Radiation Safety
Training followed NRC Reg. Guide 8.31 and Respiratory Protection
Training followed NRC Reg. Guide 8.15. Also the qualifications and
training ofthe RSO and the mills Radiation Safety Techs were discussed
and how their qualifications and training compared to Reg. Guide 8.31.
Both of these NRC Reg. Guides are referenced in Denison Mines 2007
RML renewal application.
• Mill Tour: The inspector participated in a general site tour with NRC
personnel. The next day the inspector went back into the area to look at
the boards where Denison Employees keep their dosimeters and lockers in
the mill's control room where some employees keep their respirators as a
follow up to the employee interviews.
Inspection Items
Preliminaries
Item 1. Employee Interviews: Five employees were randomly picked from a list of employees
that Denison Mines provided. Each ofthe employees were asked the same questions and their
answers were vv^ritten on the questionnaire by the inspector. They were also asked to demonstrate
how they were trained on frisking themselves out of the restricted area. The employees have
worked at the mill from approximately one month to one year.
Deficiencies: The answers from each of the five employees were varied and incomplete. Not all
ofthe employees could name the types of radiation that were expected to be at the mill. Most of
their answers needed to be prompted by the inspector. None of them knew all of the different
routes of exposure to radiation, all of the ways to limit their exposure and the health concems
with the types of radiation that they maybe exposed to. When asked how often they use their
respirators and how many hours in a day do they use them their answers varied depending on
their specific job requirements. Four employees said they use respirators; none of them seemed
to be aware of the respirator exchange policy that is outlined in the Respirator Protection
Program, especially the requirement if the respirator is used more than 4 hours in a day than it
2 ofPage 6
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\Inspection Report RADMOD-DMWM-01 5-28-08 RJ.doc
needs to be exchanged daily for cleaning and maintenance. The employees that were interviewed
said that they use or occasionally use respirators more than 4 hours per day but they only
exchange their respirators every two weeks to monthly. The employees that were interviewed
were asked to demonstrate survey (fiisking) techniques; all but one of the employees did not
show the proper fiisking techniques by moving the probe of the meter too fast and holding the
probe too far from their body. These interviews indicate a lack of knowledge in Radiation Safety
and the mills Respirator Protection Program by these employees. Site employees, at a minimum,
need to know the hazards of their job. These include the radiological, chemical and physical
hazards. The employees need to know how these hazards affect them and most importantly they
need to know how to protect themselves through the concepts of ALARA and Time, Distance
and Shielding. They need to understand how procedures, RWPs, PPE, the engineering controls
at the mill, proper survey techniques, etc. relate to these concepts to help them stay safe. It does
not matter what a persons education, race or background is, if they work at the mill they need to
be proficient in radiation and work place safety. In addition to the employee's initial training and
refresher training, these concepts should be taught in regular (weekly or monthly) site safety
meetings as well.
Item 2. Site Documentation: The inspector reviewed the training documentation of the
employees that were interviewed. Specifically, theinspector looked for Exams, Initial and
Refresher Training records. Personnel Monitoring training documentation, Fit Test
documentation and Medical Clearance documentation. Denison Mines uses the MSHA 5000-23
form and employee sign-in sheets to document Initial and Refresher training for both Radiation
Safety Training and Respirator Protection Training.
Deficiencies: It was noted that one of the employee's (Treg Parrish) medical clearances was just
older than one year and th^t his fit test expired at the end of the vv^eek. Also, Denison Mines does
not have a separate Exam for Respirator Protection training but has chosen to use one question
on the Radiation Safety Exam to demonstrate employee knowledge of the Respirator Protection
Program. Employees at the mill need to demonstrate through documentation (an Exam) that they
are proficient in respirator use. One question on an exam does not do this. There needs to be
more questions either on the Radiation Safety exam or a separate exam that covers all of the
concepts of the Respirator Protection Program.
Item 3. RSO Interview: The inspector discussed with the RSO how the mills Radiation Safety
Training followed NRC Reg. Guide 8.31 and Respiratory Protection Training followed NRC
Reg. Guide 8.15. Both of these NRC Reg. Guides are referenced in Denison Mines 2007 RML
renewal application in the mills ALARA Program (Appendix I). The inspector also asked for
any training materials such as class outlines that were not provided in RML renewal application
so that the inspector could review this material as well.
The inspector and the RSO also discussed the qualifications and training that the RSO and the
mills Radiation Safety Technicians have as compared to REG. Guide 8.31 referenced iri the mills
ALARA Program. The RSO provided a brief summary of his education and work experience
and also provided the inspector a copy of his Radiation Safety Officer Certificate from his initial
training which was offered by the Nevada Technical Associates, Inc. The RSO is taking his two
3 ofPage 6
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\Inspection Report RADMOD-DMWM-01 5-28-08 RJ.doc
year refresher training in June 2008 and said that he will send the DRC a copy of that certificate
when he gets it. The RSO then described the mills training program for the Radiation Safety
Technicians; which consists of sending the Radiation Safety Technicians to Ludlum to be trained
on the meters that they will be using, having them read the Radiation Safety Procedures, tested
on the math that they will be using and a mentoring program in which each Technician is
assigned a mentor to help give them hands on training and to check their work until the
Technician can demonstrate to the RSO that they can performjtheir job without supervision.
Deficiencies: In the discussions with the RSO, it is apparent he has the knowledge and is
capable of properly training the mills personnel. However, the training documentation such as
class outlines and other materials does not document all of the! topics of radiation safety and
respirator protection outlined in Reg. Guide 8.31 and Reg. Giiide 8.15. During these discussions
the RSO admitted that he was not aware of all of the - 'Notice tjo Workers" requirements that are
outlined in UAC R313-18. The inspector gave the RSO a coij|y of UAC R313-18 and instructed
the RSO to post the necessary documentation before the next inspection.
ji •
The mill only has one Radiation Safety Technician by the definition in Reg. Guide 8.31 the other
five are still being trained. That means that the one Radiation| Safety Technician and the RSO are
mentoring the other five technicians while performing their rdgular duties as well. When asked if
the RSO provides the Radiation Safety Technicians with additional Health Physics training his
answer was no. There is also not a written; training program this time for the Radiation Safety
Technicians or an exam that covers the mills Radiation SafetjJ procedures and basic health
physics. There is no qualified designee for the RSO at the mill, the RSO is on call 24hrs a day.
• • ll • • ' '
j •. . . . • / ^ •
Item 4. Mill Tour: The inspector accompanied the NRC thijlough the restricted area on a
general site tour. Areas that were visited included the ore piles, decontaminatiori areas, the mill
including the control room, the solvent extraction circuit builling and the tailings ponds
including Cell 4A. During this tour the inspector stopped at Cell 4A to spoke to a contractor
with a gauge whose company had recently received a letter of reciprocity from the UDRC. The
inspector checked the contractor's paper work and looked forj
tmck. The following day the inspector went back into the mi
the mill employees kept their dosimeters and their respirators!
gauge security measures in the
Is restricted area to verify where
Deficiencies: During the general site tour the inspector noticled a yellowish dried powdered
material on the floor ofthe mill near the yellowcake drier/packaging area. This material was
shown to the RSO at that time. The next day while walking through that area the inspector
noticed that material was still on the floor and other similar niaterial on the catwalk near the
control room. The material on the catwalk was pointed out to the Safety Manager, who
identified it as yellow cake and he had it cleaned up. According to the mills Operators Manual
spills are to be cleaned up immediately. While checking the lockers where mill operators store
their respirators the inspector interviewed the "Shifter" (Gage Sterling). The Shifter told the
inspector that when the mill is in operation his crew wears their respirators for the full shift (up to
twelve hours per day). He also told the inspector that his crew exchanges their respirators every
two weeks. This respirator exchange practice does not follow the Respirator Protection Program.
While inspecting the boards where employees keep their dosjimeters it was noticed that there
4 ofPage 6
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\lnspection Report RADMOD-DM\)/M-01 5-28-08 RJ.doc
were dosimeters missing from the crews that were not at work at the time of the inspection.
When asked, the RSO checked the names of the individuals. Some ofthe individuals no longer
worked at the millj some were new employees that did not have dosimeters assigned to them and
some were employees that did not put their dosimeters on the board before they left. In addition,
Linda McClain of the NRC brought to my attention, while she accompanied Kevin Camey on
part of his inspection inside the restricted area that their escort did not have a dosimeter. I asked
this employee why, he told me that he was a new employee and did not have dosimeter. The
RSO indicated that he would follow-up with the employees who did not put the dosimeters on
the board. As for new employees, the RSO explained they are assigned the highest dose of the
group that they work with until they get their dosimeters.?
Closeout Meeting
Denison Mines: Dave Turk (RSO)
Dave Frydenlund (V.P. Regulatory Affairs & Counsel)
Mike Spillman (Safety)
^ Rick Bartlett (Mill Manager)
Utah DRC: John Hultquist (LLW/Uranium Mills Section Manager)
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
NRC: Linda McClain (Region 4 Agreement State Liason)
Doug Mandeville (NRC Headquarters Geotech Engineer)
R.K. Wild (Inspector General: Audit Manager)
Andrea Ferkile (Inspector General: Analyst)
Findings
There were four findings regarding the inspection, however, the inspector used Enforcement
Discretion and will treat them as Observations/Recommendations at this time to allow the
Licensee to correct them. These Observations/Recommendations are as follows:
• Respirator usage, respirators are to be exchanged for cleaning and maintenance as
specified in the site's Respirator Protection Program found in Appendix L of the 2007
License Renewal Application. Specifically if a respirator is used for more than 4
hours in a day than it needs to be exchanged daily. The DRC recommends the licensee
follow their procedures as outlined in Appendix L.
• Information and documents that are outlined in UAC R313-18 "Notice to Workers"
need to be posted on the two bulletin boards in the hallways of the main office
building. Enclosed is DRC "Notice to Workers" form for your convenience. Please
put them in appropriate locations.
• Control of employee dosimeters, several employee dosimeters were missing from the
boards on which they are kept, some of these missing badges were from employees
currently working at the mill who did not return them at the end of their shift.
Employees need to follow procedures outlined in Appendix E (Radiation Protection
Manual) sectionl .3.1 Monitoring Procedures: states that all dosimeter badges are to
remain at the mill. In Appendix I (ALARA Program) section 2.3.1 Daily Inspections
5 ofPage 6
C:\DOCUME~mhultqui\LOCALS~l\Temp\XPgrpwise\hispectionReportRADMOD-DMWM-01 5-28-08 RJ.doc
states: storage areas will be inspected daily. The Licensee needs to place more
emphasis on the dosimeter storage boards as part of the daily inspections to identify
missing dosimeter badges.
Yellow Cake and other materials that are spilled in the mill need to be cleaned up
immediately as defined in Appendix F (Ore Recieving, Feed & Grind) and Appendix
G (Yellowcake Precipitation). According to these procedures, mill operators are
supposed to be looking for spills as part of their job.
Conclusion and Recommendations
The following are DRC recommendations regarding items that need improvement:
• Training procedures, outlines and other documentation used for Radiation Safety
Training and Respirator Protection Training need to closely follow NRC Reg. Guide
8.31 for Radiation Safety and NRC Reg. Guide 8.15 for Respiratory Protection. In
addition, the Respiratory Protection Program needs a separate exam for employees to
pass or more questions on the radiation safety exam.
• New employees need to have a dosimeter issued to them before they are allowed to
work inside the restricted area. The DRC recommends either the Licensee have extra
dosimeters onsite to assign new to employees or order them with rush delivery when
they start, so when they are done with their initial training they have their badge.
Recommendation for Next Inspection
1. Dosimetry Program
2. Respirator Issuance, Documentation and Respirator Exchange.
3. Posting of "Notice to Workers" as contained in UAC R313-18.
4. Spills (Yellowcake and other materials) being cleaned up in the mill
immediately, and;
5. Radiation Safety Technic!^ Training.
Prepared By: w^^^^^.-^ ——
(Date)
6 ofPage 6
C:\DOCUME~l\Jhultqui\LOCALS~l\Temp\XPgrpwise\hispection Report RADMOD-DMWM-01 5-28-08 RJ.doc
INSPECTION REPORT
Inspection Module: RADMOD-DMWM-01: Training
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Radiation Safety Training and Respiratory Protection Training
Inspection Dates: May 28, 2008 and May 29, 2008
Inspector: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (RSO), Dave Frydenlund (VP Regulatory Affairs and Counsel)
and Mike Spillman (Safety Manager)
Goveming Documents:
UAC R313-15
NRC REG. Guide 8.15
NRC REG. Guide 8.31
RMLUT1900479
RML UT1900479 License Renewal Application (2/28/07) Appendix J
(Training Manual) and Appendix L (Respiratory Protection Program)
Opening Meeting
Denison Mines: Dave Turk (RSO)
Dave Frydenlund (V.P. Regulatory Affairs & Counsel)
Mike Spillman (Safety Manager)
Rick Bartlett (Mill Manager)
Utah DRC: John Hultquist (LLW/Uranium Mills Section Manager)
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
NRC: Doug Mandeville (NRC Headquarters Geotech Engineer)
^ R.K. Wild (Inspector General: Audit Manager)
Andrea Ferkile (Inspector General: Analyst)
The DRC opened the meeting with introductions and then a general overview of the
inspection and discussed the inspection modules that Ryan Johnson and Kevin Camey
were going to be doing during this inspection. (John Hultquist is accompanying this
inspection as part of an annual audit of the inspector) (The NRC is accompanying this
inspection aspart of the 2007 IMPEP review follow-up.)
1 ofPage 6
U:\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mmes - White Mesa UMillVHP Inspection modules\2008\hispection Report
RADMOD-DMWM-01 5-28-08 RJ.doc
Inspection Summarv
• Employee Interviews:
Carl Tahnazani (CCD Operator)
Ricky Gillis (Decon Operator)
Tyler Johnson (Maintenance)
April Arthur (Lab)
Treg Parrish (Utility Crew)
The inspector asked the same questions to each employee. The questions related to their
initial training and refresher training, with specific questions related to Radiation Safety,
Respirator Protection, Dosimetry and each individual was asked to demonstrate proper
frisking techniques. (Interview responses are documented in the RADMOD-DMWM-01
inspection module).
• Site Documentation: The inspector reviewed the training documentation
of the employees that were interviewed.
• RSO Interview: The inspector discussed how the mills Radiation Safety
Training followed NRC Reg. Guide 8.31 and Respiratory Protection
Training followed NRC Reg. Guide 8.15. Also the qualifications and
training of the RSO and the mills Radiation Safety Techs were discussed
and how their qualifications and training compared to Reg. Guide 8.31.
Both of these NRC Reg. Guides are referenced in Denison Mines 2007
RML renewal application.
• Mill Tour: The inspector participated in a general site tour with NRC
personnel. The next day the inspector went back into the area to look at
the boards where Denison Employees keep their dosimeters and lockers in
the mill's control room where some employees keep their respirators as a
follow up to the employee interviews.
Inspection Items
Preliminaries
Item 1. Employee Interviews: Five employees were randomly picked from a list of employees
that Denison Mines provided. Each of the employees were asked the same questions and their
answers were written on the questionnaire by the inspector. They were also asked to demonstrate
how they were trained on frisking themselves out of the restricted area. The employees have
worked at the mill from approximately one month to one year.
Deficiencies: The answers from each of the five employees were varied and incomplete. Not all
of the employees could name the types of radiation that were expected to be at the mill. Most of
their answers needed to be prompted by the inspector. None of them knew all of the different
routes of exposure to radiation, all of the ways to limit their exposure and the health concems
with the types of radiation that they maybe exposed to. When asked how often they use their
respirators and how many hours in a day do they use them their answers varied depending on
their specific job requirements. Four employees said they use respirators; none of them seemed
to be aware of the respirator exchange policy that is outlined in the Respirator Protecfion
Program, especially the requirement if the respirator is used more than 4 hours in a day than it
2 ofPage 6
U:\rad\C0MM0N\Uranium millsM 1 e(2)UTl 900479 Denison Mines - White Mesa UMillVHP Inspection modulesV2008VInspection Report
RADMOD-DMWM-01 5-28-08 RJ.doc
needs to be exchanged daily for cleaning and maintenance. The employees that were interviewed
said that they use or occasionally use respirators more than 4 hours per day but they only
exchange their respirators every two weeks to monthly. The employees that were interviewed
were asked to demonstrate survey (frisking) techniques; all but one of the employees did not
show the proper frisking techniques by moving the probe of the meter too fast and holding the
probe too far from their body. These interviews indicate a lack of knowledge in Radiation Safety
and the mills Respirator Protection Program by these employees. Site employees, at a minimum,
need to know the hazards of their job. These include the radiological, chemical and physical
hazards. The employees need to know how these hazards affect them and most importantly they
need to know how to protect themselves through the concepts of ALARA and Time, Distance
and Shielding. They need to understand how procedures, RWPs, PPE, the engineering controls
at the mill, proper survey techniques, etc. relate to these concepts to help them stay safe. It does
not matter what a persons education, race or background is, if they work at the mill they need to
be proficient in radiation and work place safety. In addition to the employee's initial training and
refresher training, these concepts should be taught in regular (weekly or monthly) site safety
meetings as well.
Item 2. Site Documentation: The inspector reviewed the training documentation of the
employees that were interviewed. Specifically, the inspector looked for Exams, Initial and
Refresher Training records. Personnel Monitoring training documentation. Fit Test
documentation and Medical Clearance documentation. Denison Mines uses the MSHA 5000-23
form and employee sign-in sheets to document Initial and Refresher training for both Radiation
Safety Training and Respirator Protection Training.
Deficiencies: It was noted that one of the employee's (Treg Parrish) medical clearances was just
older than one year and that his fit test expired at the end of the week. Also, Denison Mines does
not have a separate Exam for Respirator Protection training but has chosen to use one question
on the Radiation Safety Exam to demonstrate employee knowledge of the Respirator Protection
Program. Employees at the mill need to demonstrate through documentation (an Exam) that they
are proficient in respirator use. One question on an exam does not do this. There needs to be
more questions either on the Radiation Safety exam or a separate exam that covers all ofthe
concepts of the Respirator Protection Program.
Item 3. RSO Interview: The inspector discussed with the RSO how the mills Radiation Safety
Training followed NRC Reg. Guide 8.31 and Respiratory Protection Training followed NRC
Reg. Guide 8.15. Both of these NRC Reg. Guides are referenced in Denison Mines 2007 RML
renewal application in the mills ALARA Program (Appendix I). The inspector also asked for
any training materials such as class outhnes that were not provided in RML renewal application
so that the inspector could review this material as well.
The inspector and the RSO also discussed the qualifications and training that the RSO and the
mills Radiation Safety Technicians have as compared to REG. Guide 8.31 referenced in the mills
ALARA Program. The RSO provided a brief summary of his education and work experience
and also provided the inspector a copy of his Radiation Safety Officer Certificate from his initial
3 ofPage 6
U:VradVC0MM0N\Uranium millsVl le(2)UT 1900479 Denison Mines - White Mesa UMillVHP hispection modulesV2008VInspection Report
RADMOD-DMWM-01 5-28-08 RJ.doc
training which was offered by the Nevada Technical Associates, Inc. The RSO is taking his two
year refresher training in June 2008 and said that he will send the DRC a copy of that certificate
when he gets it. The RSO then described the mills training program for the Radiation Safety
Technicians; which consists of sending the Radiation Safety Technicians to Ludlum to be trained
on the meters that they will be using, having them read the Radiation Safety Procedures, tested
on the math that they will be using and a mentoring program in which each Technician is
assigned a mentor to help give them hands on training and to check their work until the
Technician can demonstrate to the RSO that they can perform their job without supervision.
Deficiencies: In the discussions with the RSO, itis apparent he has the knowledge and is
capable of properly training the mills personnel. However, the training documentation such as
class outlines and other materials does not document all of the topics of radiation s^afety and
respirator protection outiined in Reg. Guide 8.31 and Reg. Guide 8.15. During these discussions
the RSO admitted that he was not aware of all of the "Notice to Workers" requirements that are
outlined in UAC R313-18. The inspector gave the RSO a copy of UAC R313-18 and instmcted
the RSO to post the necessary documentation before the next inspection.
The mill only has one Radiation Safety Technician by the definition in Reg. Guide 8.31 the other
five are still being trained. That means that the one Radiation Safety Technician and the RSO are
mentoring the other five technicians while performing their regular duties as well. When asked if
the RSO provides the Radiation Safety Technicians with additional Health Physics training his
answer was no. There is also not a written training program at this time for the Radiation Safety
Technicians or an exam that covers the mills Radiation Safety procedures and basic health
physics. There is no qualified designee for the RSO at the mill, the RSO is on call 24hrs a day.
Item 4. Mill Tour: The inspector accompanied the NRC through the restricted area on a
general site tour. Areas that were visited included the ore piles, decontamination areas, the mill
including the control room, the solvent extraction circuit building and the tailings ponds
including Cell 4A. During this tour the inspector stopped at Cell 4A to spoke to a contractor
with a gauge whose company had recently received a letter of reciprocity from the UDRC. The
inspector checked the contractor's paper work and looked for gauge security measures in the
tmck. The following day the inspector went back into the mills restricted area to verify where
the mill employees kept their dosimeters and their respirators.
Deficiencies: During the general site tour the inspector noticed a yellowish dried powdered
material on the floor of the mill near the yellowcake drier/packaging area. This material was
shown to the RSO at that time. The next day while walking through that area the inspector
noticed that material was still on the floor and other similar material on the catwalk near the
control room. The material on the catwalk was pointed out to the Safety Manager, who
identified it as yellow cake and he had it cleaned up. According to the mills Operators Manual
spills are to be cleaned up immediately. While checking the lockers where mill operators store
their respirators the inspector interviewed the "Shifter" (Gage Sterling). The Shifter told the
inspector that when the mill is in operation his crew wears their respirators for the full shift (up to
twelve hours per day). He also told the inspector that his crew exchanges their respirators every
4 ofPage 6
U:VradVC0MM0NVUranium millsVl le(2)UT 1900479 Denison Mines - White Mesa UMillVHP Inspection modulesV2008Vhispection Report
RADMOD-DMWM-01 5-28-08 RJ.doc
two weeks. This respirator exchange practice does not follow the Respirator Protection Program.
While inspecting the boards where employees keep their dosimeters it was noticed that there
were dosimeters missing from the crews that were not at work at the time of the inspection.
When asked, the RSO checked the names of the individuals. Some of the individuals no longer
worked at the mill, some were new employees that did not have dosimeters assigned to them and
some were employees that did not put their dosimeters on the board before they left. In addition,
Linda McClain ofthe NRC brought to my attention, while she accompanied Kevin Camey on
part of his inspection inside the restricted area that their escort did not have a dosimeter. I asked
this employee why, he told me that he was a new employee and did not have dosimeter. The
RSO indicated that he would follow-up with the employees who did not put the dosimeters on
the board. As for new employees, the RSO explained they are assigned the highest dose of the
group that they work with until they get their dosimeters.
Closeout Meeting
Denison Mines: Dave Turk (RSO)
Dave Frydenlund (V.P. Regulatory Affairs & Counsel)
Mike Spillman (Safety)
Rick Bartlett (Mill Manager)
Utah DRC: John Hultquist (LLW/Uranium Mills Section Manager)
Ryan Johnson (Inspector)
Kevin Camey (Inspector)
NRC: Linda McClain (Region 4 Agreement State Liason)
Doug Mandeville (NRC Headquarters Geotech Engineer)
R.K. Wild (Inspector General: Audit Manager)
Andrea Ferkile (Inspector General: Analyst)
Findings
There were four findings regarding the inspection, however, the inspector used Enforcement
Discretion and will treat them as Observations/Recommendations at this time to allow the
Licensee to correct them. These Observations/Recommendations are as follows:
• Respirator usage, respirators are to be exchanged for cleaning and maintenance as
specified in the site's Respirator Protection Program found in Appendix L of the 2007
License Renewal Application. Specifically if a respirator is used for more than 4
hours in a day than it needs to be exchanged daily. The DRC recommends the licensee
follow their procedures as outlined in Appendix L.
• Information and documents that are outiined in UAC R313-18"Notice to Workers"
need to be posted on the two bulletin boards in the hallways of the main office
building. Enclosed is DRC "Notice to Workers" form for your convenience. Please
put them in appropriate locations.
• Control of employee dosimeters, several employee dosimeters were missing from the
boards on which they are kept, some of these missing badges were from employees
5 ofPage 6
U:VradVC0MM0NVUranium millsVl le(2)UT1900479 Denison Mines - White Mesa UMillVHP Inspection modulesV2008VInspection Report
RADMOD-DMWM-01 5-28-08 RJ.doc
currently working at the mill who did not retum them at the end of their shift.
Employees need to follow procedures outlined in Appendix E (Radiation Protection
Manual) sectionl .3.1 Monitoring Procedures: states that all dosimeter badges are to
remain at the mill. In Appendix I (ALARA Program) section 2.3.1 Daily Inspections
states: storage areas will be inspected daily. The Licensee needs to place more
emphasis on the dosimeter storage boards as part of the daily inspections to identify
missing dosimeter badges.
• Yellow Cake and other materials that are spilled in the mill need to be cleaned up
immediately as defined in Appendix F (Ore Recieving, Feed & Grind) and Appendix
G (Yellowcake Precipitation). According to these procedures, mill operators are
supposed to be looking for spills as part of their job.
Conclusion and Recommendations
The following are DRC recommendations regarding items that need improvement:
• Training procedures, outlines and other documentation used for Radiation Safety
Training and Respirator Protection Training need to closely follow NRC Reg. Guide
8.31 for Radiation Safety and NRC Reg. Guide 8.15 for Respiratory Protection. In
addition, the Respiratory Protection Program needs a separate exam for employees to
pass or more questions on the radiation safety exam.
• New employees need to have a dosimeter issued to them before they are allowed to
work inside the restricted area. The DRC recommends either the Licensee have extra
dosimeters onsite to assign new to employees or order them with msh delivery when
they start, so when they are done with their initial training they have their badge.
Recommendation for Next Inspection
1. Dosimetry Program
2. Respirator Issuance, Documentation and Respirator Exchange.
3. Posting of "Notice to Workers" as contained in UAC R313 -18.
4. Spills (Yellowcake and other materjials) being cleaned up in the mill
immediately, and; |
5. Radiation Safety Technician Training.
Prepared By:
(Print Name) (Signature) (Date)
6 ofPage 6
U:VradVC0MM0NVUranium millsVl le(2)UT 1900479 Denison Mines - White Mesa UMillVHP Inspection modulesV2008VInspection Report
RADMOD-DMWM-01 5-28-08 RJ.doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-DMWM-01
TRAINING
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Radioactive Material License UT1900479, License Renewal Application dated February 28,
2007, Training Manual, addendums 9 and 10, Radiation Protection Manual, Section 1, 10CFR20, NRC
Regulatory Guide 8.30, NRC Regulatory Guide 8.31, Regulatory Guide 8.15, Utah Administrative Code
R313-15.
TRAINING MANUAL (Appendix J. 2007 License Renewal)
Addendum 9: Radiation Safety Training
In the ALARA program (Appendix I license renewal) 2.5.2 states that the Radiation Training for new
employees will follow NRC Reg. Guide 8.31 section 2.5.
2.5 Buidiation Safetr Traiiiiiig
Ail new einplowes should be mslruGted by meam of ao estabiisiied €ai»e in tlie inherent
risks of e3q50OTre to radiation and the fimdameiitafc of proieciion against e^osure to uranium and
its daogh^rs befbre begmmng their Jobs. Other gmdance pertment to Ais c#i^
Regiilator\^ Guide 8.13. "Instmction Conceming Prenatal Radiation Exposure'' (Ref. 10), and
Repilatow Giiide 8.29, "Instmction Conceming Risks from Occiipational Radiation Exposure*'
(Ref 11). Additionally, the training should be coniniensi^aie with tfae risks and hazards of the
task. This course of instmction should include the followmg topics:
L "f^mdamentals of Health!^
• The radiologic and toxic hazards of exposure to uraniimi and 1^^^
• How urammii and lis <kughiers €^
skin penetration),
• Why exposures to uranimn and its daughters should be kept ALARA.
2, Personal Hygiene at UR Facilities . . >
• Wearing protectiire clothing,
• Using respiratoty protective equipment correctly.
• Eating, drinkmg, aiM smokmg only in. desigoaied are^^^
• Using proper niethods for decontaoimatiOT
3. Facihty-Provided Protection
• Ventilation swtems and effluent controls,
• Cieanlmess of the work place,
• Features designed for radiation safet>^ for process equipment,
• Standard operating procedures.
• Security and access control to designated areas,
• Electronic data gathering and storage,
• Automated processes.
4- Health Protection Measurements
• Measurement of airbome radioactive matenals,
• Bioassays to detect uranium (urinalysis and m vivo counting),
UAradVCOMMONVUranium millsV 1 le(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01 doc
Page 1 of 9
• Sun/eys to detect CQntaminatian of personnel and equipment,
• Pei'somiel dosimetry
5. Radiation Protaction Regulations
Regulatory aulhooty of NRC, MSHA, and State,
• Employee rights m 10 CFR Part 19,
• Radiation protection requirements m 10 CFR Part 20.
6. Emergency Procedures. '
A. written or oral test with questions directly relevant to the principles of radiation safety-
and heahh protection in UR cohered in the Gaining coi^se should be given to each work^. The
instmctor should review the test results with each worker. Tlie instmctox should discuss any
wrong answers to test questions with the worker until the v/orker understands the correct answer.
Workers who fail the test should be retested afto:- receiving additional, training. These teste end
results should be maintained on file.
Each pennanent worker should be provided an abbreviated retraining course annually.
Documented successftil completion ofthe retraining course should also be mamtamed on file.
Renaming should include relevant mformation that has become available during the past year, a
review of safety problems that have arisen durmg the year, changes m regulations and license
conditions, exposure trends, and other current topics.
in addition, all new workers, including super\isors, shouid be given specialized instruction
on the health and radiation safet>" aspects and on the nonradiological hazards ofthe specific jobs
die3^ Will perform. This instruction should be in the fomi of mdividuaiized on-the-job training.
Supei\isors shouid be pro\^ded additional speciahzed trainmg on their super\lsorv^ responsibilities
in the area of worker radia ticin protection. Retraining should be conducted annually and
documented. AM employees should sign a statement that they received job-specific radiation
safety traming. The statement should indicate the dates the training was received and it should be
cosigned by the mstmctor. Radiation safet\^ matters of concem that arise durmg plant operation
should be discussed with all workers during regular monthly or bimonthly meetings.
Ail visitors wiio liave not received training should be escorted by someone properly trained
and knowledgeable about the hazards of the facihty. At a mmimum, visitors should be instructed
specifically on what they should do to avoid possible radiological and nonradiological hazards in
the areas of the facility they will be visitmg.
Contractors that have work assipiments m a UR facility should also be given appropriate
training and safety instruction. Contractor workers who will perfbrm work on heavily
contaminated equipment should receive the same traming and radiation safety instruction normally
required of all permanent workers. Only job-specific radiation safety instmction is necessarv- for
contract workers who have previously received fiill training on prior work assipiments at the
faciiity or have evidence of recent and relevant radiation safety trainiog elsewhere.
UAradVCOMMONVUranium millsV 1 le(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01.doc
Page 2 of 9
Addendum 10: Respirator Protection Training
In the ALARA program (Appendix I license renewal) 2.7.5. states that the Respirator Protection
Program will follow NRC Reg. Guide 8.15. Section 5.2 of Reg. Guide 8.15 covers the Training
Program for respirator users.
7) Review the Respirator Protection Training material with the instructor and identify in the document(s)
where each subject is covered. Then comment on any subject that needs clarification, revision or not
covered. At a minimum each trainee should: covered.
2H6e infor Je informed of the hazard to which the respirator
wearer may be exposed, the effects of the
contaminants on the wearer if the respirator is not
wom properly, and the capabilities and limitations
of each device that may be used.
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.
; able to demonstrate competency in donning,
"using, and removing each type of respiratory
protective device that may be used.
Je instructed in how to inspect each type of
respiratory protective device that may be used and
be instructed to perform such an inspection before
donniflf^ny device.
se 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.
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 .
of operating conditions, or any other condition that
might necessitate such relief.
Be advised that in case a respirator malfunction or
wearer distress, the respirator may be removed as
the respirator user exits the airbome contamination
area.
UAradVCOMMONVUranium mjllsV 1 le(2)UTl900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01.doc
Page 6 of 9
^Electronic data gathering and
storage
Automated processes
I ^ radii
Section 4:Health Protection
Measurements
[easurements of Airborne
radioactive materials rafH
T^io ioassays to detect Uranium
(Urinalysis and in Vivo
Coimting)
surveys to detect contamination
on personnel and equipment
/A.'I J ^-T^ ^^7^ <s>/^^ /^^^ '^^^^ -Personnel Dosimetry
Section 5: Radiation Protection
Regulation
-Regulatory Authority of the
NRC, MSHA and the State
-Employee Rights in 10CFR19 /^.^^ ) ^,k^
-Radiation Protection
Requirements in 10CFR20
Seaion 6
^ Procedui
:tion 6: Emergency
Procedures
2) Dose the Radiation Protection training cover the information sufficiently to enable onsite personnel to
properly implement the Radiation Protection program and the ALARA program? Yes . No
Have the employee's demonstrated sufficient understanding of the material to be able to implement the
Radiation Protection program and the ALARA programs? Yes_^ No_
Has this training been properly documented? Yes .XT No
Comments:
Section 3.1 Pre-Employment Instruction - Items I and J.
3) Did the licensee provide training to female employees on 'Prenatal Radiation Review
Yes
Comments:
No
UAradVCOMMONVUranium millsV 1 le(2)UTI900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01.doc
Page 4 of 9
R313-15-101. Radiation Protection Programs.
(1) Each licensee or registrant shall develop, document, and implement a radiation protection program sufficient to ensure
compliance with the provisions of Rule R313-15 . See Section R313-15-1102 for recordkeeping requirements relating to these
programs.
(2) The licensee or registrant shall use, to the extent practical, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is
reasonably achievable (ALARA). |
(3) The licensee or registrant shall, at intervals not to exceed 12 months, review the radiation protection pirogram content and
implementation. j
(4) To implement the ALARA requirements of Subsection R313-15-101(2), and notwithstanding the requirements in Section
R313-15-301, a constraint on air emissions of radioactive material to the environment, excluding radon-222 and its decay
products, shall be established by licensees or registrants such that the individual member of the public likely to receive the
highest dose will not be expected to receive a total effective dose equivalent in excess of 0.1 mSv (0.01 rem) per year from
these emissions. If a licensee or registrant subject to this requirement exceeds this dose constraint, the licensee or registrant
shall report the exceedance as provided in Section R313-15-1203 and promptly take appropriate corrective action to ensure
against recurrence.
1) Review the Radiation Safety material with the instructor and identify in the documeT|t(s) where each
subject is covered. Then comment on any subject that needs clarification, revision or not covered.
Section 1:Fundamentals of
Health Protection
ythe radiologic and Toxic
/iiazards of exposure to Uranium
and its daughters
-How Uranium and its
daughters enter the body
(Inhalation, Ingestion and Skin
Penetration)
Section 2:Personal Hygiene at
UR Facilities
-Wearing Protective Clothing
-Using Respirator Protective
Equipment Correctly
"^-Eating, Drinkingvand Smoking
only in designated areas
-Using proper methods for
decontamination
Section 3:Facility Provided
Protection
-Ventilation Systems and
Effluent Controls
-Cleanliness of the work place
-Features designed for Radiation
Safety for process equipment
-Standard Operating
Procedures
-Security and Access Control to
designated areas
UAradVCOMMONVUranium millsV 1 Ie(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-Ol.doc
Page 3 of 9
3 C/^^X _
Training Manual Section 2.0 On-Site Contractors.
"New hire training, as outlined in Section 3.1, is included in the training program, as applicable to the
site work specifications, for on-site contractors."
4) Has the licensee documented initial training of on-site contractors?
Commeijis: . -r ^
Yes :^No.
3^
Training Manual Section 3.1 Pre-employment Instmction. I
"Classroom instruction of all new employees is conducted under the supervision of the Radiation Safety
Officer and Safety Coordinator, covering plant and personal safety, including radiation protection. "
5) Has the licensee documented initial training of new employees?
No.
6) Did the licensee provide annual refresher training on 'Radiation Protection'?
Yes
Comments:
No
—^
Additional Comments or Observations
T^r^ ^-^^ - ^ ^ ^
^ -
U:VradVCOMMON\Uranium millsV 1 le(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-OMWM-01.doc
Pages of 9
8) Does the licensee provide training on the 'Respirator Protection Program'? Yes ^ No
How did they document that training?
Comments ^ . ^
9) Does the training cover all of the outlined material?
If no what needs to be added or expanded?
Comments: / c
Yes No
10) Did personnel that were interviewed have a good knowledge of the Respirator Protection Program?
• Yes i • No ><^
If no what areas do they need to be retrained in? j
Comment^ ^^^^ M,jt^^
jA . y 7 1 » ——^ "W »*——*' • — a=- a*
i^2^Z^ i^^T ^ y^iz>^'-^
Appendix I (ALARA Program) section 2.4.1 requires that the RSO should have the education, training
and experience as specified in NRC Regulatory Guide 8.31. Section 2.5 the RSO shall also receive
health and safety refresher training every two years. Section 2.4.2 The Radiation Safety Technician
(RST) shall have the qualifications specified in NRC Regulatory Guide 8.31. |
11) Who is the current RSO for this facility? __
Does the named RSO have the required education, training and experience as outiined in Reg. Guide
8.31? Yes
Has the RSO received additional training in health and safety every two years?
Comments: ^ Yes
i^No.
No
h%ij,. j7^-f^.^^ iP^-f/f^l^^
12) Who is the RSO's designee when the RSO is not available? J^^^ /S ^ ^ ^^^.^e^
Does the named designee have the same RSO education, training and experience as ou-^lined in Reg.
Guide 8.31? Yesj_ No X"
Does the RSOs designee receive additional training in health and safety?
Comments: . , Yesi No yC
1^^^ ' " ' y — -| - -
U:VradVCOMMONVUranium millsV 1 le(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-Ol .doc
Page 7 of 9
13) Do the RSTs have the required education, training and experience as outlined in Reg. Guide 8.31?
Name of RST Qualified Y/N Time in iposition Trained Y/N Assigned Duties
^ ji-
/i cL.^^-^— 7 .
1
y? /f f ' L Jx L/ "" ""•
i
1 . • • •
14) How are the RSTs trained to do their jobs?
Comnients:
Record Review
15) Look at the training records of the employees who were interviewed.
Radiation Safety
Name
4.
1^
Exams
2^ ^d?i^ >
Initial/ Refresher
I
Training Records
Respirator Training
Name
2..
Exams
l-
.(ifr^
Personnel
Monitoring
Ffrenatal Training/
Pregnancy Form
{^y s^nct^s ^^^^
Initial/Refresher
I
Training Records
Medical Clearance Fit Tests
UAradVCOMMONVUranium millsV 1 Ie(2)UT1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD -DM WM-O l.doc
Page 8 of 9
Employee Interviews
1) Employee Name
2) Employee Job Titie 7^ ^S^^J>^
3) Length of Employment
4) Did Employee receive training when hired? Yes No_
5) Did that training cover Radiation Safety? Yes /XT No
6) Did that training cover Respiratory Protection? Yes No
7) If employed longer than a year, Have they received any refresher training? Yes_
8) Did that training cover Radiation Safety? Yes_ No NA ><r
9) Did that training cover Respiratory Protection? Yes No. NA
No NA K
10) If applicable did training cover 'Prenatal Radiation Review'? Yes_
11) Where do they wear their dosimetry? 1^^^^ "^T^rS/O
12) Where do they store their dosimetrv? j^^^rcX^ / ^ /^C^ ^ y^/a^ / ^ ^^'r^<^^^^
13) What are the main types of radiation expected at this facility? A^f "^^ 3^2^^ ^
14) What are the health risks associated with the types of radiation found at this facility? ______
15) What are the main routes of exposure? ^/^A^ /^p^-^^-^^-^^
16) How do you limit your exposure? S/^^^ ^ ?^/^ ^.^^ ^//^
17) Do you use a respirator? Yes V
-7^
18) How often do you use a respirator?
19) How many hours in a day do you use your respirator?
20) How often do you exchange your respirator? /iy^
21) Where do you store your respirator? .
22) Have the employee demonstrate the proper method for scanning themselves out of the restricted
area. Did they do it correctiy? Yes Na Do they know the release limit? Yes No X? .
What do they do if the meters alarms? .>^g::2^ ^ ^ /V^^ /^^s /\ Ch^li T vg«y^
When are they supposed to do this? /^y^ fcsT^^cT^y^^^ I . ^ ^
• . . . • I . ' •
Source Appendix E: Release Limits 1,000 dpm a/lOOcm^ Survey their Hands, Feet, and Clothing; Whq'n they leave
Restricted area and at thcicnd of their shift. Probe inch from surface of item being surveyed. |
Additional Commqits: _
r^^n,-^ ^^iQ^ r
UAradVCOMMONVUranium millsV 1 le(2)UTl900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-|DMWM-01 .doc
Page 9 of 9
Employee Interviews
1) Employee Name
2) Employee Job Title.
3) Length of Employment ^j^^-^y^-^
4) Did Employee receive training when hired? Yes. No
5) Did that training cover Radiation Safety? Yes. No
6) Did that training cover Respiratory Protection? Yes. No
7) If employed longer than a year, Have they received any refresher training? Yes_
8) Did that training cover Radiation Safety? Yes No_ NA
9) Did that training cover Respiratory Protection? Yes No NA
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No
11) Where do they wear their dosimetry? fpC^
No ,NA_>^
12) Where do they store their dosimetry? /^^^ /O i^^^::^^ }n k^,y^^f ^^^y^
13) What are the main types of radiation expected at this facility? ^ \^^^ < ^^^^^
14) Wha^re the health risks associated with the types of radiation found at this facility?
15) What are the main routes of exposure? AA^^^^X^^ /^>^!> y
16) How do you limit your exposure? . J?^<c
No 17) Do you use a respirator? Yes
18) How often do you use a respirator? QJ^rc
NA
19) How many hours in a day do you use your respirator? ^ ^ ^ /&£^y<^ ^ ^ ^4
20) How often do you exchange your respirator? //^<s^^
21) Where do you store your respirator? ^ Y A-g A\ /^tyf'-^ c^
22) Have the employee demonstrate the proper method for scanning themselves out of the restricted
area. Did they do it correctiy? Yes No Do they know the release limit? Yes No>d
What do they do if the meters alarms?
When are they supposed to do this? ^o&^^^^^^ ^^j^c^J^
Source Appendix E: Relekse Limits 1,000 dpm a/lOOcm^; Survey their Hands, Feet, and Clothing; Whein they leave
Restricted area and at theiend of their shift. Probe V4 inch from surface of item being surveyed. |
Additional Comments: / / x I \P yl/
UAradVCOMMONVUranium millsV 11 e(2)UTl900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01 doc
Page 9 of 9
Employee Interviews
1) Employee Name ^^^^.^pxy,
2) Employee Job Title i /^KTyi%^ er^izniO-^^
3) Length of Employnient /( flio//i^
4) Did Employee receive training when hired? Yes. No
5) Did that training coyer Radiation Safety? Yes No
6) Did that training cover Respiratory Protection? YesyXC No
7) If employed longer than a year, Have they received any refresher training? Yes. No NA
8) Did that training cover Radiation Safety? Yes. J^No NA.
9) Did that training coyer Respiratory Protection? Yes No_ NA ___
10) If applicable did training cover 'Prenatal Radiation Review'? Yes^ No__
11) Where do they wear their dosimetry?
12) Where do they store their dosimetry? S^^r^ t '^
13) What are the main types of radiation expected at this facility? ^ ^c^^p^d^ ^ ^ ^-{^ <^cz^
14) ^hat are the health risks associated with the types of radiation found at this facility?
15) What are the main routes of exposure? 4^'y^f M<Jt^ ^€jyt^ <:^:::^^^"'^-^t^ i^^v^^
16) How dOf you limit your exposure? fj J l^O^^-- y ^ ^/^^ ^ ^gp/^ ^
^}eiA
17) Do you use a respirator? Yes_ No NA
18) How often do you use a respirator? ^y/"
19) How many hours in a day do you use your respirator?
20) How often do you exchange your respirator?.
21) Where do you store your respirator? ^^oy O/^ -^rjj^ l^S^<::::^^^^
22) Have the employee demonstrate the proper method for scanning themselves out of the restricted
area. Did they do it cbrrectiy? Yes i^^.^'-'-'^o Do they know the release limit? Yes_ No Vf
What do they do if the meters alarms? (^^^^^C^ d^T^ ^^jj^^J^ / yC^u^ ^^€>^-^—
When are they supposed to do this? ^u S^ ^/^^ Af^^^^^"^^^
Source Appendix E: Release Limits 1,000 dpm a/lOOcm^; Survey their Hands, Feet, and Clothing; When they leave
Restricted area and at the end of their shift. Probe VA, inch from surface of item being surveyed.
Additional Comments:
UAradVCOMMONVUranium millsV 1 le(2)UTl900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01.doc
Page 9 of 9
Employee Interviews
1) Employee Name .P^fo / jl^r^c^y^
2) Employee Job Titie^ /C^^ ^/S^T^
3) Length of Employnient ^jg^y^ 3
4) Did Employee receive training when hired? YesNc^ No_
5) Did that training cover Radiation Safety? Yes PC No
6) Did that training coyer Respiratory Protection? Yes_ ^ No
7) If employed longer !than a year. Have they received any refresher training? Yes No NA.
8) Did that training coVer Radiation Safety? Yes No NA-
9) Did that training cover Respiratory Protection? Yes No NA
10) If applicable did training cover 'Prenatal Radiation Review'? Yes/__ No.
11) Where do they web their dosimetry? 4:^ / ^^c^
12) Where do they store their dosimetry? ^:^^r/>^ ^ /^^^^^^^ ^ ^^/^c^^
13) What are the main; types of radiation expected at this facility?/^^ f^-^^^^^^^^^
14) What are the health risks associated with the types of radiation found at this facihty?
Y^y^^ \
15) What are the mairi routes of exposure? ^/^cJ^ /^/^ ^
16) How do you limit your exposure"^^^^^^^t^ C^^\!^ L ^^^y^ ^^^/-^^ 5 ^
17) Do you use a respirator? Yes^ No NA;
18) How often do you use a respirator? ^
19) How many hours in a day do you use your respirator?
20) How often do yod exchange your respirator?
21) Where do you store your respirator?
22) Have the employee demonstrate the proper method for scanning themselves out of the restricted ^
area. Did they do it correctly? Yes No >C Do they know the rel^^ limit? Yes No
What do they do if the meters alarms?-?^^r^?^g^^ ^Q^^ >^ J>^^ ^
When are they supposed to do this? /Pjj£i/-p L^^^ /^JT/y^^^tZ^^^^^
Source Appendix E: Release Limits 1,000 dpm a/lOOcm^; Survey their Hands, Feet, and Clothing; When they leave
Restricted area and at the end of their shift. Probe V4 inch from surface of item being surveyed.
Additional Comments:
^-^yj7 --f^g:^ ^ ¥^^ff ^fG^ % ^ 7 <^2>f^M
UAradVCOMMONVUranium millsV 11 e(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01 doc
Page 9 of 9
Employee Interviews
1) Employee Name _
2) Employee Job TitleL
3) Length of Employnient A^g^^y^ <^
4) Did Employee receive training when hired? Yes No_
5) Did that training cover Radiation Safety? Yes No
6) Did that training cover Respiratory Protection? Yes>X No
7) If employed longer than a year. Have they received any refresher training? Yes. X No NA
8) Did that training cover Radiation Safety? Yes No NA
9) Did that training cover Respiratory Protection? Yes No NA ___
10) If applicable did training cover 'Prenatal Radiation Review'? Yes_ No
11) Where do they wear their dosimetry? _
12) Where do they store their dosimetry? TjlDi^r//- A\ y^^-^f^^^ /&»-».^
13) What are the main types of radiation expected at this facility? /S&^T^j <^ .^4<K^jfy<. y£^^
14) What are the health risks associated with the types of radiation found at this facility?.
15) What are the main routes of exposure? ^^^^/^^^^^-^^——'^/^t^^ <^ ^ <^Sw^
^^X'^^P^i^^'^^ - '
16) How do you limit lyour exposure?
17) Do you use a respirator? Yes No NA
18) How often do you use a respirator? ^^^^^
19) How many hours in a day do you use your respirator?
20) How often do you exchange your respirator?
21) Where do you store your respirator? /^y,k:^y . 3^
22) Have the employee demonstrate the proper method for scanning themselves out of the restricted
area. Did they do it cbrrectiy? Yes ^No Do they know the release limit? Yes No ^/
What do they do if the meters alarrns?^ OL^^ '^-^ ^US^ J&^?C^J^^^
When are they supposed to do this^'l^^^^Jy^ y^^J^i^^ 5gx^/^ J Y'>^r\ -"^^^f^—
Source Appendix E: Release Limits 1,000 dpm a/lOOcm^; Survey their Hands, Feet, and Clothing; When they leave
Restricted area and at the end of their shift. Probe V4 inch from surface of item being surveyed.
Additional Comments:
UAradVCOMMONVUranium miilsV 1 le(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01.doc
Page 9 of 9
Employee Interviews
1) Employee Name i_
2) Employee Job Title!_
3) Length of Employnient
4) Did Employee receive training when hired? Yes No_
5) Did that training coyer Radiation Safety? Yes No
6) Did that training coyer Respiratory Protection? Yes No^
7) If employed longer jthan a year, Have they received any refresher training? Yes_ No_ NA_
8) Did that training coyer Radiation Safety? Yes No NA
9) Did that training cover Respiratory Protection? Yes_ No NA
10) If applicable did training cover 'Prenatal Radiation Review'? Yes No_
11) Where do they wear their dosimetry?
12) Where do they store their dosimetry?
13) What are the mairi types of radiation expected at this facility? :
14) What are the health risks associated with the types of radiation found at this facility?.
15) What are the mairi routes of exposure?.
16) How do you limit your exposure?.
17) Do you use a respirator? Yes No NA
I
18) How often do yoii use a respirator?
19) How many hours in a day do you use your respirator?
20) How often do you exchange your respirator?
21) Where do you store your respirator?
22) Have the employee demonstrate the proper method for scanning themselves out of the restricted
area. Did they do it cbrrectiy? Yes___ No Do they know the release limit? Yes No
What do they do if the meters alarms?
When are they supposed to do this?
Source Appendix E: Release Limits 1,000 dpm a/lOOcm^; Survey their Hands, Feet, and Clothing; When they leave
Restricted area and at the bnd of their shift. Probe V4 inch from surface of item being surveyed.
Additional Comments:
UAradVCOMMONVUranium miljlsV 1 le(2)UT 1900479 Denison Mines - White Mesa UMillV HP Inspection modulesV RADMOD-DMWM-01 doc
I ' Page 9 of 9
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, 2004.
Dav One
7:00 A.M. Introduction:
Introductions of instmctor and employees.
Pass around the course outline.
Explain who the regulatory agencies are that govem our
activities.
Hand Out Rulebook and sign off Sheet.
Hand out urine sample cups and explain purpose.
Pass aroimd the Training Attendance Sheet.
Brief History of the Mill.
Explain the milling process.
Discuss Emergency Escape & Fire Evacuation Procedures.
Instmction in the Statutory Rights of miners
9:00 A.M. Break
9:15 A.M. Mill Tom-
Introduce the Alpha Survey and demonstrate the proper firisk.
Go to the warehouse and get safety glasses and hard hats.
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,
11:30
Lunch
Class: Radiation Training and Respiratory Protection
• Show the Video, Radiation Naturally
• Have a general discussion about radiation. Including but not
limited to such topics as the health affects of radiation,
benefits of radiation, types of radiation, and explain intemal
and extemal dose.
• 5 rem
• Explain what the radiation department's responsibility is and
how we measure radiation and monitor exposures.
• Annual Exposure letter.
• Previous employment at a radiation regulated site for exposure
history.
• Discuss D.A.C. and radiation postings.
• Importance of Urine samples.
• RWP's
• Define ALARA
• Explain what the employee's responsibility is in regards to
radiation protection.
• Restricted Area and the alpha fiisk. Sign the "Training on the
Proper use of Personnel Alpha Monitor form.
• Go over and explain the importance of the exposure time
cards.
1:15 P.M. Break
1:30 P.M. Class
• 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 of the first day.
Dav Two
7:00 A.M. Class: Transportation Controls & Communication Systems.
• Organization Chart
• Foreman's Report of Injury.
• Reporting accidents, near miss incidents, and unsafe
conditions.
• Review direct and indirect costs of accidents.
Break
• MSDS.
• NFPA
• Review pages 1 & 2 of the mlebook.
• Human Resource Director or designated representative: Time
Cards and explanations of benefits.
10:00 A.M. Class: Hazard Recognition
• Discuss the hazards of the mill.
• Discuss the Safe Work Permit
• Video
11:00 A.M. Lunch
11:30 A.M, Class: First Aid
• Pretest #1, Medical Emergencies in the Workplace.
• Video and review.
• Pretest #2, Choking Emergencies
• Video and review
1:15 P.M. Break
1:30 P.M. Class: First Aid continues
• Pretest #3, Control of Bleeding.
• Video, review and practice.
• Pretest #4, Shock- The silent Killer.
• Video and review.
End Second Day
Dav Three
7:00 A.M, Class: First Aid-continue
Pretest #5, Proper Treatment of Fractures.
Video, review and practice.
Pretest #6, Bum Emergencies.
Video and review.
Go through the ambulance.
9:00 A.M. Break
9:15 A.M. Class: Electrical Hazards & Ground Control, Water Hazards, Night
Work, Elevated Work Areas.
Review ralebook page 29, Electrical Safety Rules.
Review page 3, Electrical Lock out Procedure.
Show one of the Training videos if time allows.
Discuss site traffic rales.
Vehicle pre-shift inspections.
Equipment operator training requirements.
Safety Rules for Tails page 34.
Ladder & Scaffolding rales 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.
• Show the Training Video 'Nurse Vera knows it all.
• Discuss PPE
• Housekeeping page 13
• Sound Levels
• Dust Sampling
• Chemical Hazards and monitoring.
1:15 P.M.
1:30 P.M.
Break
Class:
Review
Questions & Answers.
Collect all paper work and complete the 5000-23 form.
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 05^1-08
Name Date_
Radiation Protection Quiz 2008
Select the correct answer from the possible choices.
1. Radiation Exposure time cards are:
a. Filled out the same every day.
b. A important part in estimating your radiation exposure to airbome radioactivity
c. Filled out by your supervisor.
d. Filled out in pencil.
2. OSL badges are used at the Mill to monitor:
a. Microwave radiation exposure.
b. Extemal Beta/Gamma exposure.
c. Radon exposure.
d. Cosmic radiation exposure.
3. When issued a clean respirator you must:
a. Fill out a respirator issuance log.
b. Fit test with irritant smoke.
c. Perform a field inspection of the respirator.
d. All of the above.
4. To minimize the ingestion of uranium, you should:
a. Wash hands before eating regardless of job assignment.
b. Wash hands before eating only if you are working with yellowcake.
c. Wear gloves while eating.
d. Wash hands before eating when visibly dirty.
5. Leaving the restricted area requires you to:
a. You do not have to monitor yourself.
b. Monitor your self by brashing the detector over your cloths, hands, and soles of your feet.
c. Monitor your self when you are being watched.
d. Monitor your self only on the way home.
6. Housekeeping is:
a. Regulated by MSHA.
b. Regulated by the State of Utah Division of Radiation Control.
c. Essential to reducing the potential for exposure.
d. All of the above.
7. If your supervisor wants you to do a task that is not routine for your job, you should:
a. Find out what special hazards maybe encountered and if permits are needed.
b. Contact the Radiation Office afterwards.
c. Leave it for the next shift.
d. None of the above.
8. An area posted as "Caution Radiation Area" means:
a. Airborne uranium concentrations are above 25% of DAC.
b. Beta/Gamma values are at or above 5 mrem/hr.
c. You must wear a respirator.
d. An RWP is required to enter the area.
9. The ways to reduce workers dose exposures are:
a. Decrease time.
b. Increase distance.
c. Shielding.
d. All of the above.
10. Alpha radiation is the same as:
a. Ganima radiation.
b. Microwave radiation.
c. Radiation from the sun.
d. None of the above.
11. An area posted as "Caution Airbome Radioactivity Area" means:
a. Airbome uranium concentration is above 25% of DAC.
b. Beta-Gamma levels are at or above 2 mrem/hr.
c. You must wear a respirator when you work in the area.
d. Both A and C.
12. Bioassay monitoring determines:
a. Quantity of uranium absorbed through the skin.
b. Probable ingestion or inhalation of uranium.
c. Probable exposure to ganima radiation.
d. Quantity of thorium absorbed through the skin.
13. Total Effective Dose Equivalent (TEDE) is:
a. Intemal exposure effect on the individual.
b. The sum of intemal and extemal exposure.
c. Calculate external exposure.
d. The release requirements set by the state for equipment.
14. ALARA stands for:
a. Acceptable Level Assimilation Resonance Allowable.
b. As Low As Reasonably Achievable.
c. As Long As the RSO Allows.
d. Just another acronym that no one understands.
15. Yellowcake is;
a. Chemically toxic.
b. Produces only Gamma radiation.
c. Yellow all the time.
d. Should be eaten with ice cream.
16. DAC stands for:
a. Daily Accumulated Concentration.
b. Daily Accumulated Contaminate.
c. Dose Actually Calculated.
d. Derived Air Concentration.
17. ALARA limits are:
a. More restrictive than NRC limits.
b. Essentially the same as NRC limits.
c. Less restrictive than NRC limits.
d. Have nothing to do with NRC limits.
18. The Restricted Area:
a. May be visited, with permission, regardless of age.
b. Contains high level radioactive materials.
c. Is an excellent hunting preserve.
d. Consists of all operational and disposal area.
19. Uranium Mill Tailing:
a. May go critical.
b. Are not radioactive.
c. Makes good sandbox filler.
d. Must stay on site.
20. The Utah Radiation Control Division has regulatory authority for:
a. Uranium Mills.
b. Employee health in uranium mills.
c. Environmental concems while processing uranium.
d. All ofthe above.
aierials may contam: 21. Alternate Feed Maief ials may contain
a. Only uranium.
b. Only radioactive elements.
c. Other potential toxic metals and radioactive elements.
d. Mostly junk and spoiled flesh.
22. A "Radioactive Materials" sign signifies that in the area:
a. There maybe a potential extemal exposure level greater than 2.0 mrem/hr.
b. There maybe a potential extemal exposure level of 5.0 mrem/hr or greater.
c. There maybe drums in the area that contain uranium product.
d. All of the above.
23. Bioassay samples must be given:
a. Whenever you feel like it.
b. Before reporting to your job assignment.
c. After you get ready for the day.
d. When wearing work gloves.
24. If the persormel scarmer alarm goes off, what must one do:
a. Hit reset and leave it for the next employee to deal with.
b. Walk on by and just sign your name.
c. Contact the radiation department.
d. Pick up the probe and go through the motions.
25. When required to wear certain PPE, one must wear it:
a. Whenever the RSO walks by.
b. Whenever you think the supervisors are watching you.
c. Whenever you remember.
d. Whenever you enter a job assignment that it has been required and until restriction have been
lifted.
26. Which of the following materials must be surveyed prior to leaving the restricted area:
a. Tools.
b. Vehicles.
c. Equipment.
d. All of the above.
27. Radiation Work Permits (RWP's) are issued by:
a. Safety Department.
b. Radiation Department.
c. Any Supervisor.
d. All of the above.
28. The gravel roadway can be accessed by vehicular traffic without going through
decontamination?
a. True
b. False
29. Equipment and vehicles can be scanned out by any supervisor?
a. True
b. False
30. Where are OSL badges stored?
a. In one's locker.
b. On the OSL badge board.
c. At home.
d. Wherever you leave at the end of the shift.
Training Outline for Newly Hired Employees
Experienced
This outline meets the requirement of the MSHA approved training plan for the White
Mesa Mill, Dated September 1,2004.
7:00 a.m.
9:00 a.m.
9:15 a.m.
Introduction
Introductions ofthe instractor and employees.
Explain who the regulatory agencies are.
Hand out Rulebook and sign off sheets.
Hand out urine specimen cups and explain purpose.
Pass around the Training Attendance Sheet.
Brief history of the Mill.
Explain the milling process.
Discuss Emergency Escape & Fire Evacuation Procedures.
Fire Safety Training
Authority and responsibility of supervisors and miners representatives.
Break
Mill Tour
• Introduce the Alpha Survey and demonstrate the proper frisk.
• Transportation Controls & Communication
• Ground Controls, working near high-walls, water hazards, night work, and elevated
areas
• Electrical Hazards
• Accident Prevention
11.00 a.m. Lunch
11:30 a.m. Class: Radiation Training
Discuss the types of radiation with meter demonstrations.
Explain the difference between intemal and extemal dose.
5 rem
Exposure History
Exposure letter
Exposure Time Sheets
Explain what the employee's responsibility is in regards to radiation
protection,
ALARA principle
Respirators & Fit Testing
• Postings
• Urine Sampling
• PPE
• Radiation Training Quiz and Review
Class: Health & Mandatory Health Standards
Class: HAZCOM
1:30 p.m. Break
1:45 p.m. Class
Fkst Aid
Health Standards
Special Work Permits
Accident Reporting
Intermodal Container Safety
Ore Pad Safety
Tails Safety
5000-23 Forms
3:00 p.m. Supervisor
(
I
^„
...... . ~
1
'"^-.^.-la^Lc^. r:?^. .^y£y>:u.^...
y T.
^'^^ ^ ^ . . -
^J7T<^<^ . ^^^3 - ^ j^^^ "^^^
'^y^.^^L^
\/m
^ ^-^.-^^
., Aja^-^s-
y^<^P€^^<-.If^
\
^^jra^i7
;^^A.._.<^r..i^. . ,
^'>MJ^..
.^4^^^
( fy
....^::i^IiAl}o^:...,.lj>..^^^
r_M^.._.^e_f(^„...^^
IZ..^^^./i^j'Jlr^_,.Jir A/$M^...J^..kyM^.
DENISO
MINES
August 22, 2008
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax:[phone]
www.denisonmines.com
VIA PDF AND FEDEX
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4850
Heceived..
•^UG 2m -
Division of ,
Radiation. Conlro»
Re: Inspection Conducted May 28 and 29, 2008; Notice of Violation and Notice of Proposed
Imposition of Civil Penalty: Radioactive Materials License Number UT1900479
Dear Mr. Finerfrock:
This letter is in response to your letter dated July 25, 2008 regarding the above-referenced Notice of
Violation and Proposed Notice of Imposition of Civil Penalty (the "Notice"), which letter was received
by Denison Mines (USA) Corp. ("Denison") on July 27, 2008.
In your letter you respond to Denison's July 10, 2008 response to the Notice, and state that in order
to close out the Notice of Violation, the DRC requests the licensee to provide the revised Mill
procedures including what changes were made, the date of implementation and the date when
training on the revised procedures will take place. These items are addressed below.
1. Revisions to Procedures
In order to incorporate the changes to Mill procedures discussed in Denison's July 10 response to the
Notice, paragraph 1.2.3 of Section 1.0 of the Mill's Radiation Protection Manual (Mill SOP Book 9)
was amended to add new subparagraphs 7 and 8. A copy of paragraph 1.2.3 of Section 1.0 of the
Mill's Radiation Protection Manual, marked to indicate such changes, is attached to this letter.
2. Date of Implementation
On July 31, 2008, the number of locations where personnel can exit the Mill's restricted area was
limited as follows:
a) access through the entry to the Administration Building near the Radiation Safety Department
was limited to only Radiation, Environmental and Safety staff, Mill Management and Mill
Supervisory Staff. Those personnel are required to perform their own scanning at that
location following existing procedures.
b) access through the entry to the Administration Building frorn the laboratory area was limited
to Senior Lab Personnel, Radiation, Environmental and Safety Staff, Mill Management and
Mill Supervisory Staff. Those personnel are required to perform their own scanning at that
location following existing procedures.
c) All other personnel and workers, were required to exit the restricted area via the main exit at
the Guard Shack. Since June 3, 2008, a Radiation Safety Technician has been positioned at
that location during peak exit times, such as during breaks, and at the ends of shifts, to
observe that each worker is performing a proper scan.
As of July 31, 2008 the foregoing restrictions were implemented by:
• training all personnel on proper scanning technique and on the new restricted area exit
restrictions; and
• closing the access point doors near the Radiation Safety Department and the door between
the Laboratory area and the Administration Building and placing signs on those doors
indicating that access was limited to the personnel specified above.
An electronically controlled security system had been installed prior to July 31, 2008, but was not fully
functional until August 21, 2008. Under this security system, which is now fully functional:
entry/exit access points into and out of the Mill's restricted area are kept locked. This also
includes access to the administration area from the main reception lobby in the Administration
Building; and
each worker and contractor is provided his or her own access card that will unlock only those
access points that the worker or contractor is authorized to access.
As a result, the restrictions on entry/exit access points put into place on July 31, 2008, as described
above, are now enforced through this electronic access system.
The main decontamination pad has not yet been moved from its current location to the Scale House
area. As a result, all truck traffic has not yet been directed to exit at the Scale House. Instead, such
truck traffic continues to exit at the main Guard Shack, where scans continue to be performed on
personnel, as required, by a Radiation Safety Technician. Once the main decontamination pad is
moved to the Scale House area, which is expected to occur by the end of 2008, all truck traffic will be
directed to exit at that location, where scans will be performed on personnel by a Radiation
Technician, as required.
3. Date when Training on the Revised Procedures will take Place
Initial training on proper scanning procedures and the restrictions on access points to and from the
Mill's restricted area, as documented in the revisions to the Radiation Protection Manual described
above, was conducted at sessions held on June 2, 3, 5, 9 and 13, 2008. Documentation of this
training is maintained on file at the Mill. The importance of proper scanning and the restrictions on
access points has also been re-emphasized in monthly safety meetings held on July 11, 16, 21 and
24 for the various work groups.
In addition, on August 21, 2008, at the time each worker and contract employee was given his or her
personal access card. Mill Radiation Staff provided additional training to each individual on proper
scanning technique and on the restrictions to the access points, as set out in the revised procedures
contained in the Mill's Radiation Protection Manual.
DENISO
MINES
These points will also be included in the training for newly hired employees and in the eight-hour
refresher training. In fact, this training has already been included in training for newly hired
employees that took place on July 28 through 30, 2008.
Denison agrees that it is very important to instill a culture throughout the Mill which motivates
employees and contractors to monitor themselves properly because they understand the risks
involved in radioactive materials leaving the facility and not because it is just another requirement
imposed by the regulations. In the training sessions referred to above and in future training sessions
Mill Radiation Staff have and will continue to emphasize these points as a means to instilling this type
of culture.
In our July tO, 2008 letter, we also stated that Denison is evaluating an automated full body scanning
portal at the main exit, which would require each worker exiting at that location to scan out of the
restricted area by exiting through the portal. The decision as to whether or not the Mill will acquire
such a full body scanning portal was to be made by the end of August, 2008. Denison has reviewed
this matter and has decided to defer making the final decision on this until it has had a chance to
evaluate the success of the current changes to scanning and access procedures. As stated above,
increased training, more emphasis on changing the culture among Mill workers and contractors as it
relates to proper scanning, more control over the exit locations and a general decrease in the number
of contract personnel on site, may yield satisfactory results. Denison will be able to monitor the
success of these changes through the placement of the Radiation Technician at the main exit location
at peak times and the continued vigilance of Radiation Safety Staff in performing spot checks on
personnel scanning at other non-peak times throughout the day. If Denison is not satisfied that these
measures have resulted in all workers and contractors complying with Mill procedures upon scanning
out of the Restricted Area, Denison will consider other measures, including installing an automated
full body scanning portal at that time.
If you have any questions or require any further information, please contact the undersigned.
Yours truly.
C.rrydenlund
Vice President Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
DENISO
MINES
EXCERPT FROM RADIATION PROTECTION MANUAL, SHOWING CHANGES
TO PROCEDURES:
1.2.3 Monitoring Procedures
The monitoring procedure includes the following steps:
1. The alarm rate meter is adjusted within the range of 500 to 750 dpm/100 cm^ to
ensure a margin of 250 dpm/100 cm^ due to the low efficiency of this
instmmentation.
2. An individual monitors himself by slowly passing the detector over their hands,
clothing and shoes, including the shoe bottoms, at a distance from the surface of
approximately VA inch. An area that is suspected of possessing any contamination
(i.e. hands, boots, visible spotting/stain on clothing etc.) should be carefully
monitored by placing the detector directiy on the surface and note the measurement.
3. Should an alarm be set off indicating the presence of contamination, the individual
should:
a. Resurvey themselves to verify the contamination.
b. If contamination is present the individual must wash the affected area and
again resurvey themselves to ensure the contamination has been removed.
4. If the decontamination efforts by the individual are not successful, then the Radiation
Safety personnel will be contacted to assess the situation. Further decontamination
may be required.
5. If an individual's clothing cannot be successfully decontaminated, they must obtain
clothing from the warehouse to use and must launder the personal clothing in the
laundry room.
6. Individual surveys are to be logged and initialed.
7. Access to and from the Mill's Restricted Area bv all Mill workers, contractors and
deliverv personneL other than Radiation, Safetv and Environmental Staff Senior
Laboratorv personneL Mill Management and Mill Supervisory personnel and others
as mav be designated bv the RSO, will be hmited to one or more access points as may
be designated by the RSO from time to time.
8. A Radiation Technician will be positioned at each access point designated by the
RSO under paragraph 7 above during peak transition times, such as during breaks and
at the ends of shifts, to observe that each worker, contractor or deliverv person is
performing a proper scan. This paragraph 8 will cease to apply to any such access
point if and when one or more automated full body scanning portals or the equivalent
are situated at the access point, which would require workers exiting at that location
to scan themselves by exiting through the portal, and the procedures in this Manual
are amended to incorporate the use and maintenance of such portal or portals.
DENISO
MINES
July 10, 2008
VIA PDF AND FEDEX
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp,
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: Inspection Conducted May 28 and 29, 2008; Notice of Violation and Notice of Proposed
Imposition of Civil Penalty: Radioactive Materials License Number UT1900479
Dear Mr. Finerfrock:
This letter is in response to the above-referenced Notice of Violation and Proposed Notice of
Imposition of Civil Penalty (the "Notice"), received by Denison Mines (USA) Corp. ("Denison") on June
11, 2007, which lists one violation of the Utah Radiation Control Rules, based on an inspection of the
White Mesa Mill (the "Mill") conducted by representatives of the Utah Division of Radiation Control
("DRC") on May 28 and 29, 2008.
Enclosed please find a check in the amount of $2,500 payable to the State of Utah, in satisfaction of
the civil penalty imposed in connection with this Notice of Violation.
The Notice requires Denison to provide a written response within 30 days after receipt of the Notice,
including:
a) Corrective actions which have been taken by Denison and the results achieved;
b) Corrective actions which will be taken to avoid further items of noncompliance; and
c) The date when full compliance will be achieved.
The Notice also states that R313-18-11(1 )(d) requires that Denison post a copy of the Notice in a
conspicuous place.
Specifically, the Notice lists the following violation:
"Denison's Radioactive Material License Number UT 1900479 Amendment No. 3; Condition 9.6
states:
'Standard operating procedures stiall be established and followed for all operational
process activities involving radioactive materials that are handled, processed, or stored.
SOPs for operational activities shall enumerate pertinent radiation safety practices to be
followed. Additionally, written procedures shall be established for non-operational
activities to include in-plant and environmental monitoring, bioassay analyses, and
instrument calibrations. An up-to- date copy of each written procedure shall be kept in
the mill area to which it applies.'
The White Mesa Mill Radiation Protection Manual, Section 1.2.1; Restricted Area, states:
'All personnel who enter the Restricted Area will monitor themselves each time they
leave the Restricted Area and at the end of their shift. The Radiation Safety Department
will review the monitoring information. All personnel exiting the Restricted Area must
initial a record of their monitoring activity.'
The White Mesa Mill Radiation Protection Manual, Section 1.2.3: Monitoring Procedures,
step 2, states: 'An individual monitors himself by slowly passing the detector over their
hands, clothing and shoes, including the shoe bottoms, at a distance from the surface of
approximately U inch. An area that is suspected of possessing any contamination (i.e.
hands, boots, visible spotting/stain on clothing etc.) should be carefully monitored by
placing the detector directly on the surface and note the measurement.'
Contrary to the above, on May 28, 2008, while leaving the Mill site at the end of their
shift, all of the approximately 25 individuals observed exiting at the guard shack
monitoring point failed to properly monitor before exiting the restricted area. Monitoring
deficiencies included surveying at a rate of speed too fast to sufficiently detect alpha
contamination; surveying at a distance from the body too far to detect alpha
contamination; and failure to completely survey all surfaces (i.e., hands, clothing and
shoes). Some individuals violated one of the above criteria while others violated all or a
combination of the three.'
The Notice also states that:
"In addition, the DRC is concerned regarding access control issues in that a previous
Severity Level III NOV was imposed in October 2007 for similar violations relating to
personnel exit monitoring..."
Denison responds as follows:
1. Root Cause of the Noncompliance
This violation resulted from independent contract workers exiting the Mill's restricted area without
scanning properly. We understand that each of the workers did scan and initial a record of his or her
monitoring activity, but their manner of scanning was inadequate
We have reviewed this matter carefully and have concluded that the root causes of this violation are
as follows:
All Mill workers and independent contract workers are provided training on proper scanning
techniques upon exiting the Mill's restricted area, and are advised of the consequences of not
performing a proper scan in accordance with Mill procedures.
However, to date, Denison has relied upon the honor system for each worker to properly scan himself
or herself in accordance with the procedures. Mill radiation safety staff have not performed these
DENISO
MINES
scans for the workers, nor have radiation safety staff systematically monitored the actuai scanning
performed by workers as they leave the site.
The Mill has relied on this honor system, spot checking of scanning procedures, and on the
imposition of strict sanctions if a worker is observed to not be scanning properly. A number of
workers have been fired or their contracts terminated in the recent past for these reasons.
The observations of the inspectors during this inspection, however, have made it evident that this
system of worker scanning with the threat of sanctions can not always be relied upon for all
employees and contractors at the site. Some workers or contractors may not fully understand how to
properiy scan themselves, or may choose not to properly scan. Changes to Mill procedures are
therefore necessary to address this issue.
2. Corrective Actions Which Have Been Taken by Denison and the Results Achieved
The following initial, interim, corrective actions have been taken by Denison:
a) All Mill workers have been reminded of the importance of proper scanning and the
consequences of failing to do so. This message has been given to the workers at various
training and operations review sessions.
b) In giving initial independent contractor training, radiation safety staff have emphasized these
same points.
c) A sign has been posted at the main scanning station (by the guard shack) reminding
personnel what is required for a proper scan.
d) Mill radiation safety staff have been more vigilant in observing worker scans on a spot check
basis.
Since the inspection. Mill radiation staff have not observed any further violations of proper personnel
scanning procedures. In circumstances where a worker could have performed a better job at
scanning, the radiation safety personnel have provided on-the-spot instructions.
3. Corrective Actions Which Will be Taken to Avoid Further Items of Noncompliance
In order to prevent a further occurrence of this type of violation, the Mill will take the following actions:
a) A new security system is being installed that will limit the number of locations where
personnel can exit the Mill's restricted area. This will include the following:
(i) Limiting access through the entry to the Administration Building near the Radiation
Safety Department to only Radiation, Environmental and Safety staff. Mill Management
and Mill Supervisory Staff. Those personnel will be required to perform their own
scanning following existing procedures. Because of the seniority of these personnel,
Denison is confident that they will all perform proper scans on themselves in
accordance with Mill procedures.
(ii) Limiting access through the entry to the Administration Building from the laboratory
area to Senior Lab Personnel, Radiation, Environmental and Safety Staff, Mill
Management and Mill Supervisory Staff. Those personnel will be required to perform
their own scanning following existing procedures. Because of the seniority of these
personnel, Denison is confident that they will all perform proper scans on themselves
in accordance with Mill procedures.
DENISO
MINES
(iii) Directing all truck traffic to exit at the scale house, where scans will be performed on
personnel, as required, by a Radiation Safety Technician.
(iv) All other personnel and workers, will be required to exit the restricted area via the main
exit at the guard shack. A Radiation Safety Technician will be positioned at that
location during peak exit times, such as during breaks, and at the ends of shifts, to
observe that each worker is performing a proper scan. Radiation safety personnel will
also continue to be more vigilant at performing spot checks on personnel scanning at
other non-peak times throughout each day.
b) Denison is also evaluating installing an automated full body scanning portal at the main exit,
which would require each worker exiting at that location to scan him or herself by exiting
through the portal. If Denison decides to install such a scanning portal, a Radiation Safety
Technician would not be required to be in attendance to observe scanning (as described in
item 3(a)(iv) above) nor would additional spot cheeks be required; however a Radiation
Safety Technician would be on call and readily available to assist in the event that there is a
problem with the machine, or if a worker fails to clear through the scan.
c) Mill Radiation Safety personnel, will continue to emphasize the importance of proper
scanning, and the consequences of failure to do so, during all applicable employee and
contractor training sessions.
4. Date When Full Compliance Will be Achieved.
The actions listed in item 3(a) will be in effect by the end of July, 2008. A decision as to whether or
not the Mill will acquire a full body scanning portal will be made by the end of August, 2008. The
actions listed in item 3(c) are currently in effect and are ongoing.
A copy of the Notice of Violation has been posted in the Administration Building, in accordance with
R313-18-11(1)(d).
If you have any questions or require any further information, please contact the undersigned.
Yours truly,^
Da/y 0. Frydenlund
Vice President Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David Turk
DENISO
MINES
SENDER: C 7DD7. D71D DDDD 7T^D h^EE N ON DELIVERY
Complete Items 1,2, and 3. Also complete
item 4 if Restricted Delivery is desired.
Print your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
• Agent
• Addressee
C. Date of Delivery
1 ] 2flfl8
6/6/08 Inspection conducted May 28 & 29 2008/kc |
I
MR DAVID FRYDENLUND i
VICE PRESIDENT AND GENERAL COUNSEL ;;
INTERNATIONAL URANIUM (USA) CORPORATION jt;
INDEPENDENCE PLAZA STE 950
1050 SEVENTEENTH STREET
DENVER CO 80265
D. Is delivery address different from item 1 ? • Yes
If YES, enter deli^ijry address^belovsTr^r^D No
j 3. S^ice Type
\ ^Certified Mail
• Registered
• Insured Mail
nu Expre^-Maij ^^0$
4. Restricted Delivery?
|DR%|5i^g^S^Merchand|y^
>'(B(traFee) \ • \fes%^ f
2. Article Number
(Transfer from se/v/ce label)
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ;
ru ru I
IT 1
a cr cr
CD a a
CD
a
a
n-a
CD
U^S. Posta l Servl
(pbmestie Mail Only-No Insurance Coverage Provided)
For delivery information visit our websjte at wwvy.usps.com®
H.y7
Postmark
Here
Postage
Certified Fee
Return Receipt Fee (Endorsement Required)
Restricted Delivery Fee
pr.rl«r««~. * " ' - "
, 6/6/08 Inspectjon conducted May 28 & 29 2008/kc
i
MR DAVID FRYDENLUND
VICE PRESIDENT AND GENERAL COUNSEL
INTERNATIONAL URANIUM (USA) CORPORATION
INDEPENDENCE PLAZA STE 950
1050 SEVENTEENTH STREET
DENVER CO 80265
'^Printecl on 100% recycled paper
State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executive Director
Division of Radiation Control
Dane L. Finerfrock
Director
CERTIFIED MAIL
RETURN RECEIPT REOUIRED
JON M. HiprSMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
June 6, 2008
David Frydenlund, Vice-President and General Counsel
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, Colorado 80265
RE: Inspection conducted May 28 and 29, 2008; Notice of Violation: Radioactive Material
License Number UTI 900479
Dear Mr. Frydenlund:
On May 28 and 29, 2008, an inspection was* conducted at your facility by Kevin Carney, a
representative of the Division of Radiation Control of the Utah Department of Environmental
Quality. Results of the inspection were discussed with management at the conclusion of the
inspection.
The inspection was an examination of the activities conducted in your facility as they relate to
comphance with the Utah Radiation Control Rules and the conditions of the license. The
inspection consisted of selective examinations of procedures and representative records,
interviews of personnel, independent measurements, and observations by the inspector.
It was noted that not all of your activities were conducted in compliance with State requirements.
A Notice of Violation and Notice of Proposed Imposition of Civil Penalties is enclosed. The
particular violations are described in the enclosed Notice. Please continue to remember that
radiation safety is the responsibility of the licensee.
UTAH RADIATION CONTROLBOARD
Dane L. FinOTirock, Executive Secretary
cc: Steve Landau, Corporate Radiation Safety Officer
Enclosure
168 North 1950 West • PO Box 144850 - Salt Uke City, UT 84114-4850 • phone [phone] • fax [phone]
T.D.D. [phone] • www.i/e^.w/fl/z.^ov
Printed on 100% recycled paper
.3Nn a3iioa.iv.anod
• -ssaaaav Naniaa do iHOia 3Hi Oi
3d013AN3 dO'dOi iV d3>IOIiS 33V1d
I Complete items T and/or for additional services.
I Complete items 3, 4a, and 4b.
RF NOV OF PROPOSED IMPOSI TION OF CIVIL PEhJALTY 'Q article num^bfer.
RML NO U T1900479 ^ KEVIN CARNEY [ed and the -dite
f CM
3. Article Addressed to:
A TTN OAViD C FF^yDENLUND —^
V!CE PRESIDENT AND GENERAL COUNCIL
UtNI JON MINES (USA > CORPORATION
INDEPENDENCE PLAZA STF %0
1050 ITTH STRE.FT STF 9*^0
DENVER CO 80265
^al^se-wlslajo receive the
^.^l^lowil^services m-f^^
^^extraje):-^^;^^
1. & Addresset^iS^Address
^Consult posfmaster||)i| fee.
0
U I
a> •
CO
4i^MArticle Nurriber 8^
ocr
4b\Sfen/ice Tyfig^^
• Re^is|ered
• Expffe^teil^f;^ o|,
• Return ReceipffofMefchanciise • COD
Certified
Insured
w 1
3 nDate ofiDelivery p
3 !
c I
L Received By: (Print Name)
j^Signature;^ (^dresses hr Aaent)
\ddressee's Address (Only if requested
and fee is paid)
i2 PS Form 3811, December 1994 102595-98-B-0229 Domestic Retum Receipt
U.S. Postal Service
CERTIFIED MAIL RECEIPT
(Domestic Mail Oniy; No Insurance Coverage Provided)
CO
zt cr
Ul
C3
€3; a a
CD
ATTN DAVID C FRYDENLUND
VICE F^RESIDENT AND GENERAL COUNCIL
DENISON MINES (USA) CORPORATION
INDEPENDENCE PLAZA STE 950
1050 17TH STREET STE 950
a
a a cn
F^E NOV OF PROPOSED IMPOSITION OF CIVIL PENALTY
RML NO UT1900479 - KEVIN CARNEY
'sVree't''Apt. No.; or PO Box No.
City, State, ZIP+4
rm 3800, Febru See Reverse for Instructio
State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executive Director
Division of Radiation Control
Dane L. Finerfrock
Director
JON M. HUNTSMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
July 25, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUIRED
David Frydenlund, Vice-President and General Counsel
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, Colorado 80265
Re: Notice of Violation and Notice of Proposed Imposition of Civil Penalty: Radioactive Material
License Number UT1900479.
Dear Mr Frydenlund:
The Utah Division of Radiation Control (DRC) has received your response to the above-
referenced Notice of Violation and Notice of Proposed Imposition of Civil Penalty dated July 10,
2008. The check in the amount of $2,500 payable to the State of Utah, in satisfaction of the civil
penalty imposed in connection with this Notice of Violation was recei ved.
The reply to the Notice of Violation includes: (1) corrective actions which have been taken by you
and the results achieved; (2) corrective actions which will be taken to avoid further items of
noncompliance; and (3) the date when full compliance will be achieved, which satisfies the
requirements of Utah Rule R313-14-15.
Section 1, Root Cause of the Noncompliance, of your response letter stated, "The Mill has relied
on this honor system, spot checking of scanning procedures, and on the imppsitioa of strict
sanctions if a worker is observed not to be scanning properly. A number of workers have been
fired or their contracts terminated in the recent past for these reasons." Section 1 also stated, "The
observations of the inspectors during this inspection, however, have made it evident that this
system of worker scanning with the threat of sanctions can not always be rehed upon for all
employees and contractors at the site. Some workers or contractors may not fully understand how
to properly scan themselves, or may choose not to properly scan. Changes in Mill procedures are
therefore necessary to address this issue."
168 North 1950 West • PO Box 144850 • Salt Lake City, UT 84114-4850 • phone [phone] • fax [phone] ^
T.D.D. {^0\)536-44\4'www.deq.utali.gov
Printed on 100% recvcied naner
Page 2
The DRC agrees that an honor system of worker scanning with the threat of sanctions cannot
always be relied upon and that changes in Mill procedures are necessary to address this issue.
In Section 2, Corrective Actions Which Have Been Taken by Denison and the Results Achieved,
of your response letter, your corrective actions include: reminding workers of the importance of
proper scanning, emphasizing these same points in initial independent contractor training, posting
proper scanning instructions and more vigilance by the radiation safety staff.
In Section 3, Corrective Actions Which Will be Taken to Avoid Further Items of Noncompliance,
of you response letter, you have proposed limiting access through certain exits from the restricted
area to certain personnel, requiring tmck drivers to be scanned by a Radiation Safety Technician
and positioning a Radiation Safety Technician at the guard shack during peak exit times. The
DRC acknowledges that these changes will be implemented by July 31, 2008. You also stated that
you are evaluating installing an automated full body scanning portal at the main exit.
These actions may reduce the recurrence of the scanning deficiencies at the Mill and the DRC
supports your efforts. We encourage you to instill a culture throughout the Mill which motivates
employees and contractors to monitor themselves properly because they understand the risks
involved in radioactive materials leaving the facility and not because it is just another requirement
imposed by the regulations.
In order to close out the Notice of Violation, the DRC requests the licensee provide the revised
Mill procedures including what changes were made, the date of implementation and the date when
training on the revised procedures will take place. Please provide the revised procedures by
August 22, 2008. If you have any questions or concems, please contact Kevin Camey at (801)
536-4250.
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
DLF/KJC:kjc
cc: David Turk, Site RSO
168 North 1950 West • PO B'6x 14485G^*» Salt Lake City, UT 84114-4850 • phone [phone] • fax [phone]
T.D.D. [phone] • www.deq.utah.gov
Printed on 100% recycled paper
UTAH RADIATION CONTROL BOARD
NOTICE OF VIOLATION
AND
NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTY
Denison Mines (USA) Corp.
6425 Highway 191
Blanding, Utah 84511
License Number UTI 900479
During an inspection conducted by representative(s) of the Utah Division of Radiation Control on May 28
and29,2008, a violation of the Utah Radiation Control Rules was identified. In accordance with R313-14,
"Violations and Escalated Enforcement", the violation is set forth below:
Denison's Radioactive Material License Number UT 1900479 Amendment No. 3, Condition 9.6 states:
"Standard operating procedures shall be estabhshed and followed for all operational process activities
involving radioactive materials that are handled, processed, or stored. SOPs for operational activities shall
enumerate pertinent radiation safety practices to be followed. Additionally, written procedures shall be
established for non-operational activities to include in-plant and environmental monitoring, bioassay
analyses, and instmment calibrations. An up-to-date copy of each written procedure shall be kept in the
mill area to which it applies."
The White Mesa Mill Radiation Protection Manual, Section 1.2.1; Restricted Area, states:
"All personnel who enter the Restricted Area will monitor themselves each time they leave the Restricted
Area and at the end of their shift. The Radiation Safety Department will review the monitoring
information. All personnel exiting the Restricted Area must initial a record of their monitoring activity ."
The White Mesa Mill Radiation Protection Manual, Section 1.2.3; Monitoring Procedures, step 2, states:
"An individual monitors himself by slowly passing the detector over their hands, clothing and shoes,
including the shoe bottoms, at a distance from the surface of approximately VA inch. An area that is
suspected of possessing any contamination (i.e. hands, boots, visible spotting/stain on clothing etc.) should
be carefully monitored by placing the detector directly on the surface and note the measurement."
Contrary to the above, on May 28, 2008, while leaving the Mill site at the end of their shift, all of the
approximately 25 individuals observed exiting at the guard shack monitoring point failed to properly
monitor before exiting the restricted area. Monitoring deficiencies included surveying at a rate of speed too
fast to sufficiently detect alpha contamination; surveying at a distance from the body too far to detect alpha
contamination; and failure to completely survey all surfaces (i.e., hands, clothing and shoes). Some
individuals violated one ofthe above criteria while others violated all or a combination ofthe three.
In accordance with R313-14-10, "Severity of Violations", this violation has been characterized as Severity
Level III. The base penalty for this Severity Level is $2,500.00. A civil penalty of $2,500.00 is proposed.
168 North 1950 West • PO Box 144850 • Salt Uke City, UT 84114-4850 • phone [phone] • fax [phone]
T.D.D. {^0\) 536A4]4'www.deq.utah.gov
Printed on 100% recycled paper
Page 1
UTAH RADIATION CONTROL BOARD
NOTICE OF VIOLATION
AND
NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTY
The DRC is concemed regarding access control issues in that a previous Severity Level III NOV was
imposed in October 2007 for similar violations relating to personnel exit monitoring. Specifically, in a
written response to the DRC dated November 28,2007 regarding the October violation, the Licensee stated
the following: "On October 17, 2007, the RSO held a special training session for all Mill employees
relating specifically to this NOV and proper compliance with all scanning procedures. During that training,
the following topics were emphasized..... (iv) Reminding all employees that, as part of their new hire
training, they signed an acknowledgement that they had received training on proper scanning procedures
and that failure to comply with these procedures is cause for disciplinary action." The letter further states,
"The Mill RSO and Mill Manager have been reminded that strict adherence to scanning procedures and
requirements is expected and that it is incumbent upon them and other Mill management to ensure that the
proper compliance culture is maintained at the site."
The licensee may, within 30 working days of receipt of this Notice, pay the civil penalty in the amount of
$2,500.00, or may protest the imposition of the civil penalty in whole or in part by a written answer.
Should the licensee fail to answer in the time specified, the Utah Radiation Control Board will issue an
order imposing a civil penalty in the amount proposed.
Any reply to the Notice of Violation should include: (1) corrective actions which have been taken by you
and the results achieved; (2) corrective actions which will be taken to avoid fixrther items of
noncompliance; and (3) the date when fiill compliance will be achieved. A response protesting the
Imposition of Civil Penalties shall include: (1) an admission or denial of the item of non-compliance; (2) a
demonstration of extenuating circumstances; (3) a showing of error in the Notice of Violation; or (4) other
reasons why the penalty should not be imposed. Address your written response to Dane Finerfrock.
R313-18-1 l(l)(d) requires that you post a copy of this Notice in a conspicuous place. Should you have
any questions conceming this Notice, please contact Kevin Camey at [phone].
Dated at S^t Lake City, Utah
This davofJune/2008
UTAH RADIATION CONTROL BOARD
Dane L. Finerfrock, Executive Secretary
DLF/KJC:kjc
168 North 1950 West • PO Box 144850 • Salt Uke City, UT 84114-4850 • phone [phone] • fax [phone]
T.D.D. [phone] • wmv.i/e^.wm/i.gav
Printed on 100% recycled paper
Page 2
INSPECTION REPORT
Inspection Module: RADMOD-PEM-01
Inspection Location: White Mesa Mill, Blanding, Utah
Inspection Items: Exit Surveys, Routine Surveys and Radiological Postings
Inspection Dates: May 28-29, 2007
Inspector: Kevin Camey, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk, Dave Frydenlund
Goveming Documents: Radioactive Material License UT1900479; License Renewal Application
dated February 28, 2007: Radiation Protection Manual, Appendix E,
Sections 1 and 2; ALARA Program Manual, Appendix I, Section 2;
10CFR20; and Utah Administrative Code R313-15; 49CFR173.
Opening Meeting
The opening meeting was held in the Administration Building conference room at 08:30 a.m. on
May 28, 2008. Present were: John Hultquist, Ryan Johnson and Kevin Camey of the Utah Division
of Radiation Control; Dave Turk (RSO), Dave Frydenlund (V.P. Regulatory Affairs & Counsel),
Mike Spillman (Safety Manager) and Rick Bartlett (Mill Manager) of Denison Mines; Doug
Mandeville, R.K. Wild and Andrea Ferkile of the Nuclear Regulatory Commission.
The inspectors informed the Denison staff that there would be two inspections conducted and
discussed the items that would be included in the inspections. The inspectors also requested
documentation necessary to aid in the inspections. The NRC staff was present to observe the
inspections performed by the DRC inspectors as a follow up to the 2007 IMPEP review.
Inspection Summarv
Inspection included document review of personnel exit monitoring logs, routine alpha survey results,
weekly and monthly inspections and daily instrument checks. A walk-through inspection of the
facility included spot checks by the inspector for alpha contamination in several areas included on
the Mill's routine survey logs, verification of postings for radiation areas, airbome radioactivity areas
and radioactive material postings at mill entrances. Observations of personnel performing exit
monitoring at several Mill exit locations was also performed.
1 of Page 5
Findings
During observations of personnel exit monitoring, a vast majority of personnel did not properly
monitor. Improper monitoring included: surveying at a rate of speed too fast to sufficiently detect
alpha contamination, surveying at a distance from the body too far to detect alpha contamination and
failure to completely survey all surfaces (i.e., hands, clothing and shoes).
Inspection Items
Item 1 EXIT SURVEYS
The inspector observed personnel exit monitoring at three separate exits from the restricted area of
the Mill during the lunch break and again at the end of the work day. Approximately 6 workers were
observed exiting the lab area at lunch time and approximately 25 workers were observed at the
"guard shack" at 1700 hours while leaving the Mill facility. Two were observed at the west Admin
Bldg door during the day's activities.
The inspector verified that the alarm set-points for the exit monitors at the three main exits from the
restricted area were set to alarm within 500 to 700 dpm/lOOcm^ alpha.
The inspector reviewed exit monitoring logs to verify that personnel were logging out when exiting
the restricted area.
Deficiencies:
The Mill's Radiation Protection Manual, Section 1.2.3 step 3, states: "An individual monitors
himself by slowly passing the detector over their hands, clothing and shoes, including the shoe
bottoms, at a distance from the surface of approximately V4 inch. An area that is suspected of
possessing any contamination (i.e. hands, boots, visible spotting/stain on clothing etc.) should be
carefully monitored by placing the detector directly on the surface and note the measurement."
Contrary to the above requirement, all of the individuals exiting at the guard shack monitoring point
failed to properly monitor before exiting the restricted area. Monitoring deficiencies included
surveying at a rate of speed too fast to sufficiently detect alpha contamination; surveying at a
distance from the body too far to detect alpha contamination; and failure to completely survey all
surfaces (i.e., hands, clothing and shoes). Some individuals violated one ofthe above criteria while
others violated all or a combination of the three.
Item 2 ROUTINE SURVEYS
The inspector performed a walk through inspection of the Mill and performed spot check fixed and
removable alpha contamination surveys at several places during the inspection. These surveys were
performed in areas that are listed in the Mill's Radiation Protection Manual Table 2.3.1-2. The Areas
included: Maintenance Lunchroom Tables, Warehouse Office Desks, Chemical Laboratory Desks
and Change Room Lunch Tables. No contamination above background was found.
2 of Page 5
The inspector reviewed weekly routine survey documentation for the months of March, April and
May 2008. These surveys included areas that are listed in the Mill's Radiation Protection Manual
Table 2.3.1-2. Section 2.3.2 of the Mill's Radiation Protection Manual states: "Fixed and removable
alpha surveys are made at those general locations on the Table 2.3.2-1, "Alpha Area Survey
Locations." Surveys are completed weekly during production periods. During non-production
periods, only those areas designated by the RSO as authorized lunchroom/breaks areas are
monitored." The RSO verified to the inspector that the Mill has been in a "production period" for the
period that documents were reviewed. Table 2.3.2-1 is as follows:
Table 23.2-1
Wliite Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Lunch Tables
Maintenance Lunchroom Tables
Mill Office Lunchroom Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
All survey records were in order with the following exceptions:
• In heu of documented surveys forthe weeks of March 17-21,2008 and March 24-28,2008, a
letter was posted in the survey log book stating that the surveys were not performed due to all
three of the Mill's alpha survey instmments either out for calibration or otherwise non-
operational. The RSO was interviewed conceming this situation and informed the inspector
that steps were being implemented to prevent recurrence of this problem. The steps include:
staggering instrument calibration periods, purchasing additional alpha survey instruments
and/or temporarily utilizing one of the exit monitoring survey instruments to perform the
routine surveys.
• The 'Locker/Change Room and New Lunch Room' survey for the week of March 30 to April
4, 2008 was missing from the survey logs. The RSO informed the inspector that he would
search the survey files and try to locate the survey.
The inspector reviewed weekly and monthly inspection reports. The Mill's ALARA Program,
Section 2.3.1, requires the RSO or designee to perform daily inspections throughout the Mill and
document the results on the Daily Mill Inspection form. Section 2.3.2 requires the RSO and Shift
Foreman or designees to perform weekly inspections throughout the Mill and document the results
on the Weekly Mill Inspection form.
3 of Page 5
No problems other than minor typographical errors were identified. These errors were brought to the
RSO's attention.
Deficiencies: None
Item 3 RADIOLOGICAL POSTINGS
Utah Administrative Code R313-15-902( 1) requires that the licensee post each radiation area with a
conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIATION
AREA" and 10CFR20.1003 defines a Radiation Areas as an area, accessible to individuals, in which
radiation levels could result in an individual receiving a dose equivalent jn excess of 0.005 rem
(0.05 mSv) ih 1 hour at 30 centimeters from the radiation source or from any surface that the
radiation penetrates.
The inspector performed a walk through inspection of the Mill and performed spot check gamma
radiation surveys to verify Radiation Area postings and boundaries. The inspection also included
verification of Airbome Radioactivity Area postings and postings at the Mill entrances required by
Utah Rule R313-15-902(4) stating, "Any area in this mill may contain radioactive materials."
All Radiation Area postings were appropriately placed and no un-posted radiation areas were
identified. All Airbome Radioactivity Areas were appropriately posted including the Yellowcake
Drying and Packaging areas and the SAG Mill.
The inspector identified three gated entrances to the restricted area of the Mill site that were not
posted in accordance with Utah Rule R313-15-902(4). The RSO informed the inspector that he
would have the gates posted as soon as possible.
Deficiencies: None
Item 4 SHIPPING CONTAINER LABELING
As a follow-up to a previous concem involving shipping container labehng, the inspector looked at
several shipping containers that were loaded onto outgoing trucks for transportation out of the Mill.
The containers were being shipped as 'Empty' containers subject to the requirements of
49CFR173.428. All containers were properly labeled in accordance with 49CFR173.428.
Deficiencies: None
Closeout Meeting
The closeout meeting was held in the Administration Building conference room at 1:00 p.m. on May
29, 2008. Present were: John Hultquist, Ryan Johnson and Kevin Camey of the Utah Division of
Radiation Control; Dave Turk (RSO), Dave Frydenlund (V.P. Regulatory Affairs & Counsel), Mike
Spillman (Safety Manager) and Rick Bartlett (Mill Manager) of Denison Mines; Doug Mandeville,
R.K. Wild, Andrea Ferkile and Linda McClain of the Nuclear Regulatory Commission.
4 of Page 5
The inspectors informed the Denison Mines staff of the results of the inspections performed and
recommendations for improvement to the Mill's various radiological safety programs. This inspector
discussed the minor deficiencies identified pertaining to documentation, instrumentation issues and
postings at gated entrances to the restricted area of the Mill.
The inspector also discussed the finding related to personnel exit monitoring with the Mill staff.
Conclusion and Recommendations
The inspector is satisfied with the corrective actions cited by the Mill's RSO pertaining to the gate
signs and the weekly routine alpha surveys. However, the deficiencies in exit monitoring
demonstrated by Mill personnel are of significant concem. These deficiencies seem to be the status
quo among Mill personnel and in no way sufficiently demonstrates that no radioactive material is
being removed from the Mill in the form of personnel contamination. During a previous inspection
conducted at the Mill by DRC inspectors in October 2007, personnel were observed leaving the
restricted area without properly scanning. A Notice of Violation was issued to the Mill and a letter
dated November 28, 2007 from David Frydenlund of Denison Mines was sent to the Utah DRC
outlining corrective actions to circumvent recurrence of improper exit monitoring. Listed among the
corrective actions were, "On October 17, 2007, the RSO held a special training session for all Mill
employees relating specifically to this NOV and proper compliance with all scanning procedures."
"Reminding all employees that, as part of their new hire training, they signed an acknowledgement
that they had received training on proper scanning procedures and that failure to comply with these
procedures is cause for disciplinary action." The letter also states, "The Mill RSO and Mill Manager
have been reminded that strict adherence to scanning procedures and requirements is expected and
that it is incumbent upon them and other Mill management to ensure that the proper compliance
culture is maintained at the site." The inspector recommends a Severity Level IQ Notice of Violation
with a base civil penalty of $2,500.00 be imposed.
Recommendation for Next Inspection
1. Observe exit monitoring at restricted area exits to verify compliance.
2. Inspect Mill entrances to ensure proper postings.
3. Review weekly alpha survey logs after May, 2008.
Prepared By: Kevin J Camey V-g^,.^^ —<^ ^ b
(Print Name) ^^^11(14^^1^5 ~/ (Date)
5 of Page 5
UTAH DIVISION OF RADIATION GONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-PEM-01
SURVEYS/POSTINGS/EXIT MONITORING
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Radioactive Material License UTI900479; License Renewal Application dated February
28, 2007: Radiation Protection Manual, Appendix E, Sections 1 and 2; ALARA Program
Manual, Appendix I, Section 2; 10CFR20; and Utah Administrative Code R313-15;
49CFR173.
Date of Inspection: ^ I 2-% I Inspector(s) K^luiM^
EXIT SURVEYS
Radiation Protection Manual Section 1.2.1, Restricted Area, states "All personnel who enter the
Restricted Area will monitor themselves each time they leave the Restricted Area and at the end of their
shift. The Radiation Safety Department will review the monitoring information. All personnel exiting
the Restricted Area must initial a record of their monitoring activity."
1) Did all employees observed monitor themselves in accordance with the Radiation Protection Manual
Section 1.2.1 upon exit from the Restricted Area?
Yes No /
Comments:
Ay^^ I>fTfy(<L , ff<>h(^€^$ /M£i^^ci - .S^^'^n^^^^'^^ -jpZ^T^sij ^S^'^'-^^yJ^^
Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to
perform proper personnel monitoring.
2) Section 1.2.3 step 1.
Were all exit monitor (count rate meter) alarms adjusted within the range of 500 to 750 dpm/lOOcm^?
(Note: Because the Ludlum Model 177 reads out in counts per minute and because the Ludlum Model
43-5 probe has an effective surface area of 50 cm^, ensure proper calculations were used to achieve a
500 to 750 dpm/1 OOcm^ range).
Yes y/ No
Comments:
U:\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2008\RADMOD-PEM-01
3) Section 1.2.3 step 2.
Did all observed personnel exiting the Restricted Area slowly survey their hands, clothing and shoes,
including the shoe bottoms, at a distance from the surface of approximately 14 inch?
Yes No
Comments:
4) Section 1.2.3 step 6.
Has the licensee provided documentation of individual (exit) surveys being logged and initialed?
Comments
Yes y No
ROUTINE SURVEYS
The Mill's Radiation Protection Manual, Appendix E, Section 2.3 requires the licensee to perform alpha
surveys, both fixed and removable, at regular intervals in particular areas of the Mill. Table 2.3.2-1 lists
the areas to be surveyed. Section 2.3.2 requires the listed areas to be surveyed on a weekly basis during
production periods. During non-production periods, only those areas designated by the RSO as
authorized lunchroom^reak areas are monitored.
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Lunch Tables
Maintenance Lunchroom Tables
Mill Office Lunchroom Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
U:\rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection moduIes\2008\RADMOD-PEM-01
5) For the period including the last three (3) months, on what dates was the Mill considered in
"production periods" and in "non-production periods"?
1 st Month 2nd Month 3rd Month
Production Periods Ml
Non-Production Periods -—
Comments nments: / / ^ H - / ^/
6) During production periods, were all areas listed in Table 2.3.2-1 surveyed for removable alpha as per
Section 2.3.2? ^
Yes.-^ No
Comments:
7) During production periods, were all areas listed in Table 2.3.2-1 surveyed for fixed alpha as per
Section 2.3.2? ^
Yes^-^ No
Comments:
-^(^ ^he^^
8) During non-production periods, were all areas designated by the RSO as authorized lunchroom/break
areas surveyed for removable alpha as per Section 2.3.2?
Yes No fufjf^^j^
Comments:
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2008\RADMOD-PEM-01
9) During non-production periods, were all areas designated by the RSO as authorized lunchroom/break
Yes No /1P>
areas surveyed for fixed alpha as per Section 2.3.2? ^
Comments: ^ / A » ^ / /
The Mill's ALARA Program, Section 2.3.1, requires the RSO or designee to perform daily inspections
throughout the Mill and document the results on the Daily Mill Inspection form. Section 2.3.2 requires
the RSO and Shift Foreman or designees to perform weekly inspections throughout the Mill and
document the results on the Weekly Mill Inspection form.
Inspector shall review inspection documents for the period including the last three (3) months.
10) Has the licensee performed the daily Mill Inspections in accordance with Section 2.3.1?
Yes v/ No
Comments:
11) Were the forms completed to satisfy the requirements of Section 2.3.1?
Yes \/ No
Comments:
12) Has the licensee performed the weekly Mill Inspections in accordance with Section 2.3.2?
Yes \/ No
Comments:
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2008\RADMOD-PEM-01
13) Were the forms completed to satisfy the requirements of Section 2.3.2?
Yes / No
Comments:
RADIOLOGICAL POSTINGS
License Condition 9.9 states: The licensee is hereby exempted from the requirements of R313-15-902(5)
for areas within the mill, provided that all entrances to the mill are conspicuously posted in accordance
with R313-15-902(5) and with the words, "Any area within this mill may contain radioactive material".
14) Has the licensee conspicuously posted all entrances to the mill in accordance with R313-15-902(5)
and with the words, "Any area within this mill may contain radioactive material"?
Yes_ No y
Comments:
Utah Administrative Code R313-15-902(1) requires that the Hcensee post each radiation area with a
conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIATION
AREA."
10CFR20.1003 defines a Radiation Areas as an area, accessible to individuals, in which radiation levels
could result in an individual receiving a dose equivalent in excess of 0.005 rem (0.05 mSv) in 1 hour at
30 centimeters from the radiation source or fi*om any surface that the radiation penetrates.
15) Were all radiation areas posted in accordance with R313-15-902(l)?
Yes No
U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2008\RADMOD-PEM-01
16) Were all posted Radiation Area boundaries found to be < 5mrem/hr?
Yes y No
Comments:
As required by Utah Administrative Code R313-15-902(4), the Hcensee or registrant shall post each
airbome radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words
"CAUTION, AIRBORNE RADIOACTIVITY AREA" or "DANGER, AIRBORNE RADIOACTIVITY
AREA."
17) Has the licensee employed the proper postings for Airbome Radioactivity Areas in accordance with
R313-15-902(4)?
Yes / No
Comments:
18) Were all radiological postings observed found to be legible, conspicuously posted and unobstmcted?
Yes y No
Comments:
As per the letter from Utah DRC to Denison Mines dated April 8, 2008 regarding transportation
requirements, a follow-up will be conducted conceming the release of containers.
19) As per 49CFR173.428, are all containers observed released by the Mill properly labeled as EMPTY
including all previously used class 7 labels removed prior to shipment?
Yes y No
U:Vad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection modules\2008\RADMOD-PEM-01
Ky^i Pw>. [(de '5
3
t3joo:
f-
/
/
f
w
' • •. • •• • • • • •••• •• • ' .• • • •' •• • ••• • • ' • •• • • . • • • -\ .. ^ •• " .
i •
fe V^^ ^
/" ..• , • •
•
7
yu^-iL.
1^ / i-
11
(A
t K.y ^ : •;•
/%</i i/ilh:Ay&^^
M^/df^f OK
<-
•
, • ,/ ^ / v . V./
i 1 J
: ^ d^^ii'^ oC job's.
• ; •• , V , r *^ • . • •
. " • . . • ' • • ' • •
• . . • ' .. . • • -. ' ' -'•
. • . •• .• •• • •-•!•. . - : • • •• •• • •• ' . • • • • ' . • • • ••. - . • • • . •. ' • • • '\ " • •
• • • 1 . • • • , • . : .
. •. • • i • • ••••• • • ••
•' . ' , • - . .• ' !