DRC-2009-004065 - 0901a06880141abb

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Acting Executive Direclor
OrVlSION OF RADIATION CONTROL
Dane L. Finerfrock
Director
X3ic-9-ctq-ooqotr.s
September 14, 2009
David Frydenlund, Vice-President and General Counsel
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, Colorado 80265
RE: Inspection Module RADMOD TPEM-02, White Mesa Mill, Denison Mines, Radioactive
Materials License Number UTI900479.
Dear Mr. Frydenlund:
On September 1^' and 2^^, 2009, an inspection was conducted at your facility by the Division of
Radiation Control (DRC). Results of the inspection were discussed with your staff at the
conclusion of the inspection.
The inspection was 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 license. The
inspection consisted of selective examinations of procedures and representative records,
interviews of personnel, independent measurements, and observations by the inspector.
During this inspection, the items reviewed were found to be conducted in compliance with the
Utah Radiation Control Rules and requirements for this license. Please continue to remember that
radiation safety is the responsibility of the licensee. Thank you for cooperating in this matter.
If you have any questions or concems regarding this letter, please contact Kevin Carney at (801)
536-4250.
UTAH RADIATION CONTROL BOARD
Dane L. Fi^rfrock, Executive Secretary
DLF/KJC:lcc
cc: David Turk, Site RSO
168 North 1950 Wesi • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Sail Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deQ.utah.f^ov
Printed on 100% recycled paper
Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
Inspector:
Personnel Contacted:
IxspncnoN REPoRT
RADMOD TPEM-02
White Mesa Mill
Rad Worker training, radiological postings and personnel exit monitoring.
September 1 through 2, 2009
Kevin Carney, Utah Division of Radiation Control (DRC)
White Mesa Manasement: Richard Bartlett and David Turk.
Governing Documents:o Radioactive Material License UTI9O0479o License Renewal Application dated February 28,2007
o White Mesa Training Manual, Sections 2 and3
o White Mesa Radiation Protection Manual, Section I
o l0CFR20
o NRC Regulatory Guide 8.30
. Utah Administrative Code R313-15
Inspection Summarv
The opening meeting was conducted on the morning of September 1,20A9.In attendance were Kevin
Carney and Ryan Johnson of the DRC and David Turk of Denison Mines. The Inspector discussed
the areas the inspection would cover and records that would be needed for review. Mr. Turk
explained the current status of Mill operations: the uranium ore circuit is not operating; the alternate
feed circuit is operating and processing UF4; the vanadium circuit is undergoing maintenance and
cleaning; vanadium drums are being repackaged and prepared for shipment; maintenance is being
performed in the yellowcake drying and packaging enclosure.
Findines
No findings were noted during the inspection.
Inspection ltems
Item l. Rad Worker Trainins
Personnel and contractor training records were reviewed to verify the Mill's radiation worker and
respiratory protection training for new hire, re-hired and contract employees during the 2009
calendar year. There were 3 new hire and 4 re-hire employees for 2009. All training records for these
personnel were found to be complete and appropriately filed. Contractor training records for 2009
were reviewed and found to be complete and appropriately filed. Verification of records for training
of declared pregnant workers was not applicable. The Mill had no declared pregnant workers in the
past year.
Deficiencies: None.
I of Page2
C:\Documents and Settings\Kcamey\My Documena\l le2 RMls\Denison - White Mesa\Inspections\TPEM-02\TPEM -02 Insp Rep 9-lG09.doc
UTAH DIVISION OF RADIATION CONTROL
Inspection Module TPEM-02
Denison Mines
White Mesa Mill
Radioactive Materials License W 190047 9
OPENING MEETING
lnspector(s)
Date(s): q/1/0q
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Carney DRC
Rvan Johnson DRC
Dave Turk Denison Mines
U:\rad\COMMON\Uranium mills\ l le(2)UT190O479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
Page I of9
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-TPEM-O2
TRAINING/POSTINGSiEXIT MONITORING
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT19OO479
Inspection Dates: Start 9lll09 End 912109
lnspector(s);
References:
Radioactive Material License UT 1900479
License Renewal Application dated February 28,2007
White Mesa Training Manual, Sections 2 and3
White Mesa Radiation Protection Manual. Section I
lOCFR2O
NRC Regulatory Guide 8.30
Utah Administrative Code R313-15
TRAINING
Training Manual Section 2.0 On-Site Contractors.
"New hire training, as outlined in Section 1.2, is included in the training program, as applicable to the
site work specifications, for on-site contractors."
1) Has the licensee documented initial training of on-site contractors?
[lves nNo
Comments: Reviewed ?009 Contractor Training File. All records complete.
Training Manual Section 3.1 Pre-employment Instruction
"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."
2) Has the licensee documented initial training of new employees?
[lYes nNo
Comments: Reviewed training files of 3 new hire and 4 re-hire employees for 2000. All records are
included in the files.
U:\rad\COMMON\Uranium mills\ I le(2)UT190O479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
Page 3 of 9
Radiation Protection Manual Section 1.2.3, Monitoring Procedures, outlines the steps required to
perform proper personnel monitoring.
7) Section 1.2.3 step 1.
Were all exit monitor (rate meter) alarms adjusted within the range of 500 to 750 dpm/100cm2?
(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 cm2, ensure proper calculations were used to achieve a
500 to 750 dpm/100cm2 range).
[lYes INo
Comments: 2 exit monitoring instruments were checked. The alarm set points were set at 100 cpm. The
inspector calculated the alarm set Foints to be appropriately set between -500 and 750dlm/.100cm2.
8) Section I.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 r/a inch?
Xves ENo
Comments: Appro-imatel), 20 personnel ohserved at the main gate as dayshift was exiting the Mill and
several other Fersonnel e-iting at other exit points durjng the course of the inspection. All frersonnel
observed adequately monitoring prior to erit.
9) Section 1.2.3 step 6.
Has the licensee provided documentation of individual (exit) surveys being logged and initialed?
IYes INo
Comments: Exit logs were present at exit monitoring stations. Fmployees initialed the log Frior to
e-iting.
U:\rad\COMMON\Uranium mills\ l1e(2)UT1900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
Page 5 of 9
Regulatory Guide 8.30.C.6 sets the requirements for establishing Airbome Radioactivity Areas.
13) Has the licensee established Airborne Radioactivity Areas in accordance with Regulatory Guide
8.30.C.6?
fives nNo
Comments: The qre circuit is currently non-operational and no yellowcake drying or lackaging was
taking place during the insFection. The alternate feed circuit is currently operational. The yellowcake
drying and packaging-gnclosure is currently undergoing maintenance. All airhorne or Fotentially
airborne areas were found to he appropriately Fosted.
14) Has the licensee established the yellowcake drying and packaging areas as Airborne Radioactivity
Areas?
IYes nNo
Comments: See comments in #13 above,
As required by Utah Administrative Code R313-15-902(4), the licensee or registrant shall post each
airborne radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words
''CAUTION, AIRBORNE RADIOACTIVITY AREA'' oT ''DANGER, AIRBORNE RADIOACTIVITY
AREA.''
15) Has the licensee employed the proper postings for Airborne Radioactivity Areas in accordance with
R313-15-902(4)?
Xves nNo
Comments: All postings observed met with the requirements of R313-15-00"(4),
U:\rad\COMMON\Uranium milts\ I le(2)UT1900479 Denison Mines - White Mesa UMill\ HP Inspection modules\ RADMOD-TPEM-02.doc
Page7 of9
UTAH DIVISION OF RADIATION CONTROL
Inspection Module TPEM-O2
Denison Mines
White Mesa Mill
Radioactive Materials License W 190047 9
CLOSEOI-TT MEETING
DISCUSSION Of FINDINGS
No finrlings were noterl rirrring the insfection. The inspector noted several minor ohservations and
made several srrggestions for improvement srrch as reinforcing workers' skills for self monitoring and
replacing aging radiological postings- Tnspectors also discrrssed the eafing area changes implemented at
the Mill. The Mill has reduced the numher of eating areas inside the restricted area and has trained
workers on the monitoringrec|rirements for entry into these areas- The inspecfors erpressed their
srrpporf of these imnrovements.
SITE STAFF COMMENTS
The site staff were receptive to the suggestions made perfaining to the inspection and e-Flained the
positve effects ortne ing areas
U:\rad\COMMOf-l\Uranium mills\ 1le(2)UT1900479 Denison Mines - White Mesa UMill\ HF Inspection modules\ RADMOD-TPEM-02.doc