DRC-2009-007885 - 0901a0688025a99d

State of Utah
JON M, HLINTSMAN, JR.
Govertor
GARY HERBERT
Lieutenanl Govennr
Department of
Environmental Quality
William J. Sinclair
A c ting Exectttiv e D i r ec to r
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
BRC- 2[)U ., -0a7885
March 71,2OOg
David Frydenlund, Vice President
Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, Colorado 80265
General Radioactive Material License (RML) Number G3-250
Dear Mr. Frydenlund:
On February 24 arrd25,2OO9, an inspection was conducted at your facility by Ryan Johnson, a
representative of the Division of Radiation Control, Department of Environmental Quality.
Results from the inspection were discussed with Dave Turk and Ronnie Nieves at the close out
meeting.
The inspection.was an examination of the activities conducted in your facility as they relate to
compliance with the Utah Radiation Control Rules. The inspection consisted of personnel
interviews, records reviews and observations by the inspector. Based on the inspection, there are
several findings regarding fixed nuclear gauges. The findings involve leak testing, on-off
mechanism tests, and the condition of required labels. The DRC has chosen to use enforcement
discretion, as it relates to the findings, because the gauge labels indicate that the Licensee has up
to three years to perform a leak test and to test the On-Offmechanism. Therefore, the Licensee
will have time to correct these issues before the next inspection. The particular findings that
were observed by the inspector are set forth below:
1. Improper leak testing of the devices:
R313-21-2 2$)(c)requires lhat Any person who acquires, receives, possesses, uses or
transfers radioactive material in a device pursuant to the general license in R3 I i-21-
22@(a):
(i) shatl assttre that all labels affixed to the device at the time of receipt and bearing a
statement that removal of the label is prohibited are maintained thereon and shall comply
with all instructions and precautions provided by the labels;
(ii) shall assure that the device is testedfor leakage of radioactive material and proper
operation of the on-offmechanism and indicator, if any, at no longer than six-month
intervals or at other intervals as are specified in the label; however:
(iii) shatl assure that the tests required by R313-21-22@(c)(ii) and other testing,
I 68 North 1950 West ' Salt lake City, UT
Mailing Address: P.O. Box 144850 ' Salt Lake City, UT 84114-4850
Telephone [phone] ' Fax [phone] 'T.D.D. (801) 5364414
|9w.deq.utah.gov
Printed on 100% recycled paper
uotttpuoc atq*at ut raq.T a?!^ap aqt urDtulou ,rrr;;:::"X:#:;::{'::li'{:::':rY:;
:uoppuoC IsqB"I redorduq 'E
'ecrlep EufnBE etp uo eclruuelureur ^(tru ol roud petruo;ard eq
plnoqs lueurernber slrlJ'Jolscrpur Jo lusllrugceuJgo-uo eqt {caqc puu lsel {Bel E uuogred
o1 sreer( aeJrD ol dn seq easuesr'J ew }?rD elBcrpur sscr^ep Eu6nuE eq} uo slSqBI er{J
'ac!^ap aqt rc{pnuDu aqt u! ro pqol aqt uo paprlpul so,onlcolnumil aqt tq pagfteads
tcuanba{ aqt w n .spMaru! qruoru 4s p parutoltad uaaq soq 'tuo 11 'totD"!pu! ,to
wsluoUcauSo-uo aryto uouotado ndo,td puo lDQapru a^lpDolPD"tlo a8uloal rc{Eu14sar
tDl,fi ruaancop ot spn?il ulapr lloqs aasua?n aW leql ssrtnbeJ 9 uoqrpuoC esuecrl
:setneg erllJo,rusm?gcey[JJg-u9 erllJo {ceqC puogursdg uu Eurturo;-rad toN 'Z
',&relerceg elrlncexg eql,Sqou 1ou
prp eesuecrl erp prrp uon?urumluocJo ecueserd eqt peleolpul 8OOZ'gl eImI uo penuogred
lsal ryel e 'elouueqlmd 'senIBA papJoceJ erp ol psr6rssu slrun eABg lou p1p sllnseJ
eW leql peurlrnlap pup e1ep ol peuuojlred slssl {pel eW roJ s}ueumcop etp pelrteller
ropedsur uy 'seldurus lsel {uel Eul(ess" pue Eurdtm epnlcut o} esuecrl cgrceds rnod
puetrr? o1 $enbar e e1g ,(eur no1 'tou sI lnq '(6w0O6t 16f asuecr:1 cgrcedg s.eeslrecl'I
erp ul pe1uu.6 eq plnoc uoquzuoqlnu qcns 'druprceg el4ncexg eql ruo{ uoqezlrorprc
lnoqlll(\ slsel {eel rr/(o nerp Euruuo3ued ueeq sBrI easuecrl erp 'sepr essqt ol.&ru4uo3
:slsDq asoc-tq-asvc o uo tko1atcag a^lfi)axg aqt tq pauuuapp so 'a1qoc11ddo
aq tow Z1t-Sf€Ity u! fio ps Dyaqrc aqt 'sacuatstttncnc asaqt rapun 's{op gg
ultlryl^ rttoyatcag a^uncax7 aqt q paqslur{aQ $nru 'asn paprysarun rclalqoqdacco
atD sao4lua puD sastwatd atlt 7oq7 Suunsua .totuo1d o 'suot!^ua aqt ,to raslwatd
aqllo uoltouluDluo? u! ilnsil ot t7aq1 aornos o o7 aSowop tolo an1nln PlDlDw
aopoolpo.t alqD^ouil atou to (lCn EOO'il ptanbcaq ggt lo uo4ca4aplo asnc
aqt u! 'puo lua4q uoucD lDlparuil aW puD Tuaaa aqt{o uouducsaptauq o 3u1u1o7uoc
uodat y 'tn1atcag ai!fi?axfl aqt ,tq paaotddo asld4raqto sp ro a?Kap aqt u! lDy?tolu
a^lpDolpDt aqt a^lnar ot asuaoil cgftcads o tq pazyoqfio uostad o o7 ntsuo.t1
{qlo pasodsgp aq tluo tow anrcp aqt uo{1olnlow avpDolpD.t tuo puo a)t^ap
a[['apg Eu1suac17 t) "to 'awrs TuawaatBV ttD 'ttotsstutruoS ttoqoy8ay nalcnN aql
tq n 77-91ttr npun panss! sol* tDUt a"lnap aqt nodat ot ?suaoil cgficads o Eulp1oq
uouad nqto to.ratntcotnuow aqt ,{q pa4odat ua?q spq U ffrun pa|otado aq rcu ,(ou
a?nap arlJ 'layaww aopDolpD.t alqa^owar atow to (lCn SOO'O) pnnbcaq Sgt to
uoucapp aql uodn fi 'rcwclpu! Jo tus?uaqcaw[o-uo aLlLJo l4nww atg)DolpoJ aqtr
lo &ulp1ags aqt 'ot aSowop toto atqTotalqrssod olo uouz)tput tuo to 'o7 aSouop
to {o atn1ru{o sl anqtfi ao!^ap aqtlo uountado puadms t1aTolpauurl yoqs (t)
:saUhUcD
qcns utoltad o7 a7o7g SwsaactT D Jo 'alqs Tuawaat7y ItD 'ttotssnttwoS ttoqo1n&ay
napnN aqt uottto Zz-tttv ot ruonstnd asunfi cgficads o Sutploq uostad p tq (g)
n :spqq aqt tQ paptraotd suoqcn4sut aW LfltM acuDptoc?D ut (y)
:pautoltad ato 'fliaututDluo) to Zury1a1qs s1t
'slnlt?tuw anpDo?pDt aqtr Sutqotut uollollzlsut wo,t!lotowat pul 'Sutclruas 'uottDllztsul
7e?e4
Contrary to this condition, the device located in the lower SAG Mill was covered in sand
and grit and the label was therefore not legible'
The purpose of the radiation control inspection and compliance program is to assure the
radiological safety of the public, radiation workers, and the environment by encouragng
improvanent of performance, including the prompt identification, reportinB, and correction of
potential safety problems. We will review your response to these concems during a future
inspection. If you have any questions concerning this letter, contact Mr. Ryan Johnson by
telephone at 801-536-4250. Please find attached a copy of the DRC Inspection Report.
UTAH RADIATION CONTROL BOARD
Dane L. Fineftock, Executive Secretary
DLFIRJ:rj
Cc: David Turk, Radiation Safety Officer
Enclosure
INspBcrroN Rrponr
Inspection Module: RADMOD-General License-O1: Fixed Nuclear Gauge Inspection
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Three Ronan Model SA1-C10 Fixed Nuclear Gauges
Inspection Dates: February 24,2009 and February 25,2009
Inspector: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (RSO) and Ronnie Nieves (Radiation Technician)
Governin' Documents.
uac R313-2r
o General RML G3-250
openins Meetins
Denison Mines: Dave Turk (RSo)
Ronnie Nieves (Radiation Technician)
Utah DRC: Ryan Johnson (Inspector)
Kevin Carney (Inspector)
The DRC inspectors opened the meeting with introductions and then a general overview of the
inspection and discussed the inspection modules that Ryan Johnson and Kevin Carney were going
to be doing during this inspection.
Inspection Summarv
. Site Documentation: The inspector reviewed documentation that was related to the Mill's
General License. This included documentation that documents Employee Training, Dosimetry,
Radiological Instrumentation, and Leak Tests.
. RSO Interview: The inspector discussed with the RSO the requirements outlined in the mill's
General License.
. Mill Tour: The inspector participated in a general site tour. During the tour the inspector
looked at each of the three nuclear gauges and took photographs of their condition to document
and to confirm compliance
Inspection Items
Item 1. Security and Control of Licensed Material: The Gauges are located within the
restricted area of the White Mesa Uranium Mill. The Mill's restricted area is surrounded by a
chain link fence and radiation safety technicians are posted 24 hours a day at all open gates.
Deficiencies: None
U:\rad\COMMON\Uranium mills\11e(2)UT1900479 Denison Mines - White Mesa UMillU{P Inspection
modulesV00gVnspection ReportsVnspection Report RADMOD-General License-O1 3-4-09 RJ.doc
1 ofPage 5
g aflEdlo z
rop.Iu 6o-?-E Ig-esuerr-I Iureuec-ootr lcvu uodeu uorlcedsulslrodea uoqcedsul6ggTlsalnpoul
uoqcedsul dFnllll In ESaI ellqrt\ - seuItrAI uoslueq 6tr006IIn(7)e111q1nu umlwrn1{OniruOC\peq:n
sl (dA\$ tpuod ryo1$. uorturpug B ueq^{ see[oldue o] popl^oJd sI Sururzrl uonstpu)I IEIcedS
'reUB aJeql reef fue,re JoJ esJnoo JaqsoqeJ Jnoq ]qBIe ue uI eledIrluud ol poJlnboJ osle sI ea,(olduie
qcug 'Uru urnruE{f EsetrAI etF{t\ eqt le parlq sl uosred B elun eql W 3efoldura r{re,r,e r(q ua>pt
sr esrnoc Eutumrt,(1agus uoItEIpuJ IeDIuI uV :socllruld puu 8upp.r;,$epg uoIlBIpEU '9 ulell
euoN :solcuolJuao
'pe1?301 are se8ne8 eql orer{^\ Surplrnq III-tu [3$3€ el{]
aplsul Surpnlcur ueru pe]crlser eqt lnoq8norqt pe]cnpuoc eru s{alrns pc€o1o1pur eunnoll 'sre}etu
U orcrju 6I urnlpnT puu eqn1 I41D 8op tor{ u q}r^\ reteur g lepory unlpnT sepnlcul uonsluelunJlsul
alEJ esoq 'sqtuoru xrs /fteAe peluJqlpo eJB qclqlt lueudmba ,(e,r-mg uoItBIpEU Jo sad/t luaJeJJIp
pre^es quq IIIhI tunruBrn Bselnl ellq^\ eqJ, :sIo^rns puB uollBluolurufsul uollBIpBU 'S Iuall
auoN :salcuelJua(
'snleJ
eqt ot ornsodxe lepuetod ,(uu p;ocar 01 sl{o€Iuots rleql.rea,o sculd o1 e8puq TSO puoJes u peu8tsse
oJB prru ,(gtuoru pe8uuqcxe se8puq Jleql eABq uoluolyr luuu8erd peJBIseC 'ree[ e ecuo see,(oldure
o1pJocoJ ernsodxe ue seprnord pue ellJ uo stlnser 1p sdeel lueugudep,fie;us UoRBIpBJ eq1,
.srs,(1uuu JoJ srseq ,(peuunb e uo peEuer{oxe ere se8puq esoql 'eEpuq TSO uE peu8tssu uoeq suq
IIrtrA[ IunruBrn BSer I elH \ or{} tB $lro^\ teql euofue,tg :tuu.r8o.r4,{rlerulso(I uoIlBIpBU ', tuoll
euoN :soIJueIJUao
euoN :sarnsBatr I,$o;e5 aa,lsuaqa.rdtuoJ '€ tuoll
',trularces elllncexg eql ol peuodar lou
seA\ irrelqoJd uorluunueluoc prluelod u puu pelueuncop ,(pedord ueeq lou eluq slsel {uel oseql
',fue1erceg eAqncexg eql uroq uoqezuoqtnu tnoqll/( peuuoped uoaq eAuq slsoJ {B{I :salJuelJ$a(
',{rulercag olltncexg eqt,quou lou pTp aesuecl[ eql puu uolpurrrsluoc
gio ecuese.rd eql perccrpu) g1tillg uo peuuoped lset {Bal eqt pue sqnseJ eq} ot peu8tsse
suun eABq lou p1p perruo;:ed slset )pel aqt'uotltppe uJ 'tou sl lI [l]uoxno ]nq asuaclT cr;rcedg
s,put eqt ur peluur8 eq plnoc sql 'slsel {Eel u^\o JIoq} urJoFed ot fuetarcas enllncaxg eql
rrro4 uor1uzuoqtnu pe^rareJ tou suq IIru eql mou lq8rg '6z6zunlpn-I B qll^\ seldures aqt Surz(1uuu
puu Surldures sepnlcur qcFllrr srsuq,(pegenb u uo stsal >1ue13uruuo;ted ueeq suq IIFU eqi 'oslv
'g002 'gZ IIrdV uo pellztsur ereft\ seEne8 aqt ocurs pe{ceqc uaeq lou enuq slusluuqieul JJo-uo
aqt lnq ,(1-rodo-rd Supporn are ,(eqlJr aes o1 ,(1mp pe{ceqo arc sa8nug JBelcnN eI{I .,'slenralut rea,{
(E) uew -re8uol ou ]B JouueJeql puu luaureculdeJ acJnos 1B 'uollellulsul lu roiuclpul puu tusluullseur
JJO-gO or{l Jo uoqcunJ.redord puu e8e4ee[ elqoeolpuJ JoJ pelset aq Iluqs eclle(,, oql puu ..'eluls
lueueer8y w ro JUN aq1,(q pasuocrl ,(lpcrgrceds suos.red {q paquog-ted eq Ipqs luetuuptuoc
pue Surplarqs s1r 'puel€ru elrlceorpuJ eLIl Sunlonut Surlsel ro;tedu'uotlucole; 'luauelluuurstp
'uortullulsur aorlep Jor.llo gV 'uonrsod JJo eql uI {f,ol sI usruuqceru JJO-uO eql paprno,rd
,(lpryur eceld ur ecr^ep srql tunoru ,(uur uos-red ,(uV,, e8nu? q3?o Jo slequl paqc€ilu pe.ltnba:
eqt Jo euo uo ere teqi suor]onrtsur eql ot Surp.roccy :lelrelutr l pesuerlT 1o 3up1a1qs 'Z tuall
issued. The RSO indicated for any work done on or around the Nuclear Gauges a RWP would be
issued for the work to be done. RWPs also include extra radiation monitoring and survey
requirements for each job.
During the mill tour when the inspector observed the condition of the Nuclear Gauges is was noted
that labels on the gauge (serial number 6277CN) Iocated in the lower SAG mill area was covered
in sand and grit thus making them not legible. When the inspector reviewed Licensee's
documentation of the quarterly Irak Tests and noted the records contained comments that this
gavge was covered in sand.
Deficiencies: The labels on the gauges are required to be maintained. The gauge located in the
lower SAG mill was covered in sand and grit making the labels not legible.
Item 7. Management Oversight: Dave Turk is responsible for the gauges at the White Mesa
Uranium Mill. Dave Frydenlund is the Vice President of Regulatory Compliance and General
Counsel for Denison Mines. Dave Turk reports to Dave Frydenlund and has support on all
compliance issues.
Deficiencies: None
Item 8. Violationsr lncident,Investigation Follow-up: This was an Initial Inspection for this
General License and there are no previous violations, incidents or investigations to follow-up on.
but recommendations will be made to address the deficiencies that have been
and 6.
^.;:
Denison Mines: Dave Turk (RSO)
Ronnie Nieves (Radiation Technician)
Utah DRC: Ryan Johnson (Inspector)
Kevin Carney (Inspector)
Findines
The following are DRC findings of items that need improvement:
1. Improper Leak Testing of the devices:
R3l3-21-22@)(c). General Licenses*--Radioactive Material Other Than Source Material.
(c) Any person who acquires, receives, possesses, uses or transfers radioactive mateial in a device
pursuant to the general license in R313-21-22(4)(a):
(i) shall assure that all labels ffixed to the device at the time of receipt and bearing a statement
that removal of the label is prohibited are maintained thereon and shall comply with all
instructions and precautions provided by the labels;
(ii) shall assure that the device is tested for leakage of radioactive material and proper operation
of the on-off mechanism and indicator, if any, at no longer than six-month intervals or at other
intervals as are specified in the label; however:
(iii) shall assure that the tests required by R313-21-22@)(c)(ii) and other testing, installation,
servicing, and removalfrom installation involving the radioactive materials, its shielding or
U:\rad\COMMOMUranium mills\i Ie(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection
modulesV009Unspection ReportsUnspection Report RADMOD-General License-01 3-4-09 RI.doc
3 ofPage 5
Deficiencies: None,
identified in Items 2
Closeout Meetins
E e8ud Jo ,
cop.Iu 6o-v-t.Ig-asuecr.I prauaD-(otrAICVU Uodau uoncadsunslrodag uor1cadsu16666sa1npou
uortcedsul dII\lUI{n BSaIN elrql\ - seulw uoslua(l 6tr006lm(7)a111s11ttu tunlusrnu{Onu IOJ\PBA:II
nwap aql rotpnu0u aql u ro pqq aLfi
uo pawctpu! sD DrruJD{nuuru aqt {q pa{rcads Kcuanba$ aqt tD Jo slDMatut tltuout xls lD pauuotrad
uaaq sDq'Kt ort'to4octput ro u,tstuzr,lcawSo-uo ?qtto uotwtado ndotd puo lD!-4apu afiPDotpDt
lo agovoa\ n{ tugsal pqt ruauncop ot sproc?r ulopr llDtls zasuarlI aqJ :9 uo4rpuoC esueclT
:seEnug eql Jo rrrsruuqcel4l JJO-uO eril Jo {ceq3 luuorluredg uu tururro;red roN 'Z
.,{relarceg elqncaxg eq} {Jnou tou plp eesue3ll eW puu uollgullllsluoc
;o ecueserd eqt paprrpul g0/9ll9 uo pauuoJlred trsel{sel eqt pue stlnser oqt ot patftssu sltun
e^uq tou p1p peuuoFed slsal {Bel oqt'uotlppe tq 'tou st 1t,(pueunc pue esueJrl cr;lcedg rreql
q8norqt IIIN erp ol peluurE eq plnoc qc1{r\,fue1arce5 elqncexg eqt luo4 uonuzuoqlnu lnoqll/s
slsel {Bel ut\o Jreql Eunruograd ueeq suq eesuecq aW slueuleJrnber pue salru esoq} o1,fuer1uoc u1
..'slu^relur me,( (g) ueql -ra8uo1 ou }e JeuBerew puu
lueruaculder erJnos 1u 'uorlulplsur lp JolBcIpuI ptru lusrueqcelrl JJO-uO eql Jo uoqcunJ rado.rd pue
e3u4ue1 elqcuorpuJ JoJ polsel eq IIBqs eorle(,, puv .,'eluls lueuree.6y ue Jo CUN aql /tq pesuecll
,(llecgrceds suosrad,(q peuuogred eq lpqs lueruuleluoc puu Sutplalqs sll'luueluur o^IlsuolpuJ
eqt Eura.loa,ur EuRsel:o rreder'uorlucolar lueurepuuutsrp 'uot1u11utsul ecllep Jeqlo 11Y 'uoqrsod
go eg ur pe{col sr tusruuq3eruJJO-uO eql papl^oJd,(lpurur eceld ut ecl^op slql ]unoru,(Btu uos:ed
,(uy,, eqt eflne8 qcue Jo slequl paqJeilu peltnbar eql Jo ouo uo er€ leql suoqcrulsul eql 01 Eurproccy
'apnut arD spro)il aql n{o stnat adgfto{ fto4arlas angn?axg
at# {q uogcadsuT totpaup1ulout puD aynsarilut n Tatanbcaq{o s|yn m 7da4 aq noqs ru?I
-gl-e I€A uol1cos tq pannbat sarrnos pa1oas {o uwDuttttoluor to aEoqoa1 n{ s|sa|to sproxay
socrnos pepes Jo uouuulruuluo3 ro aEu>pel roJ slsel Jo sproceU 'r0II-SI-EIEU
lnsoq asnc-Kq-aso) D uo Ktolanag a^!filaxg aqt {q paunua@p sD
,a1qon1ddo aq Kout Z7t-gI-€t€A u fio ps Duaflrr aqt'saouotsutnrro asaUl rapun 'stop 0e u\ltt,rt
tn4atcag a^ltncaxg aq, q paqslrun{ aq lsnu bsn parc!4sotun nt a7qo7da33o arD suorTiua
puo sastuald aql W4l Suunsua ntur4d n (suo4tua aql Jo sasuatd aQ{o uolloultttDruoj
ut rlnsal o7 tya4g acJnos o o7 oSoutop to {o anpot,to p.uagDu aAg?oolpoJ alqDioutar alout ro
GJn SAO.O) Tatanbcaq Sgt to uo1trca1ap lo asDc aq, u1 puo :uarprt uolltD Impauar aq, puD ,ua^a
at17 {o uorlducsap {ayq o tu1uyoluoc yodat y 'fuolatcas aofiraxg aqt tq patotddo asuvtaqP
sD to aJwap aql u! lDyaDu aqpDotpu aqt anarar ot asunq cyfrcads o Kq pazuoqfio uoaad
o o7 n{suott Kq{o pasodsTp aq KTuo Knut acutap aqt uto$ Touatow aotcDotpnr {uo puo aJt^ap
aql.apg Eursuacr7 D ro 'atDts Tuautaat?y uD 'notssntluto3 tto\oynSay fiapnN aql {q Jo ZZ-€tSA
Japun pans$ sDlh wql azllap aql nodat 01 asuacq cgftcads o Eurp\oq uostad nqto 10 ralnpolnuota
ary Kq patrcdat uaaq sDq q l!run pauondo aq pu {ow acmap aW'p.u?tDu aqpDolpor alqD^oua.t
arota ro (nn SOO.il Tatanbcaq ggl {o uolparap aql uodn to loqoctput ro tttsruoqcau t{o-uo aql
n plrarrru anlpDolpt r ary to &u1p1arys aqt 'ot aSoutop to {o am1p{ a1qtssod n {o uogoc4pul tuo
to,ol aSouop.ro to anpo{o s! anqtt! a?!^ap aryto uolptado puadsns t1apqpauu1lot1s (t)
:sautlrtlco qcns uto{tad o7 a7o7g 3u1suac17 o n'a7o7g luauaatty uo'uorssnautoS
fuo4o1n&ay napnN atlt utoq ro Z,Z-e rcA o7 Tuonstnd asuaoll cyficads o tu1p7ot1 uostad n tq (g)
to :spqq aqt Kq paptlotd suournusut aUl qfitur acuvpto)rD u! (V)
: p auto{ta d a to' ya a utu?Dlu o )
The instructions on the Gauges labels indicate that the Licensee has up to three years to perform
this requirement. This requirement should be preformed pnor to any matntenance to the gauge or
equipment that the gauge associated with.
3. Improper Label Condition:
License Condition l: The Licensee shall maintain the device Label in legible condition and
securely attached to the Device.
In contrary to the license condition the device label instructions, the device located in the lower
SAG Mill was covered in sand and grit and the label was therefore not legible.
Conclusions and Recommendations
The DRC has chosen to use enforcement discretion because the gauge labels indicate that the
Licensee has up to three years to perform a Leak Test and to test the On-Off mechanisms of their
gauges.
Recommendation for Next General License Inspections
1. lrak Testing
2. On-Off Mechanism Checks
3. Label Condition
Prepared 7 -//-a?
(Date)
3-rt-o1
(Date)
U:Vad\COMMON\Uranium mills\l1e(2)UT1900479 Denison Mines - White Mesa UMillViP Inspection
modulesVO0gUnspection ReportsVnspection Report RADMOD-General License-O1 3-4-09 RJ.doc
5 of Page 5
(Signature)
O,n
INspBcuoN Rrponr
Inspection Module: RADMOD-General License-O1: Fixed Nuclear Gauge Inspection
Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Three Ronan Model SAI-Cl0 Fixed Nuclear Gauges
Inspection Dates: February 24,2009 and February 25,2009
Inspector: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (RSO) and Ronnie Nieves (Radiation Technician)
Governing Documents:o UAC R313-21
. General RML G3-250
Opening Meeting
Denison Mines: Dave Turk (RSO)
utahDRC: lillTJi",::tdl#J*?lrechnician)
rhe DRC inspectors opened tr'" -""tinf;;lll:r1ffili,'l'Iff:Tihen a generat overview or the
inspection and discussed the inspection modules that Ryan Johnson and Kevin Carney were going
to be doing during this inspection.
Inspection Summarv
. Site Documentation: The inspector reviewed documentation that was related to the Mill's
General License. This included documentation that documents Employee Training, Dosimetry,
Radiological Instrumentation, and Leak Tests.
. RSO Interview: The inspector discussed with the RSO the requirements outlined in the mill's
General License.
. Mill Tour: The inspector participated in a general site tour. During the tour the inspector
looked at each of the three nuclear gauges and took photographs of their condition to document
and to confirm compliance.
Inspection Items
Item L. Security and Control of Licensed Material: The Gauges are located within the
restricted area of the White Mesa Uranium Mill. The Mill's restricted area is surrounded by a
chain link fence and radiation safety technicians are posted 24 hours a day at all open gates.
Deficiencies: None
U:\rad\COMMON\Uranium mills\l le(2)UT1900479 Denison Mines - White Mesa UMillU{P Inspection
modulesV009Vnspection ReportsVnspection Report RADMOD-General License-O1 3-4-09 RJ.doc
1 ofPage 5
Item2. Shielding of Licensed Material: According to the instructions that are on one of the
required attached labels of each gauge "Any person may mount this device in place initially
provided the On-Off mechanism is lock in the off position. All other device installation,
dismantlement, relocation, repair or testing involving the radioactive material, its shielding and
containment shall be performed by persons specifically licensed by the NRC or an Agreement
State." and the "Device shall be tested for radioactive leakage and proper function of the On-Off
mechanism and indicator at installation, at source replacement and thereafter at no longer than (3)
year intervals." The Nuclear Gauges are checked daily to see if they are working properly but the
on-off mechanisms have not been checked since the gauges were installed on April 28, 2008.
Also, the mill has been performing Leak Tests on a quarterly basis which includes sampling and
analyzing the samples with a Ludlum 2929. Right now the mill has not received authorization from
the Executive Secretary to perform their own leak tests. This could be granted in the mill's
Specific License but currently it is not. In addition, the leak tests performed did not have units
assigned to the results and the leak test performed on 6/16/08 indicated the presence of
contamination and the licensee did not notify the Executive Secretary.
Deficiencies: I-eak Tests have been performed without authorization from the Executive Secretary.
These leak tests have not been properly documented and a potential contamination problem was
not reported to the Executive Secretary.
Item 3. Comprehensive Safety Measures: None
Deficiencies: None
Item 4. Radiation Dosimetry Program: Everyone that works at the White Mesa Uranium Mill
has been assigned an OSLbadge. These badges are exchanged on a quartbrly basis for analysis.
The radiation safety department keeps all results on file and provides an exposure record to
employees once a year. Declared pregnant women have their badges exchanged monthly and are
assigned a second OSL badge to place over their stomachs to record any potential exposure to the
fetus.
Deficiencies: None
Item 5. Radiation Instrumentation and Surveys: The White Mesa Uranium Mill has several
different types of Radiation Survey equipment which are calibrated every six months. Dose rate
instrumentation includes Ludlum Model 3 meter with a hot dpg GM tube and Ludlum 19 micro R
meters. Routine radiological surveys are conducted throughout the restricted area including inside
the actual mill building where the gauges are located.
Deficiencies: None
Item 6. Radiation Safety Training and Practices: An initial radiation safety training course is
taken by every employee at the time a person is hired at the White Mesa Uranium Mill. Each
employee is also required to participate in an eight hour refresher course for every year there after.
Special Radiation Training is provided to employees when a Radiation Work Permit (RWP) is
U:\rad\COMMON\Uranium mills\l le(2)UT1900479 Denison Mines - White Mesa UMillU{P Inspection
modulesVOOgVnspection ReportsVnspection Report RADMOD-General License-01 3-4-09 Rl.doc
2 of Page 5
issued. The RSO indicated for any work done on or around the Nuclear Gauges a RWP would be
issued for the work to be done. RWPs also include extra radiation monitoring and survey
requirements for each job.
During the mill tour when the inspector observed the condition of the Nuclear Gauges is was noted
that labels on the gauge (serial number 6277CN) located in the lower SAG mill area was covered
in sand and gnt thus makrng them not legible. When the inspector reviewed Licensee's
documentation of the quarterly Leak Tests and noted the records contained comments that this
gauge was covered in sand.
Deficiencies: The labels on the gauges are required to be maintained. The gauge located in the
lower SAG mill was covered in sand and grit making the labels not legible.
Item 7. Management Oversight: Dave Turk is responsible for the gauges at the White Mesa
Uranium Mill. Dave Frydenlund is the Vice President of Regulatory Compliance and General
Counsel for Denison Mines. Dave Turk reports to Dave Frydenlund and has support on all
compliance issues.
Deficiencies: None
Item 8. Violations, Incident, Investigation Follow-up: This was an Initial Inspection for this
General License and there are no previous violations, incidents or investigations to follow-up on.
Deficiencies: None, but recommendations will be made to address the deficiencies that have been
identified in Items 2 and 6.
Closeout Meeting
Denison Mines: Dave Turk (RSO)
Ronnie Nieves (Radiation Technician)
Utah DRC: Ryan Johnson (Inspector)
Kevin Carney (Inspector)
Findines
The following are DRC findings of items that need improvement:
1. Improper [,eak Testing of the devices:
R3L3-21-22@)(c). General Licenses*--Radioactive Material Other Than Source Material.
(c) Any person who acquires, receives, possesses, uses or transfers radioactive material in a device
pursuant to the general license.in R313-21-22(4)(a):
(i) shall assure that all labels ffixed to the device at the time of receipt and bearing a statement
that removal of the label is prohibited are maintained thereon and shall comply with all
instructions and precautions provided by the labels;
(ii) shall assure that the deviie is tested for leakage of radioactive material and proper operation
of the on-off mechanism and indicator, if any, at no longer than six-month intervals or at other
intervals as are specified in the label; however:
(iii) shall assure that the tests required by R313-21-22@)(c)(ii) anil other testing, installation,
servicing, and removal from installation involving the radioactive mateials, its shielding or
U:\rad\COMMON\Uranium mills\l1e(2)UT1900479 Denison Mines - White Mesa UMill\HP Inspection
modulesVO0gUnspection ReportsUnspection Report RADMOD-General License-O1 3-4-09 RJ.doc
3 ofPage 5
c o ntainme nt, are p erfo rme d :
(A) in accordance with the instructions provided by the labels; or
(B) bl a person holding a specific license pursuant to R313-22 or from the Nuclear Regulatory
Commission, an Agreement State, or a Licensing State to peffirm such activities;
(v) shall immediately suspend operation of the device if there is afailure of, or damage to, or
any indication of a possible failure of or damage to, the shielding of the radioactive materi-al or
the on-off mechanism or indicator, or upon the detection of 185 becquerel (0.005 aCi) or more
removable radioactive materi.al. The device may not be operated until it has been repaired by the
manufacturer or other person holding a specific license to repair the device that was issued under
R313-22 or by the Nuclear Regulatory Commission, an Agreement State, or a Licensing State. The
device and any radioactive material from the device may only be disposed of by transfer to a
person authorized by a specific license to receive the radioactive material in the device or as
otherwise approved by the Executive Secretary. A report containing a brief description of the
event and the remedial action taken; and, in the case of detection of 185 becquerel Q.A05 uCi)
or nxore removable radioactive material or failure of or damage to a source likely to result in
contamination of the premises or the environs, a plan for ensuring that the premises and
environs are acceptable for unrestricted use, must be furnished to the Executive Secretary
within 30 days. Under these circumstances, the criteria set out in Ri13-15-402 may be applicable,
as determined by the Executive Secretary on a case-by-case basis;
R313-15-1104. Records of Tests for Irakage or Contamination of Sealed Sources.
Recorcls of tests for leakage or contamination of sealed sources required by Section R313-15-
1401 shall be kept in units of becquerel or microcurie and maintained.for inspectinn by the
Executive Secretary forfive years afterthe records are ntade.
According to the instructions that are on one of the required attached labels of each gauge the "Any
person may mount this device in place initially provided the On-Off mechanism is locked in the off
position. All other device installation, dismantlement, relocation, repair or testing involving the
radioactive material, its shielding and containment shall be performed by persons specifically
licensed by the NRC or an Agreement State." And "Device shall be tested for radioactive leakage
and proper function of the On-Off mechanism and indicator at installation, at source replacement
and thereafter at no longer than (3) year intervals."
In contrary to these rules and requirements the licensee has been performing their own leak tests
without authorization from the Executive Secretary which could be granted to the Mill through
their Specific License and currently it is not. In addition, the leak tests performed did not have
units assigned to the results and the leak test performed on 6/16/08 indicated the presence of
contamination and the licensee did not notify the Executive Secretary.
2. Not performing an Operational Check of the On-Off Mechanism of the Gauges:
License Condition 6: The Licensee shall retain records to document that testing for leakage of
radioactive material and proper operation of the on-off mechanism or indicator, if any, has been
performed at six month intervals or at the frequency specified by the manufacturer as indicated on
the label or in the manual for the device.
U:\rad\COMMON\Uranium mills\l1e(2)UT1900479 Denison Mines - White Mesa UMillU{P Inspection
modules\2O09Vnspection ReportsVnspection Report RADMOD-General License-01 3-4-09 RJ.doc
4 of Page 5
The instructions on the Gauges labels indrcate that the Licensee has up to three years to perform
this requirement. This requirement should be preformed prior to any maintenance to the gauge or
equipment that the gauge associated with.
3. Improper Label Condition:
License Condition I: The Licensee shall maintain the device Label in legible condition and
securely attached to the Device.
In contrary to the license condition the device label instructions, the device located in the lower
SAG Mill was covered in sand and grit and the label was therefore not legible.
Conclusions and Recommendations
The DRC has chosen to use enforcement discretion because the gauge labels indicate that the
Licensee has up to three years to perform a Leak Test and to test the On-Off mechanisms of their
gauges.
Recommendation for Next General Iricense Inspections
1. Irak Testing
2. On-Off Mechanism Checks
3. Label Condition
Prepared By:7 -//-a?
(Date)
Approved
By:
U:\rad\COMMOMUranium mills\l le(2)UT1900479 Denison Mines - White Mesa UMill\FIP Inspection
modulesg00gUnspection ReportsVnspection Report RADMOD-General License-O1 3-4-09 RJ.doc
5 of Page 5
(Signature)
Ont
(Date)
DIVISION OF RADIATION CONTROL
INSPECTION FORM
License
rt rc\
License #:(": -e(c
Licensee
Address iu :ir-' / 7 '< ;7
/). to r t) /a ''^ '/':
Last Amendment #
Date of Amendment
Inspection
At n,4,T. :-.trs -{ /<t / (License Expiration
Date
t)-, u.2 1/t )J/\
Inspection Date 7 -2-/- , 7
Licensee
Contact:D-r, A, f- , .,{ s c Closeout Date ) -z;-'r',
Telephone
Number
Previous Inspection
/).;4q]-
lnspectionPriority: I II m [V V For Previous & Present Findings - See
Compliance History
Type of
Inspection
(Circle
Appropriate
Types)
Routine
Or
-^.-/ lnitial\----
\
,r'\)nartnounced \
Or
Announced
Modules
Used
1
1(ppta
5l / -./J
1., -t '4 bzl7<-/
&7'r c''-t
62J4 ;'J
Persons Contacted
Ato frt {so
/f,,n . //eJ'> Z.(^f,,..- T,L
Yes No ,,') ),1,.,). --Inspector: * ^Approved:
:/L oi,o 7rA Z
{-**b, /_z Trad
L S./ /; =t-?zaq
_>vw
)'7-Z!"' 1'--,f"4 7oV '>/.?.iv <:1 ,*./ 17,O Zl **L-r^ 5--? Vr,O
)-n'€:/'-? /T'o q -ara'1 (Zt_/. Z-T { /
22 Z-b Z */ f -7 v r,rP
{ r//*rf y /-e/ <4-,€) /'a // /4'2-n12 /<L Z"rZ
f**,i/,ltn ?/a I /: d.d: 4 g ff S,e"-{)71272
9")-e y",/a /./- ./ "'t ,-?*v
q'z ./-
/ -''
/7 !-sry' vve
U ,-7.a /,A-.rr
?'y ,r"y--v/- . r*-"€//'u 3/ y'o -,r- fZ'2V:*2/
t
loyapl4l p?sua?lTJo lo$uoc puo fitynaas
hTUO.{ NOIIDfldSNI
TOUINOJ NOIIYICYU dO NOISIAI(
6,-t €a //rf D"> ,p.Z*_
;^sTy'*-l I s tt F-,y
,//tc-tL z,z4an h, ,*--
j ,*1 /,- /,,9./^,/ei4., 4- ^*t
^,// a-7- 77.,.<-- ,4 €-.r<
L,c- Z; Qrru o.oft?zQ
Ofu*lvtg * ?<, th, rt o4 frgu z'^-<,
;)ztqe p ^-T
*,( Dl, {r.L,(L/l U 7 n-4 /er,-/.-/,g G-y.-/.-..u { d*.no,- (6.^,. (
a7 (b./Dr^7{
Wolation, Incident. Investisation Follow-up
rlo,tL, i",T*( '7)s/nrt^-""--
Radiation Instrumentation and Survevs
/u,//',"- r'a,Z/ b *'E
J lL /-r/L /"
*L* 4,
-/a 4 ue-L3^r 19 n/
d/1'n;J
/-.9/4
Radiation Safetv Trainine and Practices
-/h,,i,..( 2.1 fr-.,n;-- /. T€,)
f //, Lb',-. e-7"
hta )4 D. *"t-- ?2^t
6rA,^--(-- a.r.,ft )S 4.
/r- F
7. Manasement Oversisht
Cauzlir/. /JP
"'7.* /.-/ u^-2,- a.n
1 4rZ. ct= tzt.4al
tar/2 .s, ue.- /(
v5_ z
J?, V *2
-22
,
luautadauoru Jaq q4M tnoasolJ 'tl
.II
,ZI
f-y/-ZS zry ,f-?? )-ruv-'tr'€ f*,7'"/ L6ry -r"t
?*, -/-7-,1 //,u r*rrd
J,(C r""2 ;
F29 --L,L
,/:7
V,,
1"1af J{a- a-?l
,A -o1no2 ,., ) rf-7
/""7 vo {tr'u?' 0a
'01suoltolou
urAH",*tHKN,?l3N'l'I3#ffi
fr 33"""
SURVEY OF GENERAL LICENSE
DAVID TURK
DENISON MINES
IO5O 17TH ST
DENVER, CO 80265
(43s) 678-222t
PERSON CONTACTED
GENERAL LICENSE #: G3-250
DATF 2.2 /-O?
POSITION {€c)
THIS SURVEY FORM IS INTENDED ONLY FOR DEVICES SPECIFICED IN R3l3-21-22(4). Registrants of
these devices are subject to the requirements of R313-12-51through 12-53, R3L3-12-70, R313-14, R313-19-34,
R3l3-19-41, R3l3-19-61 and R3I3-19-100. These devices include fixed gauges, gas chromatographs, ion
generators, X-ray fluorescence and light production.
R3l3-
t2-51
*21-22(4)(c)
t9-34
le-4r(3)
le-61(3)
le-100(3)
2L-22@)(c)
Instruction
Given?
Rule
Followed?
Records of receipt, transfer and disposal must be kept.x
[includes installation and removal from service; servicing; testing]
License or rights to possess may not be transferred without
executive order
Transfers to persons verified as authorized to receive?
Licenses may be modified, revoked or terminated.
Transportation is as authorized.
Labels on device are intact.
Instructions on label are followed.
kak tests are taken at required frequency.
On-off indicator is tested as required.
Y
t'
Y
YN
$vN
YN
fl N N/A @;N N/A
YNN4I YN@
)NW
N N/A
N N/A
@
N/A
N/A
(pN N/A @N N/A
N N/A
N N/A
N N/A
&
(y)
Y
o
U
Y
N N/A
N N/A
N N/A
Have any devices been abandoned, improperly transferred or lost? Y N N/A
NOTES
'2 </pERFORMEpgy. /Lr* Jsh^ Sa-t_
Page 2 of 2
G3-250
I 2 J 4
TYPE OF DEVICE
MANUFACTURER
MODEL NUMBER
SERIAL NUMBER
RECEIVED FROM
DATE RECEIVED
TRANSFER TO
TRANSFER DATE
RADIONUCLIDE
ACTIVITY
5 6 7 8
TYPE OF DEVICE
MANUFACTT]RER
MODEL NTIMBER
SERIAL NUMBER
RECETVED FROM
DATE RECEIVED
TRANSFER TO
TRANSFER DATE
RADIONUCLIDE
ACTIVITY
ATTACHMENT A
TO GENERAL LICENSE CERTIFICATE OF REGISTRATION G3.250
DEVICES REGISTERED WITH
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF RADIATION CONTROL
BY DENISON MINES
AS OF February 09,2009
Type Manufacturer Model #Serial #Isotope Activity Value
GAUGE
GAUGE
GAUGE
RONAN
RONAN
RONAN
SAl-CIO
SAI-CIO
SAI-CIO
6277CN
6278CN
6279CN
Cs-137
Cs-137
Cs-137
300.0 mCi
300.0 mCi
300.0 mCi
Page I of I
Quorterly Seoled Source Check
Dote: Februory 3, 2009
lnspector: Ronnie Nieves
lnstrument - Ludlum Model 2929 SN l4678l
Colibrotion - August 25,2008
Efficiency -36.38%
Bockground - 4.27
Source #l SN 6277CN (lower levetSAG Mill) - BKG
Source #2 SN 5278CN (upper level SAG Miil) - BKG
Source #3 SN 6279CN (CCD) - BKG
* Reoding were lower thon instruments bockround
Quarterly Sealed Source Check
Date: bltu/ot
lnstrument - Ludlum Model 2929 SN 146781
Calibration - February 11, 2008
Efficiency -35.7Lo/o
Background - 25L
Source #1 SN 5277CN (lower level SAG Mill) - 58 (instrument was covered in sands)
Source #2 SN 6278CN (upper level SAG Mill)- 11
Source #3 SN 6279CN (CCD) - 3
Quorterly Seoled Source Check
Dote: December 23, 2008
lnspector: Ronnie Nieves
lnstrument - Ludlum Model 2200 SN 17534
Colibrqtion - December 12 ,2OOB
Efficiency - 27 .92%
Bockground - 4.5
Source #l SN 6277CN (lower level SAG Mill) - BKG (instrument wos covered in sonds)
Source #2 SN 6278CN (upper levelSAG Mill) - BKG
Source #3 SN 6279CN (CCD) - BKG
Quorterly Seoled Source Check
Dote: September 19, 2008
lnspector: Ronnie Nieves
lnstrument - Ludlum Model 2929 SN 146781
Colibrotion - Februory 2008
Efficiency -36.33%
Bockground - 251
Source #l SN 6277CN (lower level SAG Mill) - bkg (instrument wos covered in sonds)
Source #2 SN 6278CN (upper level SAG Mill) - bkg
Source #3 SN 5279CN (CCD) - bkg
(3/i0/2009) Ryan Johnson - RE: Additional information for General License lnspection
From:
To:
Date:
Subiect:
April 28, 2008
David Turk <DTurk @denisonmines.com>
Ryan Johnson <rmjohnson @ utah.gov>
3l9l2o1g 2:28 PM
RE: Additional information for General License lnspection
David Turk
Radiation Safety Officer
t: 435-678-2221 x1 1 3 | tt 435-678-2224
6425 S. Highway 191, PO Box 809, Blanding, UT 8451 1
DENISON MINES (USA) CORP
http://www.denisonmines.com/
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and any attached files with it
are confidential and may contain privileged or proprietary information. lf you are not the intended recipient(s) please delete this
message and notify the sender. You may not use, distribute print or copy this message il you are not the intended recipient(s).
---Original Message---
From: Ryan Johnson [mailto:[e-mail]]
Sent: Monday, March 09,2009 1:37 PM
To: David Turk
Subject: Additional information for General License lnspection
Dave,
What was the date(s) when the gauges were installed?
Thanks,
Ryan
(StZtZObg) Ryan Johnson - RE: Additional inlormation for General ljgelse (Fixed Gauge) lnspectioq 1
From: David Turk <[e-mail]>
To: Ryan Johnson <[e-mail]>
Date: 31212009 2:03 PM
Subiect: RE: Additional information for General License (Fixed Gauge) lnspection
Attachments: DOC006.PDF
Mr. Johnson,
Attached is the documents you requested.
David
David Turk
Radiation Safety Off icer
t: 435-678-2221 xl 13 I t: 435.678-2224
6425 S. Highway 191 , PO Box 809, Blanding, UT 84511
DENISON MINES (USA) CORP
http://www.denisonm ines.com/
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and any attached liles with it
are confidential and may contain privileged or proprietary information. lf you are not the intended recipient(s) please delete this
message and notify the sender. You may not use, distribute print or copy this message if you are not the intended recipient(s).
----Original Message----
From: Ryan Johnson Imailto:[e-mail]]
Sent: Monday, March 02,2009 1:29 PM
To: David Turk
Subject: Additional information for General License (Fixed Gauge) lnspection
Dave,
When you received your fixed gauges, there should be a leak test sheet that was performed by the manufacturer that accompanied
them. Will you please email or fax those leak test sheets to me for each gauge.
Thanks for your cooperation
Ryan
oo
m{HSruffU
RONAN ENGINEERING COMPAN\
8O5O PRODUCTION DRIVE
F'LORENCE, KY 41442
LEAK TEST CERTIFICATE
CUSTOMER: DENISON MINES - WIIITE MESA CONCENTRATOR
ADDRESS: 6425 SOUTH HIGHWAY 191
BLAI\DING, UT 84511
ATTN: DAVID TT,RK rELE 435-678-2221 PO ?AA2t7
THIS IS TO CERTIFY THAT THE FOLLOWING SEALED SOURCE
HAS BEBN LEAK TESTED AND FOUND TO BE:
tr ACCEPTABLE tr UNACCEPTABLE tr NEEDINGRETEST
ISoTOPE: CS-l37 SOURCE ACTIVITY (mCi): 300 mCi
SOURCE SEzuALNo.: 6277CN SHOPORDERNUMBER: UT-209260
GAUGEMODEL: SA|-C16 MANUFACTURER: RONAN ENG.
TEST DATE: I2I28IO7 TBSTED BY: CRAIG CARIS
AIIALYSISDATE: 12128107 ANATYZEDBY: CRAIGCARIS
TESTRESULTS: <0;001 MICROCURIE OF REMOVABLE
CONTAMINATION
NEXT REQUIRED LEAKTEST DATE:
oo
m{mffiuAlll
RONAN ENGINEERING COMPANY
8O5O PRODUCTION DRIVE
FLORENCE, KY 41042
LEAK TEST CERTIFICATE
CUSTOMER: DENISON MINES - WHITE MESA CONCENTRATOR
ADDRESS: 642s SOUTH IIIGHWAY 19I
BLANDING, UT 84511
ATTN: DAVID TURK TELE 435-678-2221 PO POO217
THIS IS TO CERTIFY THAT THE FOLLOWING SEALED SOURCE
HAS BEEN LEAI( TESTED AND FOTJND TO BE:
E ACCEPTABLE tr UNACCEPTABLE tr NEEDINGRETEST
ISOTOPE: CS-}37 SOURCE ACTIVITY (mCi): 300 mCi
SOURCE SERIALNO.: 6278CN SHOP ORDER NUMBER: IJT-20926A
GAUGEMODEL: SAl-Cl[MANUFACTURER: RONAN ENG.
TEST DATE: 12128107 TESTED BY: CRAIG CARIS
ANALYSISDATE: 12128107 ANALYZED BY: CRAIG CARIS
TESTRESULTS: <0.001 MICROCURIE OF REMOVABLE
CONTAMINATION
NEXT REQUIREDLEAK TEST DATE:
oo
EI BtrNAN
RONAN ENGINEERING COMPANY
B()5(} PRODUCTION DRIVE
F'LORENCE, KY 4IO4Z
LEAK TEST CERTIFICATE
CUSTOMER: DENISON MINES - WTIITE MESA CONCENTRATOR
ADDRESS: 6425 SOUTH HIGI{WAY 191
BLANDING, UT 84511
ATTN: DAVID TURK rELE 435-678-2277 PO POO277
THIS TS TO CERTIFY THAT THE FOLLOWING SEALED SOURCE
HAS BEEN LEAK TESTED AND FOUND TO BE:
EI ACCEPTABLE tr LINACCEPTABLE tr NEEDING RETEST
ISOTOPE: CS-137 SOURCEACTIVITY(rnCi): 300 mCi
SOURCE SERIAL No.: 6279CN SHOP ORDER NUMBERT AT-209260
GAUGEMODEL: SA!-C![MANUFACTURER: RONANENG.
TEST DATE: 12128107 TESTEDBY: CRAIGCARIS
ANALYSISDATE: 12128101 ANALYZED BY: CRAIG CARIS
TEST RESULTS: <0.001 MICROCURIE OF REMOVABLE
CONTAMINATION
NEXT REQT'IRED LEAK TEST DATE:
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09,2008 PAGE: 1 of I
DEVICE TYPE: GAMMA GAUGE
MODEL: SA-'1
MANUFACTURER/DISTRIBUTOR:
Ronan Engineering Company
Measurements Division
8050 Production Drive
Florence, Kentucky 41042-3028
(8se) 342-8s00
SEALED SOURCE MODEL DESIGNATION:
3M Models: 4D6L Gamma lndustries Model: VDHP
4D6P4FOS lsotopes Laboratories Model: 225
4F6ST HEG-O6O
HEG-137
QSA Global Models. CDC. 700
(AEA Technology) CDC. 711M
cDC. 800
cDc.93
CDC, PE2
CKC. PI
CKC. P4
ISOTOPES: MAXIMUM ACTIVITY:
CESIUM-137 5000 millicuries, depending on configuration
COBALT-60 18 millicuries, depending on configuration
LEAK TEST FREQUENCY: 36 months
PRINCIPAL USE: (D) GAMMA GAUGES
CUSTOM.DEVICE: Yes XNo
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09, 2008
DEVICE TYPE: GAMMA GAUGE
Collimator Isotope
C5(112" diameter) CS-137
Co-60 l8 mCi
C10(l"diameter) Cs-137 2500 mCi
Specifi c License DistribuJion
Maximum Activity
5000 mCi
5000 mCi
100 mCi
General License Distribution
200 mCi
5000 mCi
100 mCi for mobile platforms
200 mCi
2500 mCi
100 mCi for mobile platforms
200 mCi
PAGE: 2 ol8
Ronan Gauge
X90 Point Level
X9l Density
X92 Continuous Level
X90 Point Level
X9l Density
X92 Continuous Level
X90 Point Level
X91 Density
X92 Continuous Level
X92 Continuous Level
X93 Weigh Scale
X90 Point Level
X9l Density
X90 Point Level
X9l Density
X92 Continuous Level
DESCRIPTION: The Ronan Model SA-l is a source holder to be used as a component of Ronan
X90 point level gauges, X91 density gauges, X92 continuous level gauges and X93 weight scale
gauges. The SA-l uses a manual rotary type collimator controlled by an actuating handle. The
rotary collimator can also accommodate a pneumatic remote actuator mounted under the device.
The SA-1 may utilize the collimators listed in the table below. The authorized license distribution,
the isotope used, the maximum activity per source holder and gauge system is dependent upon the
collimator used.
F37(<=37 Deg.)
F37(<=37 Deg.)
5(1/2"diameter)
C10(l"diameter)
Cs-137
Cs-137
Cs-137
Cs- 137
Cs-137
Cs-137
Cs-137F371<=37 P"*.,
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09,2008 PAGE: 3 of 8
DEVICE TYPE: GAMMA GAUGE
Description (cont.)
The SA-l source holder is constructed from a two-piece heavy walled ductile iron or stainless steel
casting with full machined mating surfaces and filled with lead. The two pieces are bolted together
with four 3/8-16 steel machine bolts. To prevent water, oil or other contaminants from entering the
source holder, the interface is coated with an elastomeric gasketing compound (silicone adhcsive
sealant), or tig welded when the application may meet or exceeded the recommended temperature
for the gasketing compound. The source holder collimator is rotary type, controlled by an actuating
handle ihat is painted ied. The actuating shaft for the shutter rotor is provided with an "O" ring and
oil seal. OryOff inaicators are cast (raised letters) into the back of the source holder and machined
into the top of the source holder adjacent to the actuating handle. The SA-1 has a cast boss on the
top to act is a stop for the actuating handle. The tab for the "off'position has a clearance hole to
aliow the lock to be inserted through the tab and the boss to lock the device in the "off'position.
The source holder is provided with four 0.44 inch diameter holes through the front cover for
mounting.
The following modifications are for the SA-l-F37 with cesium-137 source activities from 2500 to
5000 mCi. The source capsule bushing of the SA-l-F37 with cesium-137 source activities from
2500 to 5000 mCi is constructed from tungsten. A tungsten plug is inserted into the source tube
after the source is installed in the source tube. The source tube assembly is shown in Attachment 4,
Figure A. Tungsten shielding has been added to the rotary collimator for the SA-l-F.37 with cesium-
137 source activities from 2500 to 5000mCi. The tungsten shielding is half moon shaped 2.25
inches x 1.12 inches and extends the full length of the collimator and is shown in attachment 4,
Figure B. In the off position the tungsten is directly in front of the source capsule. Additional
shielcling is mountedto the bottom of the device with four (4) t/r-20 stainless steel bolts I % inches
long. After assembly, the bolts are tig welded to the auxiliary shield to ensure the shielding will not
be removed from the device housing.
A stainless steel sleeve with a tig welded bottom cover is inserted into the stainless steel source
tube. The source capsule and bushing are inserted into the sleeve and a lead plug is inserted
behind the source capsule. A 0.06 inch thick stainless steel cover plate is tig welded to the cast
housing to close off ihe source tube. The outside of the casting is recessed at the location and has
a raiseJ boss around the cover plate A secondary 0.06 inch thick stainless steel cover plate is tig
welded to the raised boss, covering the entire opening. The dimensions for the SA-l source holder
are:
Mounting surface-8 inches x 8 inches (20'3 cm x 20.3 cm)
Mounting surface to a back cover-9 l/2 inches (24'l cm)
Top to bottom, including handle-8 3/4 inches (22.2 cm\
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICBS
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09,2008
DEVICE TYPE: GAMMA GAUGE
PAGE: 4 of 8
Description (cont.)
The ANSI classification in accordance with ANSI538 for the SA-l source holder is ANSI-54-454-
454-R, based on highest readings using all collimators with maximum activities.
DIAGRAMS: See Attachments
LABELING: The source housings are labeled in accordance with 1 OCFR 20.1901 and 1 0CFR
32.51. The label is attached to the secondary cover and attached to the body of the source holder
with hardened stainless steel drive screws. Drawings of labels are including in Attachment 2,
Figures A and B.
CONDITIONS OF NORMAL USE: The Ronan SA-l is used as a component of Ronan
Engineering industrial process control instruments for level, density, and weight measurements as
designate<i by X90, Xgl,X92 AND X93 described above. The device is designed fbr the following
conditions:
Temperature
Pressure:
Humidity
lmpact:
Vibration:
Corrosion:
Fire:
Explosion:
-4ooc to +2o4oc (-4oo F to +4oooF)
Atmospheric
Ranging from 0 to 100%
Accidental conditions only
Ranging from zero to mild
Ranging form zero to highly corrosive
Unlikely
Unlikely
Users and locations of use vary throughout all process dependent manufacturers (i.e. chemical,
plastics plants, steel mills, mines, mobile platforms, etc.). The frequency of persons being near the
device varies with the process being controlled. The range of activity near the device is from
opening and closing the shutter several times per day, to only having a person near the device for
semiannual standardization and maintenance, and periodic leak tests.
The expected useful life of the SA-l is at least fifteen years.
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09, 2OO8 PAGE: 5 Of 8
DEVICE TYPE: GAMMA GAUGE
These devices may be used as density measuring devices on mobile platforms and at temporary job
sites. For mobile use, the device will be welded in place during assembly, as shown on attached
RONAN drawings so that there is no way to remove the source without cutting the welds'
PROTOTYPE TESTING:
Prototype testing for this source holder was done at Ronan Engineering in Canada. The device
passed the following tests for safety and integrity satisfactorily:
Vibration: 0 thru 50 cps at 0 thru 1/l6" displacement for varying lengths of time. Total time
approximately 20 hours. Source shutter in the "on" position during test,
Observations at the end of test: Closed and opened source shutter several times with no
difficulty. No separation of weldments or mechanical structure visible.
I-emperature: 1000C (2120D for 75 hours; 600C (140F) for 8 hours; 400C il0+0F) for 24
hours. Shutter in "on" position during test.
Observations at end of test: Closed and opened source shutter several time s during and end of
test. No difficulty encountered in the operation of the on-off mechanism.
Off-on control: Operated I00 times. Within typical environmentalconditions as listed under
Conditions of Use.
Observation at end of test: No difficulty encountered in ease of operation of source shutter
mechanism at end of test.
Drop test: Dropped from height of 48" (L22 meters) onto a I" thick steel plate supported by t/2"
plywood on top of a blacktop driveway. Source shutter padlocked in "off'position' Source
hotder dropped on padlock and shufter handle:
Observation at end of test: No noticeable damage to padlock or shutter handle. Integrity of
source containment and shielding maintained.
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09, 2008 PAGE: 6 of B
DEVICE TYPE: GAMMA GAUGE
Prototype testing (cont.)
Impact: Two hundred (200) blows with an 8 oz hammer. Dropped a I t/0" diameter steel rod
from a height of 42" (1.06 meter) onto source holder.
Observations at the end of test: No observable damage to the padlock or shutter handle after
the test. Shutter placed in "off'position with no difficulty.
EXTERNAL RADIATION LEVELS :
The following calculated dose rates were reported by the manufacturer for each collimator
type with the maximum activity of each isotope and with the shutter open. All readings are in
mR"/hour at the distances indicated
Collimator Isotone Aitivity (mCi)
C5
c10
Co-60
Cs- 137
Cs- 137
Cs-137
18
2500
5000
100
F37
F37
Cs-137 5000
5cm 30cm 100cm
5.5 1.3 0.323J 2.8 0.4
9.0 3.0 0.35
30.1 4.7 0.71
0.5 0.06 Background
OUALITY ASSURANCE AND CONTROL
Ronan maintains a quality assurance and control program that meets the ISO-9001 standards
and has been deemed acceptable for licensing purposes by the Kentucky Radiation Health
Branch. A copy of the program is on file with the Kentucky Radiation Health Branch.
REGISTRY OF'RADIOACTIVB SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B
DEVICE TYPE: GAMMA GAUGE
DATE: OCTOBER 09,2008 PAGE: 7 of 8
LIMITATIONS AND/OR OTHER CONSIDERATI9NS OF USE:
o The device may be distributed to specific licensees of the U.S. Nuclear regulatory
Commission or an Agreement State. The device may also be distributed to general licensees
when used with the collimators and sources given in the General License Distribution Table
contained in the DescriPtion.r F'or use by Mobile Platform General Licensees, the installer shall provide shields as
necessary to ensure that radiation will not exceed O.SmR/hr at any point after installation.
o Users of the device installed on Mobile Platforms must be trained according to 49 CFR 172
Subpart H.. The outer case of devices uscd on Mobile Platforms must be labeled in accordance with 49
CFR 172.101 [49 CFR 173.422 Additional Requirements], i.e. (UN29l l).
o For point level or continuous level (only) General License applications, Ronan will
calculate, manufacture and install the source such that the external radiation lcvels at
the detector side of the vessel will not exceed 2mR/hr (20 pSv/H) with the vessel empty.
o Handling, storage, use, transfer and disposal: To be determined by the licensing authority
o The device shall be teak tested at3 year intervals using techniques capable of detecting 0'005
microcuries (185 Bq) of removable contamination'
o Any person may mount this device in place initially, unless welding is required, provided the
ON/OFF Mechanism is locked in the OFF position. All other servicing of the source and
source holder, including welding during installation on mobile platforms, shall be performed
only in accordance with the terms and conditions of a specific license issued by NRC or an
Agreement State. This registration sheet and the information containcd within the references
shall not be changed without the written consent of the Kentucky Radiation Health Branch'
SAFETY ANALYSE SUMMARY:
Based on the review of information submitted by Ronan Engineering, we continue to conclude
that the device is acceptable for licensing.
Furthermore, we continue to conclude that the source would be expected to maintain its containment
integrity for normal conditions of use and accidental conditions that might occur during uses
specified in this certificate.
NO:
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
AFETY EVALUATTON OF DEVICE
AMENDED IN ITS ENTIRETY
KY-576-D-101-B DATE, OCTOBER 09, 2OO8 PAGE: 8 of 8
DEVICE TYPE: GAMMA GAUGE
REFEREN9ES:
The following supporting documents for the model SA-l source housing are hereby
incorporated by reference and are apart of this registry document.
r All information and engineering drawings submitted by Ronan engineering, as the
application for a safety analysis of the Model SA-t gauge as currently contained in the gauge
SS&D review file dated February 17, 1999
. Ronan's letters, with attachments dated April 7, 1999, May 4,1999, and July 22,1999
o Ronan's letter, with attachments dated June 3, 2002
. Ronan's letter, with attachments dated April 5, 2006
o Ronan's letter, with attachments dated June 14, 2006
. Ronan's letter. with attachments received August 11, 2006
. Ronan's letter. with attachments received September 11,2008
t$$urNG a9Fr.{9Y:
Kentucky Radiation Health Brancft
Dato
Date:
Revhwcr:
Revbwer:
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-IOI-B DATE: OCTOBER 09,2OO8 ATTACHMENT 1 FIGURE A
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09, 2008 ATTACHMENT I FIGURE B
uHT
TIn
vlE]TtiTIn
rrlzU
.Dr)
--{
T't
x
bfiUI
b) e';Dn'- ul'E
st2*
c^l i c:
co ii r.lz-T{ETI Cz.Awontl
T!'nruHu] 3
2xfti**zcnr)FruE
tAXllaA. n6(,6-rl-{ r-TI-IDrrl r -{T;(rrl
I++x
ruL.F
x
01ti
. c')--{ n
L7
^=aft-r -<>4c>
-Uh<tAman
qa-lTnr>rrl-lr- rn
rnf,-HoU --r-{rEEi =-r;E-Uil
?qzIfi(A z.?n
= [F-,8 2*frfn - frluocl --{ (n> mur-om? r<
=Dl-rrt i
3?--,PT.-md;?n6.=-N-t=zr.lMIPG]
IE]EIg l'--'r E r,l.il.l nE.=N EBi,, En=z intJ
-E;zfr;;I z.z.hctct-t{:D'rr3at r- -t f.l f.l-oD
Farn.*tt=-^rfzo+ crJ -D
=iomur-a2a-6lrn-ilcl
I
rn}Drdu
!D,-|
trlz
C)f>C--t
Ez
dtAn1?Bnf
NU
?zUn
rflT
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-IO1-B DATE: OCTOBER 09,2OO8 ATTACHMENT 2 FIGURE A
-+(,I(oU
il I
++E'+$
r-l INnirl c
nei
E5tv2roi
x*'' u I
*H'oF i
ia= Y] \o ._"'' l
tr gYi.)r i;Yt I+tsolt. ,,, i
, +{l 'coo{. ,,
..... _. -_!l_;o:cl
?,
c:szafir
;i
fiC
7-r
?-a:ITo;fi!rnl
n:i
(tx'u
ill
Urrl:r.>r:
;r>)nl
FI
I
I
I
I
I
i
I
I
I
I
i
I_-.".t.
Ft!rrlr
a
E>-{oz
c:szaf,s'
'*r,rn
4T
.!,t ,';z:t 'l
zr)
oit
C)lr
C-l ,tolzri.-,.._-1ititE: rli;i
i'i tl, ,*!*irfl e, *i
dl4l o ii \l-"1 rl'-iil I! ,o I --iI k i-EiI j>Fi
lm fliElT I
-lr
Irrl i= iItrl t< llzl i i
lEl i i
F
m
;Df
clr
I)
.E
...-.'
9i-,! n
ijl(:pl Al?lt-r9-'6ti.
lLnitrl'rl
I. .t-_
=rq
wE7r-liKIrl=-a
g5qo=
I iN); 'cD
l6)l>
t'
"ai(,
I
;Ti()iI
i TrlU
I
'c
r()'o,i
I
i
tfr;i
oT'
(:
1!
,Xi
E
.i?tDI
s!
I
>Erg
---l z
OHO'l\]
I;\
i
N
()
-_l
g
I
I:T
Iu
G
CO!
In
TNlr
N +is
ctN
lsrio.
gEergHEfififi!
Eil li?l flf E ;-o= i8!6 *8: sEE ifil^. .'<d ^z arnri \i E lJE
2 t5t; E* $E
sgB---toC
t! >+/u O-
> --ro
'fr2
na--PS8-
B3 F E F
EII]il
X.gaB
ifiltl
U
-rlr-oArrlzo
:
xrrlz--{cox
Fa
-rt
R.EGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY.576-D-IO1-B DATE: OCTOBER 09,2OO8 ATTACHMENT 2 FIGURE B
roi
EHTg6$
*9612r- BooE cdn* iHPu 6."8<FI2X.EHHE
Eil
Eq
E!
!I
EiIr*
II
TI
;[
$
lE
!
Htlqffi
iHiliit
IlI!a
i
!
t
i
F!qtIIII
EI!
I
0I
E
E
I
d
!
F$il
iE=
ii!
I:E
blU
!EE
silt
il!a;!
ir
gB
E;
Ft
I3
;x|l!
lri
lr"
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-l0l-B DATE: OCTOBER09,2008 ATTACHMENT 3
ls
irtq
lf,lil
l=It
tffls
lq
I
r-r--r'--r----jlli"i'l"l-l 3 I
l;l-t ir fil i
lEtFi lHiEl=; : Egf
iEiiligH:i I i i6,{Bl
il I il=*i
lilHiEr;i
I I li lllsl
lllitEEii .l icqnli i I i3:rllil I E;lI it I rrl
I I I ' xrrrl! ! I I m.-I I I I lA-Yl;ll ! a8i
f -1_-1-- j uq i
lliEl sii:iil;"-l qEl
l*l=i -le:i
it t;l ?Eilli i ;'Iilliti Hai
1.1-1-: | .'# l
1lL,i ii
<tr1FF
ERrE rt'lE --1r};il48fi*odz.
-l
I
€
flZ.
=C)
=.1+al-okpoE< r'r
>.<14
'gEmmE
E5zc,5Am8:HzoT
aEmm
i0=
EB4E6.z.ytitc(nc>fr2.f,:.-zv
Eoatg
t
=(}
-{=m
AI = TD -II E{4ot{r'lcra
fi6=EEil
dfrtiefi
o*9-oEE
E€9E-6
{HEHsaxc =mo
:r#:EE'xg2E=#dE#I=or*=h-z4 rqorrDulzr
^I4Zn(rr{=aeE',fi
@
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576.D-1O1.B DATE: OCTOBER 09, 2OO8 ATTACHMENT 4 FIGURE A
U] Ei-f\ !'t'llX
a
{
Zr-
T.1u]-
9b(rl C;:e. ui
C--z
FNot" EL l)'aS <nil).!);,t 7 Y.
C)-o-nt-l'
r'l . -.tn7\L
? 2'",trr-L3r5
9'.1."'',t z. $AU :(=T.-
-;,
nZU
'rJ-
-l-lao(:n
rr
*--' -'l
I
I
I
I
I
I
.{'++
x
l.)+t
l'\)XU,
b y7Jo)(n "?
;8 9-4; Z PN'.i'L) 7 'C)
tn ,J rn'- <ri < A, I1-D, aOT)Z () ct)rC) A i-0l,r < --l t-(n t't rn 'r >tn ;: ll,* ;
Yl # I _
=> \ |tsil \ir l--*-'- -'-
'\ '---
'.. --^ ...,1
I
:
I
U')C)C)Jr)trl
aO;z-O- i-
f,ZlE:{.-t u> t rr6e=3
FLrlix:holarccl
2frz_,Y
L-*-_--
-rlrC(:)
r
L'7
TTJ
f,2t-
snilvt
Est.r, irr!
;l!tol'l
L
0<:olCITIolrl'r Ic t-.UIm l?-lt
3
ticu
r{a
Isg,oz
a
<-',1L
oo
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-l0l-B DATE: OCTOBER 09, 2008 ATTACHMEN.T 4 FIGUREIB
,'
--_+r-l, Ix',rf i
i
..1-
It
I
I
i
I
I
I
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER 09, 2008 ATTACHMENT 5
a-CJ
--.{rrln
O!mz
lq
^^ li-- Evvlqo6d>oa l?
;i
-
e[- IE EgEfi FEf,ii El Er* EFt lflIE fi fl*|;x rE
IIFIIIHEflF' ll ll lt| El
a:EC-1-{mn
()roarnO
aI1
,t i,E 3 :I o
Iz
TI5
fn fo €F f f{
T
<.Id
!:tOh
;=EFUC=-{=
-u1o>ZC
a5l6
-z
ii'-Qorl
'- !0qE
nt']t+m
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN lTS ENTIRETY
NO: KY-576-D-101-B DaTE: OCTOBER 09,2008 ATTACHMENT 6
.?e9.,-FIEH-IEf;
lf il lFF Ef
U)-Cfrnfr
o-U
rrlz.
tolsti
== tEv- lCse lirx rf
9d
2Einz
sz.if;
Hri-sa=a-Bmo
F
(n:rC
=mfr
C)r-oamU
c 41
f\)bo,5 !cN E
r
-7
ts I dzo
L 6 cT !DF Di 3ts
E
r,
o o u N az
T ca A c I
-
I
o c I e u !a2q
Lv N oi ,ra
I-
D q
Tez{o u
t b o i)u Ff s \Ea
a
I o H I
!e*{
,IJ ,'D t!=n>2
=mE
=tJ
EIi5z
ry6F<oz
oC.
€
3
am26
1
=oZqoI
io
r
b
It
=
B
tn-mz{(,l
E,
oZ
R.EGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
ATTACI{MENT 7NO: KY-576-D-101-B DATE: OC'I'OBER 09, 2008
nEli-r
*r= I
>l
29LEr.E
6e,i,i 99 =A1 Z
EEe
;flf;
iE
,ilrFn!6!d^PPi
lzlLol-rlnIClcr l
lollz
lu>l-rlo
I,D
l=
la ' ,ftq;
:. ;:- -]{
, i,ll'!, j
,lii!lrrtr
;iifi;3li-lrrtl,lLl I 'itl
=-->-n(ro.Jr 4
r)ro.> rnz
(Da
111 aot
a=xiq'o{t
-og
eF
=C)
caz6l(/(]
Co
on
(,r(fql
-rlr
Ea
nooa
6z2?cJa-i<*tgP
cl0a(I,
strr"
7l\\J C!
=rhtl'rorrtx
ro2o
l<
IFII
lz rmrIX ,rnlll n<-
:<=seg614-# ,-ro: l5"'3b l=(n!m l( J
P--.,6 ltr;=rrlAmrm--{6rrn
EEqfrlF
Hi#4EE q8
Hita=I pa
rHn364 naD- @ ^
=fih#3e
EHzx?r?? Hirxi'#H - tr ImEr!Ifii Eu)lulzl!,2 x:JrCl <l-OZ6!ao6)slz' vcnl-r o67,i2nfr =
.ETE Hfi iAa< o-i14uEl
3+foDol>
R
F
E
e
EF
EE!iE'
d8
EEP.
o
kr, t -!,E
F,i,gi
'llEli
irllEqi i t i
iE ig;iui l i"tl li"i E i
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICB
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER09,2008 ATTACHMENT 8
*3
AE
E.e,H
E--'i6
F
rf
E:
E*
*#EEE gE E=Esr
Hfi;xE pB lE Bfit EEssI
E;;Eg
ui tF'
lgE - isil=E6;eHI d E:g lE FHg=F=?E?^fr ; u*H *.8!;-"'' Ifi" Sffi Hirq ;*^6
fl7
F
fipfisE6
Frn
?,aF-ozr
Pm-a
oo
zoi
potr|mo
o't,
3Fo3
=r
EE+qle
ip
E3
REGTSTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER09,2008 ATTACHMENT 9
Il--
!orub! gd
(,()
o
3
aO
dB
ooi.oJ{i.,NGtlg,
t
1\
I
\,\
_(/1>o
E=FPrri<-l:."r!#<
l$3=;
Hrl SH
lxal
lu,>IAl'=lU)l<
I
atg5
rnuz.F1o
+.
a
Urrl
[t
€
l
@
c)xC)noCz.(:,
+
l
I
uoou
lzloJ l--l' lrn
Hm 19
Ti ci70
r<filo<
I --llo<l;u mlmi
lryH,-|
i s, t')
t8 lsppps E
F Hnnnte u
BHTffi3;
EF=Elit'
llllm
{oJ(J'IAo
Ioa--l
zorrl
oCn
TNa
IUIn
-lL^l()o
1
3
n
t-
EorrIzam
a
I
I-n
Gr-J
IAoCn
C)rrl
I
!EeDIc
rfl
aCnlrl
rflz
a
0
a5z.
REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES
SAFETY EVALUATION OF DEVICE
AMENDED IN ITS ENTIRETY
NO: KY-576-D-101-B DATE: OCTOBER09,2008 ATTACHMENT l0
(nC
I
i
o.o ir(rz\
Jrb<)!-
|(rl
6 '-ir'o ioT Itn tr.
-Az
r
.5Pc)$
t--1lc:
i-u
'.--i--i[1l::i ilJ
O>i(')n
C)(]Z
I
iI
I
-/ i/
iZ
I()r i"...1.im
1,g t{
"\t.filrr {l--llo<
l.r.J rrlil;l-,< )t
I
;tr9\)
ts i8$pps ElL 13xrzl,
|I l= I;;l€ iq
bHsH,xg
lr, lo *txt.r'
l--r lc: <:<l'rlc"r
li iF iiilrl+tt"i tiBlirl
,-.(.r)>()l).'' -.\>:i v-fix=
ic j'J iII U C';
H*6xi| (tnl,:
l8;.713
ls rl
lvr:lI -:.lbt{.I
'{ (,, U'
o
(al I\- .:|
N)
C)m
cx
iIz,<\)@.\ I
O)-f.+
Ix
=-- att(-) >
oT
D
l\
I
T.tztrln
t
r-
r.lZarrl
a
I
I,l
(rJ{
0
Cn(lt'r
-L
T"c,TI
l:r
TtrIc
DIc
TI
U1C7rn
rIz--la
I
=goz
p
l"
!
b
{ -r -
NRC INSPECTION MANUAL IMNS/RGB
INSPECTION PROCEDURE 87 124
FIXED AND PORTABLE GAUGE PROGRAMS
PROGRAM APPLICABILITY: 2800
87124-01 INSPECTIONOBJECTIVES
01 .01 To determine if licensed activities are being conducted in a manner that will protect
the health and safety of workers and the general public.
01.02 To determine if licensed programs are being conducted in accordance with U.S.
Nuclear Regulatory Commission (NRC) requirements.
87124-02 lNSPECTION REQUIREMENTS
The review of the licensed activities will be commensurate with the scope of the licensee's
program. The inspector's evaluation of a licensee's program will be based on direct
observation of work activities, interviews with workers, demonstrations by workers
performing tasks regulated by NRC, and independent measurements of radiation
conditions at the facility, rather than exclusive reliance on a review of records.
The inspector should determine if the licensee possesses licensed material as authorized
by a general license. lf so, the inspector should assess the adequacy of licensee's
program for management and oversight of the generally licensed material.
The structure and the emphasis of the inspection will be on the following Focus Elements
(FE) that describe the outcomes of an effective fixed or portable gauge radiation safety
program:
02.01 FE-1. The licensee should control access to and prevent loss of licensed material
so as to limit radiation exposure to workers and members of the public to values below 10
CFR Part 20 limits.
02.A2 FE-z. The licensee should maintain shielding of licensed materials in a manner
consistent with operating procedures and design and performance criteria for devices and
equipment.
lssue Date: 11125103 -1-tP 87124
02.03 FE-3 . The licensee should implement comprehensive safety measures to limit
other hazards from compromising the safe use and storage of licensed material.
02.04 FE-4. The licensee should implement a radiation dosimetry program to accurately
measure and record radiation doses received by workers or members of the public as a
result of licensed operations.
02.05 FE-s. The licensee should provide radiation instrumentation in sufficient number,
condition, and location to accurately monitor radiation levels in areas where licensed
material is used and stored.
02.06 FE-6. The licensee should ensure that workers are:
a. knowledgeable of radiation uses and safety practices;
b. skilled in radiation safety practices under normal and accident conditions; and,c. empowered to implement the radiation safety program.
02.07 FE-7 . The licensee's management system should be appropriate for the scope of
use and should ensure:
a. awareness of the radiation protection program;
b. that audits for ALARA practices are performed; and,c. that assessments of past performance, present conditions and future needs are
performed and that appropriate action is taken when needed.
ln reviewing the licensee's performance, the inspectorshould coverthe period from the last
to current inspections. However, older issues preceding the last inspection should be
reviewed, if warranted by circumstances, such as incidents, noncompliance, or high
radiation exposures.
87124-03 INSPECTIONGUIDANCE
General Guidance
The following inspection guidance is designed to assist the inspector in evaluating the
performance of the licensee's radiation safety program. The guidance is organized by the
individual focus elements described above. The timing and sequence of inspection
activities are left to the inspector's discretion based on the circumstances and conditions
at the time of the actual inspection. Furthermore, inspectors should not feel constrained
by the guidance in this procedure. lf an inspector obtains information that indicates that
a problem may exist in an area within the NRC's jurisdiction that is not specifically
addressed in this procedure, the inspectorshould redirect, orotheruyise expend, inspection
effort to address that problem.
An examination of the licensee's records should not be considered the primary part of the
inspection program. Rather, observations of activities in progress, equipment, facilities and
use areas, etc., will be a better indicator of the licensee's overall radiation safety program
than a review of records, alone.
tP 87124 -2-lssue Date: 11125103
o
ln the records reviewed, look for trends such as increasing doses or effluent releases.
Records such as surveys, waste disposal, effluent releases, receipt and transfer of
licensed materials, training, utilization logs, and air sampling may be examined randomly
until the inspector is satisfied that the records are being maintained and are complete.
Other records that are more closely related to health and safety (such as personnel dose-
monitoring records and incident reports) should be examined in detail.
Common elements to all inspections include entrance and exit meetings with appropriate
licensee management, including the radiation safety officer (RSO), observations of facilities
and work in progress, independent confirmatory suryeys, and the evaluation of program
scope and any special license conditions. Specific guidance regarding these common
elements can be found in IMC 2800.
Each of the following elements should be reviewed as appropriate, during each inspection
of a fixed and portable gauge licensee.
Specific Guidance
03.01 FE-1:The licensee should control access to and prevent loss of licensed material
so as to limit radiation exposure to workers and members of the public to values below 10
CFR Part 20 limits
Facilities
a. Through direct observation, verify that all entrances to licensee facilities are
normally closed, locked or otherurise secured to prevent unauthorized entry. This
should include main facility gates, main building entrances, doors to waste storage
facilities, etc.
1. lf any entrance or area is unsecured, determine, through interviews of
licensee staff, the reason for the area or entrance being unsecured.
Determine if the licensee failed to follow established procedures in securing
the area or if additional training of staff is needed. Determine if the
licensee's facility is configured to separate working areas from unrestricted
areas.
2. lf entrances or other areas are unsecured, observe other areas where
radioactive materials are used and stored and verify that they are locked and
have limited and controlled access. Radioactive material use areas must be
under constant surveillance or physically secured.
b. Through observations, verify that use and storage areas are locked and have
limited and controlled access. At a minimum, radioactive material use areas
should be under constant surveillance during normal business hours when
licensee personnel are present or physically secured against unauthorized access.
Storage areas should be physically secured when unattended.
lssue Date: 11125103 -3-tP 87124
Evaluate licensee practices regarding access controls including control of keys and
access codes to ensure only currently authorized individuals have access to
licensed materials,
Licensed material in use must be controlled and under constant surveillance.
Portable gauges must be under constant surveillance when at a temporary job site.
For fixed gauges in use, constant surveillance is not required, provided that the
licensee has adequate facility security and effective procedures for ensuring that
gauges are not removed by unauthorized personnel. Determine the adequacy of
the licensee's procedures for securing licensed materials at temporary job sites.
Evaluate licensee's procedures for securing gauges that are not in use at
temporary job sites. Evaluate how the licensee secures gauges that are in
transport, including securing gauges in a licensee vehicle when that vehicle is
parked in a restaurant, hotel, or similar facility. Verify that either the gauge's
transport case or operating handle is locked when the device is packaged for
transport.
Receipt and Transfer of Licensed Materials
Through observations and interviews of licensee personnel, verify that the licensee: 1)
properly secures package receipt areas, such as loading docks or other shipping and
receiving areas; 2) inspects gauge shipping containers for damage; 3) performs
appropriate receipt surveys; 4) opens packages in a safe manner; 5) assures that
packages are properly prepared for transport; and 6) controls packages in a secure
mannerpriortopickupbycourierpersonnelortransportbylicenseepersonnel. lfpossible,
observe the receipt of packages. Otherwise, request that personnel who normally receive
packages for the licensee demonstrate package receipt processes and surveys.
a. lf packages are left unattended, then assess the licensee's receipt procedures,
including instructions provided to couriers, to assure that packages are being
delivered to the appropriate location(s).
b. lf surveys of packages (whether during receipt or preparation for shipment) are not
adequate to verify that radiation and contamination levels are within regulatory
limits, then interview licensee staff and the RSO further to assess worker
knowledge. Deficiencies regarding instrumentation should be reviewed in more
depth in Focus Element 5.
Through interviews of licensee personnel and review of selected transfer documentation,
verify that the licensee has an adequate method of determining that recipients of
radioactive shipments are licensed to receive such materials.
lnventory Control
Through observation, physically examine the inventory of gauges on hand and review
selected records of receipt and transfer to verify that quantities and forms are as
authorized on the license. Compare the possession of gauges with inventory records.
Verify that the licensee's use of byproduct material is limited to that which is authorized in
the license.
c.
d.
tP 87124 -4-lssue Date: 11125103
Through interviews of the RSO and selected licensee personnel, determine whether the
licensee has experienced any events since the last inspection, involving lost, missing, or
stolen licensed materials.
a. Review and evaluate any such incident or unusual occurrence that took place
since the last inspection. lf such incidents were required to be reported, verify,
through interview of the RSO and review of event reports, that a complete and
timely report was made to the NRC.
b. For incidents or unusual occurrences that were not required to be reported,
determine whether the licensee performed sufficient investigation to identify the
cause of the incident, and took appropriate corrections to prevent recurrence of the
situation leading to the incident or unusual occurrence.
03.02 FE-2: The licensee should maintain shielding of licensed materials in a manner
consistent with operatinq procedures and desiqn and performance criteria for devices and
equipment
Equipment. The SSD sheet specifies the type of safety features installed on the
device and specifies the frequency at which these features should be inspected for
proper operation. Fixed gauges operated in high temperature environments may
require supplemental cooling systems that have inspection and maintenance
requirements. Ensure devices are used in accordance with any operating limits
(such as temperature and vibration limits) described on the applicable SSD sheet.
Verify that engineered safety features (such as shutters, locking mechanisms, or
interlocks) are appropriate, operable, calibrated, adequately maintained, and
conform to the description in the applicable SSD sheet. Ensure that the facility
provides protection of shield integrity, including fire protection. Licensees should
have copies of or access to these SSD Certificates, in addition to the
manufacturers' manuals for operation and maintenance.
Process or Other Engineering Controls. Verify that, where applicable, that the
licensee uses processes or other engineering controls to maintain doses as low as
is reasonablyachievable (ALARA). Forexample, fixed gauge licensees may install
protective cages around the area where a gauge is mounted to prevent inadvertent
access to the radiation beam.
Routine and Non-Routine Maintenance. Confirm that any maintenance of gauges
is performed in accordance with the applicable manufacturer's maintenance
procedures. Maintenance procedures must include ALARA provisions, and ensure
that the gauge functions as designed and the source integrity is not compromised.
For portable gauges, routine maintenance may include the cleaning and lubrication
of the Source rod and shutter mechanism (e.9., to remove caked dirt, mud, asphalt,
or residues from the source rod; lubricate the shutter mechanism). For fixed
gauges, routine maintenance is normally limited to cleaning of the gauge housings
to ensure that required labels remain legible.
More extensive maintenance orservicing (beyond routine cleaning and lubrication)
that involves detaching the source or source rod from portable gauges must be
a.
b.
c.
lssue 11125103 -5-tP 87124
performed by the gauge manufacturer or a person specifically authorized by the
NRC or an Agreement State. Persons performing installation, initial radiation
surveys, relocation, removal from service, dismantling, alignment, replacement,
disposal of the sealed source, and non-routine maintenance or repair of
components related to the radiological safety of fixed gauges (i.e., the sealed
source, the source holder, source drive mechanism, on-off mechanism (shutter),
shutter control, shielding) must be authorized by the NRC or an Agreement State.
The license will contain a condition if the licensee is authorized to perform these
activities.
03.03 FE-3: The licensee should implement comprehensive safety measures to limit
other hazards from compromisinq the safe use and storaqe of licensed material
The inspector should be attentive to potential industrial safety hazards, for referral to the
U.S. Department of Labor's Occupational Safety and Health Administration (see Manual
Chapter 1007). The focus should be on potential non-radiological hazards personally
observed or brought to the inspector's attention by licensee staff.
a. Operational Limits. Verify that gauges are operated in accordance with any
operating limits (i.e., heat, vibration, corrosive materials, or other industrial or
environmental hazards) described on the applicable SSD sheet. Determine
whether if fixed gauge are installed in accordance with the limiting conditions
described in the sealed source and device catalog certificate and by the device
manufacturer (i.e.: temperature, vibration, etc.). Verify that gauges in storage are
protected from fire and the elements and that adequate controls are in effect to
minimize the risk from other hazardous materials.
Verify that radiological labeling is clearly visible and legible.
Temporarv Job Site Hazards. During inspections of licensed activities at
temporary job sites, verify that licensee personnel ensure that devices are
protected from heavy construction equipment, welding equipment, high voltage
lines, and other industrial hazards.
Fire Protection. Materials licensees are not required by NRC regulations to
implement a fire protection program. However, in many cases, the risk posed to
radiological safety by fires is comparable to or exceeds the risk from other events
involving licensed activities. Determine if licensees have a plan in place for
preventing fires and combating fires that might occur. Any perceived
problems/deficiencies (i.e., improperstorage of combustible orflammable material,
fire extinguishers out of selice, lack of fire alarm or detection system, lack of fire
suppression system) noted by the inspector should be brought to the licensee's
attention and discussed with regional management. Properfire protection systems
can be evidenced by the licensee's involvement with the localfire department.
Transportation. Verify that the licensee's procedures and documentation are
sufficient to ensure that licensed material is transpoiled in accordance with 1 0 CFR
Part 71 and U. S. Department of Transportation (DOT) regulations for
transportation of radioactive materials.
b.
c.
d.
tP 87124 11t25t03
Examine: packages and the associated certification documentation; vehicles
(including cargo blocking and bracing, and gauge security); and, shipping papers.
Review any incidents required to be reported to the DOT.
NOTE: For further inspection guidance refer to lP 86740, "lnspection of
Transportation Activities." lnspectors should also refer to "Hazard
Communications for Class 7 (Radioactive) Materials." These field
reference charts, related to hazard communications for transportation
of radioactive materials, are useful field references for determining
compliance with the transportation rules on labeling, placarding,
shipping papers, and package markings. They also contain references
to the DOT regulatory requirements.
03.04 FE-4: The licensee should implement a radiation dosimetry program to accurately
measure and record radiation doses received by workers or members of the public as a
result of licensed operations
A radiation dosimetry program includes all of the licensee's activities that measure the
radiation dose to workers and members of the public as the result of licensed activities.
These activities would include for example, the measurement of quantities of licensed
materials present, radiation and contamination levels, and the concentration of licensed
materials in effluent streams.
Verify that the licensee has performed adequate surveys to show compliance with public
dose limits and that conditions in controlled areas and unrestricted areas meet the
requirements specified for these areas.
a. For most fixed and portable gauge licensees, occupationally exposed workers are
not likely to receive annual doses in excess of ten percent of the applicable limit
in 10 CFR Part 20. Therefore, these licensees are not normally required to
implement a radiation dosimetry program. ln these instances, evaluate the
licensee's demonstration that personnel are not likely to receive in excess of ten
percent of the Parl20 occupationaldose limit. ln all cases, if a licensee does not
provide personnel monitoring devices, it must have a documented prospective
evaluation of occupational exposure that demonstrates that monitoring is not
required.
Dosimetry devices must be appropriate to the type, energy, and the anticipated
radiation fields, must be issued to licensee personnel, when monitoring is required.
Verify that any dosimeters, that require processing to determine the radiation dose,
are processed by a NationalVoluntary LaboratoryAccreditation Program (NVLAP)
accredited processor.
b. Verify that the licensee annually advises each worker, who is required to be
monitored, of the worker's dose as shown in records maintained by the licensee.
c. For most fixed and portable gauge licensees, extensive evaluations of doses
received by members of the public from licensed activities may not be necessary.
Verify that the use and storage of gauges will not likely result in exposures to
lssue Date: 11125103 -7 -tP 87124
d.
members of the public or radiation levels in unrestricted areas that are in excess
of the regulatory limits. For storage areas that located adjacent to unrestricted
areas, licensees must ensure (through measurement or calculation) that doses in
the unrestricted areas do not exceed 2 millirem (mrem) in any one hour or 100
mrem in a year the maximally exposed member of the public.
Area Surveys. Most fixed and portable gauge licensees are not required to
perform routine surveys. Surveys of fixed gauges are required when the licensee
(or its licensed contractor) installs, removes, or relocates a gauge. Generally,
portable gauge licensees are only required to perform surveys if they are
authorized to perform maintenance involving the removal of the source rod, or the
device's shielding.
!f practical, observe how licensees conduct any required surveys to determine the
adequacy of such surveys. Note the types of any instruments used, and whether
they are designed and calibrated for the type of radiation being measured. (See
FE-5)
Leak Tests. Verify that leak tests of sealed sources are performed at the required
frequency. Also verify that leak test samples are analyzed in accordance with the
license requirements.
1 . lf records of leak test results show contamination in excess of the regulatory
requirements, then verify that the licensee made appropriate notifications
and removed the source from service.
Storage and Disposal of Gauges Removed From Service. Determine if the
licensee has gauges that have been removed from service. Verify that the gauges
are stored and controlled in a secure and safe manner, and that radiation levels
in unrestricted areas surrounding the storage area do not exceed the limits of 10
CFR 20.1301 , "Dose Limits for lndividual Members of the Public."
Licensee personnel should be aware of the presence of the device and the need
to prevent unauthorized disposal or abandonment.
Typically, gauge licensees dispose of devices either by returning the device to the
manufacturer or by transfer to another appropriately licensed person. Verify that
any person that the licensee has transferred gauges to was properly licensed to
receive them.
lf the licensee transfers gauges to a burial site for offsite disposal, assess the
licensee's procedures and records to verify that each shipment is accompanied by
a shipment manifest that includes all the required information. Also assess the
licensee's procedures and records to verify that each package intended for
shipment to a licensed land disposal facility is labeled, as appropriate, to identify
it as Class A, B, or C waste in accordance with the classification criteria of 10 CFR
61.55 [Subsection !ll.A.2 of Appendix G to Part 20].
e.
f.
tP 87124 -8-lssue Date: 11125103
t
For additional guidance relating to the evaluation of
personnel dosimetry, refer to lnspection Procedure (lP)
radiation safety programs and
83822, "Rad iation Protection. "
03.05 FE-5: The licensee should provide radiation instrumentation in sufficient number.
condition. and location to accurately monitor radiation levels in areas where licensed
material is used and stored
Gauge licensees should either possess, or have access to radiation survey equipment.
Equipment and instrumentation should be appropriate to the scope of the licensed
program.
a. Verify that the instrumentation has the appropriate range of use. Also verify that
the survey instruments are calibrated at the appropriate frequency and checked
for operability before use. Survey and monitoring instruments must be
appropriately calibrated for the types and energies of radiation to be detected.
03.06 FE-6: The licensee should ensure that workers are knowledqeable of radiation
uses and safety practices: skilled in radiation safety practices under normal and accident
conditions: and empowered to implement the radiation safetv proqram
Authorized Users
Authorized users may either be named in the license application or be appointed by the
licensee, depending on the type of license issued and/or the wording in the license. For
those appointed by the licensee, verify that the authorized user is trained in accordance
with the approved criteria and has knowledge commensurate with operational duties.
Typically, successful completion of one of the following is considered as evidence of
adequate training and experience for operating gauging devices:
o Gauge manufacturer's course for users; or
. Equivalent course that meets Appendix D criteria in either NUREG 1556,
volume 1, Program-Specific Guidance About Portable Gauge Licenses" or NUREG
1556, volume 4, Program-Specific Guidance About Fixed Gauge Licenses"
Authorized users are required to either be physically present or to otherwise supervise the
use of gauges. The level of supervision will depend on the wording in the license
conditions or regulations. Some licenses have conditions such as " . . . used by or under
thesupervisionof ... " Forsome licensesthathavethecondition "... underthedirect
supervision of . . . ," the authorized user must be physically present at the facility for easy
contact or to observe the individual(s)working. Another phrase used is " . . . may only be
usedby..." Finally,"... underthedirectsupervisionandphysical presenceof .."
means the authorized user must directly supervise and be present at the work station.
Considering the many license condition phrases, the inspector must exercise judgment to
interpret the role of the authorized users.
When the wording of the license condition is " . used by or under the supervision of. ," an authorized user named on the license is considered to be supervising the use of
lssue Date: 11125103 -9-tP 87124
licensed materials when he or she directs personnel in the conduct of operations involving
the licensed material. This does not imply that the authorized user must be present at all
times during the use of such materials. The authorized user is responsible for assuring
that personnel under his/her supervision have been properly trained and instructed and is
responsible for the supervision of operations involving the use of licensed materials,
whether he or she is present or absent.
General Training
Determine that appropriate training and initial instructions are being accomplished as
specified in the license andior regulations. The inspector must verify that appropriate
training is provided to authorized users (including the RSO), other persons using licensed
materials, and other licensee employees who may have unescorted access to licensed
materials or to restricted areas.
The requirements for certain kinds of training and instruction are found in the regulations,
while the procedures for their implementation are generally found in the procedures
included in the license's "tie-down" condition. Discuss with the licensee how, and by
whom, training is conducted, and the content of the training provided to workers (generally
found in the license application).
Generally, most gauge licensee employees are not likely to receive an occupational dose
of more than 1 mSv (100 mrem) in a year. The only exception would likely be a licensee
that performs an extensive amount of maintenance on it own gauges. Verify that initial
instructions have been given to workers, if any, who are likely to receive more than 1 mSv
(100 mrem) in a year. For this kind of training, it is the licensee management's
responsibility to inform the workers of precautions to take when entering a restricted area,
kinds and uses of radioactive materials in that area, exposure levels, and the types of
protective equipment to be used. The workers should also be informed of the pertinent
provisions of NRC regulations and the license, and the requirement to notify management
of conditions observed that may, if not corrected, result in a violation of NRC requirements.
Also verify that authorized users and workers understand the mechanism for raising safety
concerns.
Through interview of one or more users of radioactive materials (other than the RSO)
determine that they possess the adequate knowledge and understanding of the licensee's
operating and emergency procedures. The interviews should include discussions about
actual or hypothetical emergency conditions in order to assess the worker's response to
such conditions. Observe licensed activities in progress or a demonstration of activities to
assess the worker's understanding of the radiation protection requirements associated with
their assigned activities.
Operating and Emergencv Procedures
Operating and emergency procedures will be found in license applications and may vary
from step-by-step procedures to more generalized procedures for lower-inspection-priority
licenses. The emergency procedures will be approved by the NRC, and reviewed and
updated by the licensee. Any revision requires an amendment to the license.
lP 87124 -10-lssue Date: 11125103
Verify that licensee personnel are knowledgeable of the operational procedures by
observing the performance of tasks at selected work stations and by a comparison of their
performance with established procedures. Assess the licensee's emergency procedures
to determine that these procedures are as approved by or described to NRC. Through
interview of workers, verify that licensee personnel understand and implement the
established procedures and are aware of procedural revisions.
Licensees should be aware of relative radiological risks and not try to protect the device
to the extent that they would be subjected to fire or other lifethreatening situations (e.9.,
attempting to rescue a portable gauge from the path of approaching soil compacting
equipment.)
Some licensees may have agreements with otheragencies (i.e., fire, law enforcement, and
medical organizations) regarding response to emergencies. Through interviews of licensee
officials, determine what actions the licensee has taken to ensure that such agencies
(involved in such agreements) understand their roles in emergency responses.
Posting and Labeling
Through observation, verify that proper caution signs are being used at access points to
areas containing radioactive materials and radiation areas. Through observation of
labeling on packages or other containers, verify that the proper information (e.9., isotope,
quantity, and date of measurement) is recorded. Areas with radiation hazards should be
conspicuously posted, as required by 10 CFR 20.1902.
Through observation, verify that applicable documents, notices, or forms are posted in a
sufficient number of places to permit individuals engaged in licensed activities to observe
them on the way to or from any particular licensed activity location to which the postings
would apply.
03.07 FE-7: The licensee's management svstem should be appropriate for the scope of
use and should ensure awareness of the radiation protection program: that audits for
ALARA practices are performed: and that assessments of oast performance, present
conditions. and future needs are performed. and that appropriate action is taken when
needed
The NRC holds the licensee responsible for the radiation protection program; therefore,
it is essential that strong management controls and oversight exist to ensure that licensed
activities are conducted properly. Management responsibility and liability are sometimes
under emphasized or not addressed in applications and are often poorly understood by
licensee employees and managers. Senior management should delegate to the RSO
sufficient authority, organizationalfreedom, and management prerogative to communicate
with and direct personnel regarding NRC regulations and license provisions and to
terminate unsafe activities involving byproduct material..
Through observations, interviews and the review of selected records, determine that senior
licensee management is fulfilling its responsibility of ensuring the effective operation of the
radiation safety program. Specific areas of management focus should include:
lssue Date: 11125103 -11 -lP 87124
or
Maintaining awareness of significant events such as the los
o
a
a.
s or theft of licensed
materials.
Maintaining radiation safety, security and control of radioactive materials, and
compliance with regulations.
Committing adequate resources (including space, equipment, personnel, time,
and, if needed, contractors) to the radiation protection program to ensure that
members of the public and workers are adequately protected from radiation
hazards and that compliance with regulations is maintained.
Obtaining the NRC's priorwritten consent before transferring control of the license;
Notifying the appropriate NRC regional administrator in writing, immediately
followingfiling of petitiorr forvoluntaryor involuntary bankruptcy (10 CFR 30.34(h)).
Assuring the appropriate response, when applicable, to generic communications
from the NRC.
Assuring that adequate provisions have been made to fund the safe and effective
decommissioning of licensee facilities. (10 CFR 30.35)
Notifying the NRC of the decision to discontinue licensed activities or to
decommission a facility in which licensed activities took place. (10 CFR 30.36)
Notifying the NRC of defects or other radiation safety equipment malfunctions in
accordance with the requirements of 10 CFR, Parl21.
Maintaining awareness of issues and measures to ensure worker performance and
safety are not being compromised due to safety significant human performance
issues.
RSC (where required or used). Through the review of records, and interviews of
the RSO and RSC members, determine that the committee is made up of a
representative from each type of program atea, the RSO, and a representative
from management. lf practical, attend and observe the conduct of an RSC
meeting. Review meeting minutes (and interview selected committee members
when practical) to determine the committee's effectiveness. Determine that the
RSC meets at the required frequency as specified in the license application, other
commitment documents, or in a specific license condition. Topics of discussion
during committee meetings should include ALARA reviews, incidents, generic
communications, authorized users and uses, waste issues, audits, etc.
Determine if the committee has been assertive in seeking out areas needing
improvement, rather than just responding to events and information from outside
sources. Determine whetherthe RSC has recommended any specific actions and
assess the implementation of those recommendations. The inspector's review
should be of sufficient depth and detail to provide an overall assessment of the
committee's ability to identify, assess, and resolve issues. Also consider the
effectiveness of the RSC to communicate the results of audits and trend analyses
to appropriate personnel performing licensed activities.
RSO. Through the review of records, and interviews of the RSO and authorized
users, verifythatthe RSO has been appointed by licensee management, identified
on the license, and is responsible for implementing the radiation safety program.
Determine, through interviews, that this individual is knowledgeable about the
program, and ensures that activities are being performed in accordance with
approved procedures and the regulations. Determine that, when deficiencies are
b,
tP 87124 -12-lssue Date: 11125103
identified, the RSO has sufficient authority, without prior approval of the RSC or
licensee management, to implement corrective actions, including termination of
operations that pose a threat to health and safety.
Determine that the knowledge and training of any radiation safety staff are
commensurate with their assigned duties. Verify that the radiation safety staff
levels, including numbers and types of positions, are as described in the license
application.
1 . lf the inspector identifies high staff turnover or prolonged shortfalls in staffing
levels, through interviews and observation determine if these shortfalls have
had a negative impact on licensee performance.
2. lf so, discuss these findings with the RSO and senior licensee management
to determine the source of the staffing issues and the licensee's plans to
address the deficiency. The issue should also be brought to the attention of
regional management.
Audits. Through reviews of audit records and interviews, verify that the radiation
safety program content and implementation is reviewed at least annually. The
results of all audits must be documented in accordance with 10 CFR
20.2102(a)(2). Examine these records with particular attention to deficiencies
identified by the licensee's auditors, and note any corrective actions taken as a
result of deficiencies found.
1. lf no corrective actions were taken, determine why the licensee disregarded
deficiencies identified during audits.
2. Determine if the lack of corrective actions caused the licensee to be in non-
compliance with regulatory requirements.
87124-04 REFERENCES
A listing of lMCs and lPs, applicable to the inspection program for materials licensees, can
be found in IMC 2800. These documents are to be used as guidelines for inspectors in
determining the inspection requirements for operational and radiological safety aspects of
various types of licensee activities.
END
lssue Date: 11125103 13-tP 87124
State of Utah
JON M. HUNTSMAN, JR
Goventor
CARY HERBERT
Lieulenaill Goverttor
'epartment of
Environmental Quality
William J. Sinclair
Acting Estecutiva Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
{ntt '{,',4r)8/
May 19,2009
David Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp.
1050 Seventeenth Street, Suite 950
Denver, Colorado 80265
RE: DRC Inspection Module IEM-01, RML UT1900479
Dear Mr. Frydenlund:
The Division of Radiation Control (DRC) has received your April 20, 2009 response to the Notice
of Violation relevant to the inspectioh conducted on February 24 and 25,2009 at the White Mesa
Mill in Blanding, Utah.
Your response to the Notice of Violation includes: (l) corrective actions which have been taken
by you and the results achieved; (2) conective 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 R3l3-14-15. Please continue to remember that radiation safety is the
responsibility of the licensee.
This NOV is considered closed and no further response is required. If you have any questions
regarding this letter, please contact Kevin Carney at [phone].
UTAH RADIATION CONTROL BOARDtu
Dane L. plnerfrHck, Executive Secretary
cc: David Turk, Site RSO
DLF/KC:kc
168 North 1950 West . Salt Lake City, tlT
Mailing Address: P.O. Box 144850. Salt Lake Ciry, LIT 84114-4850
Telephone (801 ) 536-4250. Fax [phone] . T.D.D. (801 ) 5364414
t' n' rr,, d e q. u I a h. g t tt'
Printed on I00(N, recycled pilper
o
"J)/
)cfdt A; O7'/
Oenison Mines (USA) Corp.
1050 17th Sireet, Suiie 950
Denver, CO 80265
USA
Tel :[phone]
Fax : 303 38$4125
www.denisonmines.com
DENIS
MINES
VIA PDF AND FEDERAL EXPRESS
April20, 2009
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
Re: lnspection Conducted February 24 and 25, 2009; Notice of Violation: DRM
lnspection Module IEM-01, RML UTl900479
Dear Mr. Finerfrock:
This letter is in response to the above-referenced Notice of Violation dated March 17,2009,
received by Denison Mines (USA) Corp. ("Denison") on March 19, 2009, 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
February 24 and 25,2009.
The Notice of Violation 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.
Specifically, the Notice of Violation states that:
"Radioactive Material License Renewal Application dated February 28, 2007,
Appendix E. Section 1.1.2, Breathing Zone Sampling, Section 1.1.2.2, Applicability,
sfates.'
Breathing zone samples are required:
. for all calciner maintenance activities,o at least quarterly during routine operating and maintenance tasks on
representative individuals pertorming these tasks,o when radiation work permits are issued in which airborne concentrations
may exceed 25% of 10CFR2O limits,. weekly for yellowcake operations, oro at the discretion of the BSO.
Contrary to this requirement, no documentation for weekly breathing zone
sampling for yellowcake operations was available for review. The Radiation Safety
representatives for the licensee stated that breathing zone sampling for these
personnel is not being performed on a weekly basis as per the requirements of the
Radiation Protection Manual. The reason given was that the majority of the
yellowcake production tasks were being pertormed on the nightshift and that the
workers usually started work before the Radiation Safety Technicians had a
chance to issue the BZ air samplers to them."
The Notice also states that:
"The DRC encourages the licensee to exercise more attentiveness in regards to
the Personnel Monitoring Program. Although the DRC recognizes that the licensee
maintains an adequate bioassay program designed to monitor workers' internal
exposure, breathing.zgle qir sampling.lor workers with-tfe h.ighest risk of internal
exposure is essential in determining the adequacy of the licensee's Respiratory
Protection Program."
The violation has been characterized as a Severity Level lll.
Denison responds as follows:
1. Root Cause of the Noncompliance
This violation resulted from the following:
Mill Radiation Safety staff was under the mistaken and improper assumption that strict
adherence to the requirements of the Mill's Radiation Protection Manual could be relaxed in the
circumstances, because:
o During the recent Mill run, operations in the yellowcake area were performed on a
sporadic basis, and when performed were typically of short duration. This was due to
the relatively low average grade of the ore that was fed to process and the resultant
reduced quantity of yellowcake produced. Specifically, yellowcake was typically dried
and packaged during some but not all night shifts, and the duration of the operations
typically lasted less than one hour each time. This made it difficult for Radiation Safety
staff to coordinate with the operations crew to arrange for a BZ test to be set up and
performed;
o Yellowcake operators wear PAPR respirators as a matter of standard practice, with a
protection factor of 1000, thereby minimizing the risk of inhalation of yellowcake from
yellowcake operations; and
. Bioassay samples are performed every two weeks on yellowcake workers to verify that
they are not ingesting yellowcake.
Denison firmly agrees with the Executive Secretary that breathing zone air sampling for workers
with the highest risk of internal exposure (such as yellowcake workers) is essential in
determining the adequacy of the Mill's respiratory protection program. Denison also feels
strongly that requirements such as this cannot be relaxed and that Mill personnel were wrong in
making that assumption.
We have reviewed this matter carefully and have concluded that the root cause of this violation
is therefore that Mill Radiation Safety staff was wrong in believing that these requirements of the
Radiation Protection Manual could be relaxed in the circumstances.
2
OENISOJ)//mlNEs
Corrective Actions Which Have Been Taken by Denison and the Results Achieved
The following corrective actions have been taken by Denison:
a) Mill Radiation Safety staff have been advised that in no circumstances may a
monitoring requirement, or any other mandatory requirement, set out in the Radiation
Protection Manual be relaxed or waived by Radiation Safety staff unless such a
relaxation or waiver is expressly permitted by the Radiation Protection Manual;Mill Radiation Safety staff have been advised that BZ samples for yellowcake
operations will be taken at the frequency required by the Radiation Protection Manual;
Starting February 27,2009, Radiation Safety staff have coordinated with operations
personnel, such that operations personnel now give Radiation Safety staff advance
notice each time they intend to operate in the yellowcake drying or packaging area.
This allows Radiation Safety staff to set up BZ samples prior to commencement of
those operations and to take the samples for the short duration of those operations.
Since February 27, 2009, BZ samples have been taken in this manner on a weekly
basis for yellowcake operations; andd) For most of these samples, test results have shown a lower limit of detection greater
than the LLD of 3 E-'' uCi/ml required by Reg. Guide 8.30. This is because of the short
duration of the samples (typically less than one hour for each sample). However, the
measured concentrations have exceeded the reported LLD, so the fact that the reported
LLD exceeds the required LLD has not been a practical concern.
3. Corrective Actions Which Will be Taken to Avoid Further ltems of Noncompliance
Mill Radiation Safety staff will continue to take weekly BZ samples for yellowcake operations in
the manner described above.
Denison is satisfied that Mill Radiation Safety staff now understand that their failure to take the
BZ samples was wrong, that they have learned from this mistake, and that they will not make
this type of mistake again.
4. Date When Full Compliance Will be Achieved.
Weekly BZs have been taken since February 27, 2009, so full compliance has been achieved
as of that date.
lf you have any questions or require any further information, please contact the undersigned.
Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
b)
c)
Regulatory Affairs and Counsel
DENISOJ)//mtNEs
. Fgqt-"j:i ems 1, 2, -a s. A"o;;;;jF_ nem 4 if Restricted Delivery is desireOi'-'-r Print your name anA aOorel'ss-on-t-hJl"r"o"
. iiJ:fl"H,: :*,.i:Til"'Htr'j#iffi ,o,*_ "19 the front if space permits.
David C Frydenlund
Vice President and General Counset
P^"Il-ot Uines (USA) Corp
1050 17th sT STE 950
Denrcr CO g0265
EI Agent
Addressee
2. Article Number
(Ttansfer from seruice tabe|7007 071,8 ouEE 7110 ?1
tEee)59r
PS Form Sat t, r"uilfizoot Domestic Hetum Heceipt '10259ffi2-l\,F154o
Er!mrL
trf
TT
T]-rL
trlEtfE
rf,rlrL
Ef,
rrtfErL
RE: DRC tnspection module IEM_01, rml 1gOO479
David C Frydenlund
Vice President and Generat Counsel
P^"11":l Mlnes (UsA) corp
1050 17th sT STE 950
Denr,er co 80265
State of Utah
JON M. HUNTSMAN, JR.
Goventor
GARY HERBERT
Lieulenant Govennr
Department of
Environmental Quality
William J. Sinclair
Acting Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
March 17,2009
CERTIFIED MAIL
RETURN RECEIPT REOUIRED
David C. Frydenlund
Vice President and General Council
Denison Mines (USA) Corp.
1050 Seventeenth Street Suite 950
Denver, Colorado 80265
RE: DRC Inspection Module IEM-01, RML IJTI900479
Dear Mr. Frydenlund:
On February 24 and 25, 2009, an inspection was performed at the White Mesa Mill in Blanding,
Utah by representatives of the Division of Radiation Control of the Utah Department of
Environmental Quality. The results of the inspection were discussed with members of your staff at
the conclusion of the inspection.
The inspection was an examination of the activities conducted at 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.
Although the overall results of the inspection were positive, it was noted that not all of your
activities were conducted in compliance with State requirements. To aid you in correcting these
non-compliant activities, a Notice of Violation is enclosed that describes each problem. Please
continue to remember that radiation safety is the responsibility of the licensee.
UTAH RADIATION CONTROL BOARD
rfrock, Executive Secretary
Enclosure
DLF/KJC:kjc
cc: David Turk, Site RSO
168 North 1950 West. Salt lake City, UT
Mailing Address: P.O. Box 144850. Salt Lake City, UT 841l4-4850
Telephone (80 I ) 536-4250 . Fax [phone] . T.D.D. (80 I ) 536441 4
www.deq.utah.gov
Printed on 100% rccycled paper
Page2
Denison Mines (USA) Corp.
1050 Sevepteenth Street Suite 950
UTAH RADIATION CONTROL BOARD
NOTICE OF VIOLATION
License Number UT 19004'19
D.enver, Colorado 80265
During an inspection conducted by representatives of the Utah Division of Radiation Control
(DRC), on February 24 and 25,2009, a violation of the White Mesa Mill Radiation Protection
Manual was identified. The current procedures for radiation protection at the Mill are those set
forth in the February 28,2007 License Renewal Application.
Violations are prioritized according to Severity Levels, with Severity Level V being the least
significant. The particular violation of the White Mesa Mill Radiation Protection Program is set
forth below:
Radioactive Material License Renewal Application dated February 28,2007, Appendix E, Section
| . I .2, Breathrng Zone S ampling, S ecti on L.l .2.2, Applicability, states :
Breathing zone samples are required:
for all calciner maintenance activities,
at least quarterly during routine operating and
maintenance tasks on representative individuals
performin g these tasks,
when radiation work permits are issued in which
airborne concentrations may exceed 25Vo of
10CFR20limits,
weekly for yellowcake operations, or
at the discretion of the RSO.
Contrary to this requirement, no documentation for weekly breathing zone sampling for
yellowcake operations was available for review. The Radiation Safety representatives for the
licensee stated that breathing zone sampling for these personnel is not being performed on a
weekly basis as per the requirements of the Radiation Protection Manual. The reason given was
that the majority of the yellowcake production tasks were being performed on the nightshift and
that the workers usually started work before the Radiation Safety Technicians had a chance to
issue the BZ air samplers to them.
a
o
a
a
Page 3
The DRC encourages the licensee to exercise more attentiveness in regards to the Personnel
Monitoring Program. Although the DRC recognizes that the licensee maintains an adequate
bioassay program designed to monitor workers' internal exposure, breathing zone air sampling for
workers with the highest risk of internal exposure is essential in determining the adequacy of the
licensee's Respiratory Protection Program.
This violation has been characterized as a Severity Level III.
A written response is required within 30 days after receipt of this Notice. The following
information is required: (1) The corrective actions which have been taken and the results
achieved; (2) the corrective steps which have been taken to prevent recurrence; and (3) the date
full compliance will be achieved.
Any response or written answer to this Notice of Violation should be addressed to Dane L.
Finerfrock, Executive Secretary, Utah Radiation Control Board, 168 North 1950 West, P.O. Box
144850, Salt Lake City, Utah 84114-4850. The licensee's attention is directed to the
Administrative Procedures set forth in UCA 63-46b. If a hearing is requested, the Executive
Secretary of the Utah Radiation Control Board will designate the time and place of the hearing.
Please address your written response or direct any questions to Dane Finerfrock at (801) 536-
4250.
Dated at Salt e City, Utah
This day of March, 2009
UTAH RADIATION CONTROL BOARD
Dane L. Finerffock, Executive Secretary