DRC-2010-003704 - 0901a0688019926a

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Ueutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DPVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
2010-003704
June 22, 2010
David Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp.
1050 Seventeenth Street, Suite 950
Denver, Colorado 80265
RE: DRC Inspecfion Module IEM-01, June 8-9, 2010, RML UT1900479
Dear Mr. Frydenlund:
Inspection Module EEM-Ol was conducted on June 8-9, 2010 by the Division of Radiafion Control
(DRC) at the White Mesa Mill. The inspecfion focused on internal and external radiafion
monitoring of workers at the Mill including air sampling, bioassay monitoring and radiafion
monitoring badges. Overall performance of inspecfion items was found to be good with some
minor deficiencies which are outlined in the attached Inspecfion Report.
During this inspection, the items reviewed were found to be conducted in compliance with the
Utah Radiation Control Rules and requirements for this license. Please confinue to remember that
radiafion safety is the responsibility of the licensee. Thank you for cooperafing in this matter.
If you have any quesfions or concems regarding this letter, please contact Kevin Camey at (801)
536-4250.
UTAH RADIATION CONTROL BOARD
Dane L. FinerfroCK, Executive Secretary
DLF/KJC:kc
cc: David Turk, Site RSO
195 North 1950 West • Salt Uke Cily, UT
Mailing Address; P.O. Box 144850 • Salt Uke City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.fieq.ulnh. f;ov
Printed on I009ii recycled paper
INSPECTION REPORT
Inspection Module: RADMOD IEM-01
Inspection Location: Denison Mines White Mesa Mill
Inspection Items: Intemal/Extemal Monitoring
Inspection Dates: June 8-9, 2010
Inspector(s): Kevin Camey, John Hultquist, Utah Division of Radiation Control (DRC)
Personnel
Contacted: Dave Turk, Site Radiation Safety Officer (RSO), Ron Nieves, Lead
Radiafion Safety Technician, Rich Bartlett, Mill Superintendent
Governing Documents:
• License Renewal Application dated February 28, 2007, Appendix E, Radiation Protecfion
Manual;
• Radioactive Materials License UTI900479;
• NRC Regulatory Guide 8.13;
• NRC Regulatory Guide 8.22;
• Utah Rules R313-12-3,R313-15-902.
Inspection Summary
The inspection covered internal and extemal monitoring of radiation workers at the White Mesa
Mill. Inspecfion points for intemal monitoring included breathing zone (BZ) and general area air
sampling focusing on frequency and locations of roufine uranium dust monitoring, adherence to
procedures as to the frequency of breathing zone air sampling of personnel working in higher
exposure locafions (i.e., yellowcake production and packaging), calibration of air sampling
equipment and documentafion of air sampling results. The inspectors also evaluated aspects ofthe
bioassay program including frequency of personnel sampling and routine contaminafion surveys of
the bioassay sample preparation area.
Extemal monitoring focused on the use and storage of personnel monitoring devices (GSL badges)
and monitoring of declared pregnant workers at the Mill. There were no declared pregnant workers at
the Mill within the past two years.
Although the inspection consisted primarily of document review, the inspectors also performed a
visual inspection to verify radiological postings and controls in airbome radioacfivity areas within
the Mill. Also, follow-up items included observation of personnel exit monitoring and adherence to
monitoring badge procedures.
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Opening Meeting
DRC Inspectors John Hultquist and Kevin Camey met with Dave Turk, Rich Bartlett and Ron
Nieves of Denison Mines at 8:30 a.m. on June 8,2010. The inspectors informed the Mill staff of the
focus of the inspection and requested documentation needed to support the task. The inspectors also
asked for an escort into the Mill to observe Mill operations.
Findings
Overall performance of inspection items was found to be good with some deficiencies noted. No
violations were cited during the inspecfion. The deficiencies are detailed below.
Deficiencies:
Item 1. Documentation of BZ air sampler calibrafion:
• BZ calibration is being performed but is poorly document^. Although changes have been
made to the BZ calibrafion documentafion, the cal informafion is still being noted on a log
sheet in lieu of a separate calibration form for each sampler.
Item 2. Procedure discrepancy for BZ air sampler calibration:
• The Mill's Radiafion Protection Manual Secfion 1.1.2.4 states: "Prior to use, calibration of
breathing zone air samplers will be done using the Bubble Tube Calibration method,
described in Section 3.2.1." The Mill now performs these calibrations using the Electronic
Calibrafion Method outlined in Section 3.2.3 of the RP Manual. This was noted in a previous
inspecfion but has yet to be changed.
Item 3. Area air sampler calibration:
• The Mill's Radiation Protecfion Manual Secfion 1.1.3.2 references Section 3.6 of the Manual
for calibration. This section does not exist in the Manual. Section 1.1.3.2 needs to be revised
to include a reference to Secfion 3.3 of the Manual for Area Air Sampler Calibrafion.
• The Radiation Protection Manual requires area air samplers to be calibrated "prior to each
usage." The calibration log sheet indicated that no calibrafions were performed between
January 2, 2010 and June 7, 2010.
Follow-up Items
• The Inspectors observed personnel performing exit monitoring at several restricted area exits.
Exit monitoring among personnel observed was adequate and no deficiencies were noted.
• The Inspectors also observed radiological postings and verified workers wearing their
monitoring badges while inside the restricted area of the Mill. No deficiencies were noted.
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• A previous inspecfion noted that the Mill was using I.O micron filters when performing area
air samples while the Radiation Protection Manual required the use of 0.8 micron filters. The
Mill has since revised the Manual and no longer requires these filters. No deficiencies were
noted.
• A previous inspecfion noted that the BZ field sampling sheets did not include the wearer's
name on the form. The Mill has since developed a form entitled, "BZ's for YC Packagers" to
document this informafion. No deficiencies were noted.
• A previous inspection noted that the Mill had changed the method of storing personnel
monitoring badges but failed to revise the procedure to reflect these changes. The Mill has
since revised the procedure and is consistent with the current method of storing the badges.
No deficiencies were noted.
Closeout Meeting
The closeout meeting was held on Wednesday moming June 9,2010. Present were DRC personnel
John Hultquist and Kevin Carney along with Dave Turk, Rich Bartlett and Ron Nieves of Denison
Mines. The Inspectors discussed the results of the inspection and the findings that were noted. The
deficiencies were discussed and the licensee's responses are noted below.
Conclusions and Recommendations
Item 1. Documentafion of BZ air sampler calibration:
The licensee informed the inspectors that the BZ calibration forms will be updated to include
all information needed to be documented. Prior to the end of the inspection, the Lead
Radiafion Safety Technician developed a form to be used during calibrafion that links the
information together. The DRC recommends that the licensee confinue with this approach
and develop a system whereby every BZ calibration is documented on a separate form that
includes all of the relevant information pertaining to the individual calibrafion. No violafion
is recommended.
Item 2. Procedure discrepancy for BZ air sampler calibrafion:
The Site RSO communicated that this was an oversight and agreed to get the procedure
revised. No violation is recommended.
Item 3. Area air sampler calibration:
The Site RSO stated that he will pursue development of a system for area air samplers
similar to that being developed for the BZ air samplers whereby every calibrafion is
documented on a separate form that includes all of the relevant informafion pertaining to the
individual calibrafion. The Site RSO also stated that he will research the American National
Standards Institute (ANSI) and other standards for guidance on air sampler calibrafion and
documentafion. The DRC will work with the licensee to ensure that these changes are in
accordance with Utah mles and industry standards. No violation is recommended.
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Recommendations for Next Inspection
1. Verify update of BZ and area air sampler calibrafion forms.
2. Verify procedure change: RPM Secfion 1.1.2.4 needs to refer to Secfion 3.2.3.
3. Verify procedure change: RPM Section 1.1.3.2 needs to refer to Secfion 3.3.
Prepared By: Kevin J Camey V^^^g^^g-,:::^_^^ 06/17/2010
(Print Name) / ^Signature) (Date)
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UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-IEM-01 (Rev 1)
INTERNAL/EXTERNAL MONITORING
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTI900479
Inspector(s) Kevin Camey / John Hultgui.st Date(s) 6/8-9/2010
REFERENCES
License Renewal Applicafion dated Febmary 28, 2007, Appendix E, Radiation Protection Manual;
Radioacfive Materials License UT1900479;
NRC Regulatory Guide 8.13;
NRC Regulatory Guide 8.22;
Utah Rules R313-12-3, R313-15-902.
AIR SAMPLING
Radiafion Protection Manual, Secfion 1.1.2, Breathing Zone Sampling,
Secfion 1.1.2.2, Applicabilitv
Breathing zone samples are required:
• for all calciner maintenance activities,
• at least quarterly during routine operating and maintenance tasks on
representative individuals performing these tasks,
• when radiation work permits are issued in which airbome concentrations
may exceed 25% of 10CFR20 limits,
• weekly for yellowcake operations, or
• at the discretion ofthe RSO.
1) Are weekly BZ air samples being conducted for workers performing yellowcake operafions?
YeslEl NoD
Comments: Reviewed records from March/April/May 2010. BZ's for yellowcake workers performed at least
weekly.
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2) Are BZ air samples being taken:
• for all calciner maintenance acfivifies? Yes|^ Nol I
• at least quarterly during roufine operafing and maintenance tasks on representative individuals
performing these tasks? Yes^ NoO
• when radiation work permits are issued in which airbome concentrafions may exceed 25% of
10CFR20 limits? Yes|EI NoD
Comments: Reviewed records from March/April/May 2010. :
Radiation Protecfion Manual. Section 1.1.2.4, Calibrafion
Prior to use, calibration of breathing zone air samplers will be done using the Bubble Tube Calibration method,
described in Section 3.2.1.
(NOTE: The Radiafion Protection Manual has been amended to include the new secfion 3.2.3, "Electronic
Calibrafion Method." Check Section 1.1.2.4 of the RPM to verify that it references this new section for BZ
calibration.)
3) Are calibrafions for BZ air samplers being performed and documented prior to each use?
YesD No|E
Comments: BZ calibrafion is being performed but is documented poorly. There is no way to associate the pump
with the wearer between the "field sheet" and the "lab sheet." However, prior to the end of the inspecfion. the
Mill developed a form to be used during calibrafion that links the informafion together.
4) Are calibrafions for BZ air samplers being performed and documented lAW Secfion 3.2.1 of the Radiafion
Protection Manual?
YesD NoIE
Comments: The Radiation Protection Manual Section 1.1.2.4 does not reference Section 3.2.3. "Electronic
Calibrafion" for BZ calibrafion. The RSO agreed to include the appropriate language.
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Radiation Protection Manual, Section 1.1.3.1. Frequency and Locafions
The following principles used for the collection of area grab samples must be considered when collecting a
sample in order to obtain a representative concentration that workers may be exposed to during their assigned
work tasks.
1. The locations selected for sampling should be representative of exposures to employees working in the area.
2. For special air sampling, the sampling period should represent the conditions during the entire period of
exposure. This may involve sampling during the entire exposure period.
3. For routine sampling, the sampling period must be sufficient to ensure a minimum flow rate of 40 liters per
minute for at least 60 minutes.
4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector.
5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or non-
routine situations.
5) Are area grab samples obtained in areas representative of workers exposure?
Yes^ NoD
Comments: Area samplers are placed as close to workers' locations as possible.
5a) For roufine sampling, did the licensee sample at a minimum flow rate of 40 liters per minute for at least 60
minutes?
YeslEl NoD
Comments: Reviewed records from March/April/May 2010. All area samplers were operated at 40 Ipm for at
least 60 minutes except at the Dump Stafion (area BA28). The sample was taken at 4 1pm for 120 minutes with a
BZ sampler due to the lack of 120v AC electricity. However, the Dump Stafion is no longer considered a
'frequenfiy occupied' area of the Mill.
5b) Were air sample filters analyzed for gross alpha using a sensifive alpha detector?
Yes[3 NoD
Comments: Samples were counted using either a Ludlum 2929 or Ludlum 2200 scaler. Both instmments are
capable of detecfing alpha at an appropriate efficiency.
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RML License Condition 11.4
Annually, the licensee shall collect, during mill operations, a set of air samples covering eight hours of sampling,
at a high collection flow rate (i.e., greater than or equal to 40 liters per minute), in routinely or frequently
occupied areas of the mill. These samples shall be analyzed for gross alpha. In addition, with each change in
mill feed material or at least annually, the licensee shall analyze the mill feed or production product for U-nat,
Th-230, Ra-226, and Pb-210 arid use the analysis results to assess the fundamental constituent composition of air
sample particulates.
6) Did the licensee perform high volume alpha air sampling in routinely or frequently occupied areas of the mill
in accordance with L.C. 11.4?
Yes|^ NoD
Comments: Annual air samples were taken in April 2010 for the current year.
6a) Did the air samples cover eight hours of sampling, at a high collecfion flow rate (i.e., greater than or equal
to 40 liters per minute)?
YeslEl NoD
Comments: All annual area samplers were operated at 40 1pm for at least 480 minutes except at the Dump Stafion
(area BA28). This sample was taken at 4 1pm for 120 minutes with a BZ sampler due to the lack of 120v AC
power in the area. However, the Dump Station is no longer considered a 'frequenfiy occupied' area ofthe Mill.
6b) With each change in mill feed material or at least annually, did the licensee analyze the mill feed or
production product for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess the
fundamental constituent composition of air sample particulates?
YeslXI NoD
Comments: Annual sampling and analysis is performed for all aitemate feed materials that are currently on site.
DAC values used for airbome monitoring are based on the current materials being processed at the Mill.
Radiafion Protecfion Manual, Secfion 1.1.3.2 Sampling Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for one
hour or longer. Equipment utilized will be an Eberline RAS-1, or a Scientific Industries Model H25004, or
equivalent. Filter media will have a maximum of 0.8 micron pore diameter. Equipment is calibrated prior to each
usage as per Section 3.6, {[3] (typo)}, of this manual.
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7) Are calibrafions for area air samplers being performed and documented prior to usage?
YeslEI NoD
Comments: Secfion 1.1.3.2 of the Radiation Protection Manual needs to be updated to include a reference to
section 3.3 of the manual for the calibration procedure. The Mill staff will revise the procedure to reflect this
change.
7a) Is the licensee using air sample filters that have a maximum of 0.8 micron pore diameter?
YesDNolE
Comments: Based on discussions during a previous IEM-01 inspection, the Mill has removed the requirement of
using the 0.8 micron filter. The Mill currently uses a 1.0 micron filter which is appropriate for their sampling
requirements.
8) Are calibrafions for area samplers being performed and documented in accordance with Section 3.3 of this
Manual?
YesD No^*
Comments: The Radiation Protection Manual requires area air samplers to be calibrated 'prior to eaich use.' The
DRC inspectors agree with the RSO that this requirement may be too stringent. The Mill is seeking DRC
recommendafions and will also research ANSI calibrafion and documentation standards for area samplers.
9) Has the licensee provided proper documentation of the results of calibrafion for the following air sampling
equipment?
Air Sampler Low Vol Pump S/N 8915 Yesg] NoD
Air Sampler Low Vol Pump S/N 8862 Yes|3 NoQ
Air Sampler Low Vol Pump S/N 8972 YesIEl NoD
Air Sampler Low Vol Pump S/N 8877 Yes|El NoD
Comments:
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9) Secfion 2.1.2 Frequency/Locations
Has the Licensee performed monthly uranium dust monitoring in the following areas? (Table 2.1.2-1)
Airborne Radiation Sample Locations
BAI Ore Scalehouse YesIEl NoD
BA2 Ore Storage YesIEl NoD
BA7 SAG Mill Area Yes|El NoQ
BA8 Leach Tank Area Yes|El NoD
BA9 Wash Circ CCD Thickness Yes|El NoD
BAIO Sol Ex Bldg/Stripping Sec Yes|3 NoQ
BAI 1 Sol Ex Bldg/Control Room Yes|El NoD
BA12 YC Precip/W Storage Area Yesj^ NoD
BA12A No. YC Dryer Enclosure Yes|EI NoQ
BA12BS0. YC Dryer Enclosure Yes|^ NoD
BAD YC Drying/Pkging Area Yes|El NoD
BA13A YC Pkging Enclosure Yesi^ NoD
BAM PkgdYC Storage Room Yesl^ NoD
BA15 Met Lab Sample Room YesIEl NoD
BA16 Lunch Room Area Yes|^ NoD
BA23 Filter Belt/Rotary Dryer Yes|El NoD
BA17 Change Room
BA18 Administrafive Building
BA19 Warehouse
BA20 Maintenance Shop
BA21 Boiler
BA22 Vanadium Panel
BA22A Vanadium Dryer
BA24 Tails
BA25 Central Control Room
BA26 Shifter's Office
BA27 Operator's Lunch Room
BA28 Dump Stafion
BA29 Filter Press
BA30 Tmck Shop
YeslEl NoD
YeslEl NoD
Yes^ NoD
YeslEl NoD
YesIEl NoD
YesIEl NoD
YeslEI NoD
YeslEI NoD
YeslE] NoD
YesIEl NoD
Yes^ NoD
YeslEI NoD
YeslEl NoD*
YeslEl NoD
Comments: Reviewed records from March/April/May 2010. .
* Filter Press removed from the area and replaced with a generator. A/S locafion is the same. The Mill will revise
the manual to reflect this change.
Air sampling locations have been temporarily added to the list including: BA6 - Sample Plant: BA31 - Women's
Locker Room: BA32 - Oxidafion: BA33A - AF South Pad: BA33B AF North Pad: BA34 - KGL.
10CFR20 Table 1 of Appendix B DAC values for ^^^U retenfion class Y: 2E-1 luCi/ml
Footnote 3 (for ^^^U):
If a mixture of radionuclides consists of uranium and its daughters in ore dust (10 /um AMAD particle distribution
assumed) prior to chemical separation of the uranium from the ore, the following values may be used for the DAC
ofthe mixture: 6E-llpCi of gross alpha activity from uranium-238, uranium-234, thorium-230, and radium-226
per milliliter of air; 3E-llpCi of natural uranium per milliliter of air; or 45 micrograms of natural uranium per
cubic meter of air.
9a) Where any of the air sample results from the above areas found to be in excess of the DAC values listed in
10CFR20 Table 1 of Appendix B?
Yes|3 NoD
Areas idenfified: Area DAC Value Area DAC Value Area DAC Value
BA12A 908% BAM 33.24%
BA12B 613%
BA13A 1871%
Comments: Results are for May 2010.
These areas are posted as Airbome Radioactivity Areas. Respiratory Protecfion Required.
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Utah Rules R313-12-3. Definifions
"Airborne radioactivity area" means: a room, enclosure, or area in which airborne radioactive material exists
in concentrations:
(a) In excess ofthe derived air concentrations (DACs), specified in Ride R313-15, or
(b) To such a degree that an individual present in the area without respiratory protective equipment coidd
exceed, during the hours an individual is present in a week, an intake of 0.6 percent ofthe annual limit on intake
(AU), or 12 DAC hours.
Utah Rules R313-15-902, Posting Requirements
(4) Posting of Airbome Radioactivity Areas. The licensee or registrant shall post each airbome radioactivity
area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, AIRBORNE
RADIOACTIVITY AREA" or "DANGER. AIRBORNE RADIOACTIVITY AREA."
9b) If yes to 9a, were the areas found to be in excess of the DAC values listed in 10CFR20 Table 1 of Appendix B
properly posted?
YeslEl NoD N/A •
Comments: See 9a above.
BIOASSAY PROGRAM
Radiation Protecfion Manual, Section 1.4.1 Frequency
Urinalysis will be performed on those employees that are a) exposed to airbome yellowcake or involved in
maintenance tasks during which yellowcake dust may be produced, or b) routinely exposed to airbome uranium
ore dust. Baseline urinalysis will be performed prior to initial work assignments.
Urine samples are collected on a routine basis from mill employees as required in Regulatory Guide 8.22. Urine
samples will be collected from employees who have worked in yellowcake packaging, yellowcake precipitation,
grind area (SAG Mill), ore feed, sample plant, scale house, and the sample preparation room every two weeks
during production periods. Samples will be collected from all other employees monthly during production
periods. During non-production periods, bi-weekly samples will be collected if individual exposures are expected
to exceed 25% of the DAC value otherwise samples will be collected from all employees quarterly. Non-routine
urinalysis will usually be performed on employees who have been working on assignments that require a
Radiation Work Permit, and always on any individual that may have been exposed to airbome uranium or ore
dust concentrations that exceed 25% of the DAC level
10) Are urine samples being collected from workers who are working under an RWP?
Yesl^NoD
Comments: Several Radiation Work Permits were reviewed and compared to the bioassay list.
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11) Are bi-weekly urine samples being collected from workers in the following areas during production?
Yellowcake Packaging YesQ Nol I
Yellowcake Precipitation YesQ Nol I
Grind Area (SAG Mill) YesD NoQ
Ore Feed YesD NoD
Sample Plant YesD NoD
Scale House YesQ Nol I
Sample Prep Room YesO Nol I
Comments: 16 bi-monthly samples taken in April 2010
9 bi-monthly samples taken in March 2010
0 bi-monthly samples taken in May 2010
1 la) During production periods, are monthly urine samples being collected from all employees working in areas
other than those listed above?
Yes|3 NoD
Comments: Reviewed monthly bioassays for March/April/May 2010.
lib) Are urine samples being collected from Radiation Safety Personnel every two weeks during producfion
periods? (Radiafion Safety Personnel roufinely work in areas listed in #11 above).
Yes|3 NoD
Comments:
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Section 1.4.3 Sample Preparation
Sample preparation will be done in an area decontaminated to less than 25 dpm alpha (removable) per 100 cm^
prior to preparation of samples. All of the equipment that is used in sample preparation will be clean and
maintained in such condition.
12) Are the sample preparation area contaminafion levels maintained below 25dpm/100cm^ •(removable)?
YeslEI NoD
Comments: Had brief discussion with lead Rad Technician on using the Ludlum 3030 and its operafional
capabilities.
EXTERNAL MONITORING
13) Secfion 1.3 Beta-Gamma Surveys
Were all observed personnel wearing a personal monitoring badge while in the Restricted Area?
YesIEl NoD
Comments:
Secfion 1.3.1 Monitoring Procedures
The monitoring procedures consist of:
1. Personnel issued personal monitoring devices will wear the device on the trunk (torso) of the body or visibly
on the exterior of their hard hat. The personal monitoring device records beta/gamma radiation as well as
other forms of penetrating radiation such as x-rays. A personal monitoring device is an exposure record of an
individual's personal exposure to radiation while on the job. Therefore, personal monitoring devices are to
remain at the Mill in the personal possession of each individual, in a locker or other secure area. All exposure
records obtained by a personal monitoring device which are not consistent with the exposure rates of work
tasks or work location measurements made throughout the Mill will be evaluated by the RSO. This evaluation
will result in an investigation by the RSO and a written explanation of the findings. These written records will
be maintained at the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be exchanged by the Radiation
Safety Department. Missing or lost badges will be reported to management.
3. Female employees that become pregnant and continue to work during the course of their pregnancy will be
placed on a monthly personal monitoring device exchange during this period. NRC Regulatory Guide 8.13
provides guidelines to be followed during pregnancy and is made part of this procedure.
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14) Under roufine condifions, were observed employees wearing monitoring badges properly on the torsO?
YeslEI NoD
Comments: Radiafion Protecfion Manual has been revised to reflect the current practice of monitoring badges
wom on the torso only for routine operations and acfivities.
15) Has the licensee assured that personal monitoring devices are being kept at the Mill in the possession ofthe
individual, in a locker or in another secure area?
YeslEl NoD
Comments: As per DRC recommendafion. the Radiation Protection Manual has been revised to reflect the
current procedure for storing monitoring badges on Badge Racks throughout the Mill.
16) Have any female workers declared their pregnancy in the past 2 years?
YesD NoIE
Comments:
16a) If yes to 16 above, has the declared pregnant worker been placed on a monthly personal monitoring device
exchange during this period?
YesD NoD N/A ^
Comments:
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UTAH DIVISION OF RADIATION CONTROL
Inspection Module IEM-01 Rev 1
Denison Mines
White Mesa Mill
Radioacfive Materials License UT1900479
CLOSEOUT MEETING
Inspector(s) Kevin Camey / .Tohn Hultquist
Date(s): fime 10. 2010
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Camey UDRC [e-mail]
John Hultquist UDRC [e-mail]
David Turk
Site RSO Denison Mines [e-mail]
Ron Nieves
Lead Radia,tion Safety Tech Denison Mines [e-mail]
Rich Bartlett
Mill Superintendent Denison Mines [e-mail]
UTAH DIVISION OF RADIATION CONTROL
Inspection Module IEM-01 Rev 1
Denison Mines
White Mesa Mill
Radioacfive Materials License UTI900479
CLOSEOUT MEETING
DISCUSSION of FINDINGS
Several discrepancies were noted and conveyed to the Mill staff. Several procedural deficiencies were noted. Tt
was discussed with the Mill's staff that calihration records for air sampling equipment were less than adequate.
Specifically, air sampler calibrations are noted on a ninning log sheet that only lists minimal information
pertaining to the calibration. Tt was discussed with the Mill's staff that .separate calihration certificates for each
sampler would he more appropriate. No NOVs were issued for this inspection.
SITE STAFF COMMENTS
The Mill's staff tended to agree with the PRC's findings. Prior to the closeout meefing, the Radiafion Safety
Lead Technician presented a draft calihration form for the breathing zone air samplers. This form was
developed during the inspection and presented at the closeout meeting. The staff communicated that they would
look into the ANSI standards for further guidance on air sampler calihration documentation. The staff also
acknowledged the procedural deficiencies noted hy the DRC and agreed to make the necessary changes.
UTAH DIVISION OF RADIATION CONTROL
Inspection Module IEM-01 Rev 1
Denison Mines
White Mesa Mill
Radioacfive Materials License UT1900479
OPENING MEETING
Inspector(s) Kevin Camey / .Tohn Hultgui.st
Date(s): hine9 9010
MEETING MEMBERS
NAME COMPANY CONTACT
INFORMATION
Kevin Camey UDRC [e-mail]
John Hultquist UDRC [e-mail]
David Turk
Site RSO Denison Mines [e-mail]
Ron Nieves
Lead Radiation Safety Tech Denison Mines [e-mail]
Rich Bartlett
Mill Superintendent Denison Mines [e-mail]
UTAH DIVISION OF RADIATION CONTROL
Inspection Module IEM-01 Rev 1
Denison Mines
White Mesa Mill
Radioacfive Materials License UT1900479
OPENING MEETING
DISCUSSION
DRC personnel discussed the .scope ofthe inspection with Denison Mines' White Mesa Mill staff. It was
conveyed to the Mill's staff that we would he reviewing documentation on the Mill's personnel monitoring and
air sampling programs. We also requested to enter the Mill and observe personnel exit monitoring as well as
radiological postings and controls. Other items were discussed including production staUis. facility upgrades
and personnel changes at the Mill. Mr. Ron Nieves was assigned to escort and help the DRC staff in completing
the inspection. ,
performed after repairs or modifications to the meter
orjf the meter, is_b.eliey.e.d_to^have been damaged.
The methods described in Section F of "Air SEtnw]
pling Instruments"^ to calibrate airflow meters arej
acceptable to the NRC staff. J ~
5.3 Uncertainty
The uncenainty in the volume of air sampled
should be less than 20 percent. The uncertainty, Uy.
in percent may be calculated from the equation:
Uv = lUj + + U?]"^
where: U, = the percent uncertainty in reading
the meter scale
Uc = the percent uncertainty in deter-
mining the calibration factor
Ut = the percent uncertainty in the
measurement of the sampling
time.
5.4 Inleakage
Air samplers and associated sampling lines
should be checked for leakage of air into the sam-
pling line upstream of the flow measurement device
when they are calibrated for volume of air sampled.
5.5 Change in Flow Rate
If the flow rate changes by more than ±10 per-
cent during collection of a sample, a correction
should be made by averaging the initial and the final
flow rates.
6. EVALUATION OF SAMPLING RESULTS
6.1 Detecting Changes in Air Concentrations
Over Time
For fixed-location sampling whose purpose is to
confirm confinement of radioactive materials for rou-
tine or repeated operations, the results should either
(1) be analyzed for trends (for example, by control
charts) to determine whether airborne concentrations
are within the normal range and administrative and
engineering controls are thus operadng properly to
maintain occupational doses as low as is reasonably
achievable or (2) be compared with administrative
action levels that serve as a basis for determining
when confinement is satisfactory.
6.2 Efficiency of Collection Media
If the efficiency of the collection media (such as
filters) for an air sample is less than 95 percent for
the material being collected, the sample result should
be corrected to account for radioactive material not
collected by the collection media. If penetration of
radioactive material into the collection media or self-
absorption of radiation by the material collected
would reduce the count rate by more than 5 percent,
a correction factor should be used.
6.3 Detection Sensitivity
The 10 CFR Part 20 monitoring criteria (i.e., 10
percent of the limit) do not establish required levels
of detection sensitivity (lower level of detection, mini-
mum detectable activity, minimum detectable con-
centration, etc.). For example, lapel samplers may
not be able to detect uranium concentradons of 10
percent of the DAC, but lapel samplers are still ac-
ceptable for measuring the uranium intake of work-
ers. The monitoring criteria should not be considered
requirements on the sensitivity of a particular meas-
urement because when the results of multiple meas-
urements are summed, the sum will have a greater
statistical power than the individual measurements.
However, to achieve the greater statistical power, the
licensee should record all numerical values meas-
ured, even values below ."minimum detectable
amounts" and values that are negative because the
measured count rate is below the background. Results
should not be recorded as "below MDA" or similar
Statements.
If the licensee desires to calculate the minimum
detectable activity of a single sample (MDA), it may
be calculated by use of the following equation:
2.71 + 3.29[RbT.(l + T./Tb)]"^
MDA =
EKT.
where: Rb = the background count rate
T, = the sample counting time
Tb = the background (or blank) count-
ing time
E = the filter efficiency
K = a calibration factor to convert
counts per minute into activity
(e.g., counts per minute per mi-
crocurie)
(The derivation of this equation is described in
NUREG-1400.)
If the proportion of the total activity of a sample
that is due to a specific radionuclide in a mixture is
known, the MDA for that radionuclide should be re-
duced proportionally:
MDAi = Ai/A X MDA
^7th Edition, American Conference of GovernmenlalTndus^
trial Hygienists, 1989. Copies are available for purchase from'
the ACGIH, 6500 Glenway Avehiie, Building D-7, Cincin-
nati, Ohio 452n.___: -—
where:
Ai/A = the proportion of the total sample ac-
tivity from radionuclide i.
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5.
Denison Mines (USA) Corp.
White Mesa Mill
Radiation Monitoring
Area Airbome Sampling Location's Field Sheet
Month: Sampled By:
Filter
Id. Location/Description Pump# Date Time On Time Off
Total
Sample
Time in
Minutes
Volume
in
L/Min. Total Volume
1 Scalehouse ?3l%}/o 60 40 2.4 E 6
2 Ore Storage / 60 40 2.4 E 6
6 Sample Plant ( lo:iS 120 4 2.4 E 6
7 SAG Mill \ 60 40 2.4 E 6
8 Leach 60 40 2.4 E 6
9 Co CCD 60 40 2.4 E 6
10 1 SX South / 60 40 2.4 E 6
11 w SX North / 60 40 2.4 E 6
12 s YC Precip 1 60 40 2.4 E 6
I2A North Dryer \ 60 40 2.4 E 6
I2B South Dryer \ Sit OH 60 40 2.4 E 6
BA13 s Pkg Area \ IS:H3 60 40 2.4 E 6
BA13A 7 Pkg Enclosure ) 60 40 2.4 E 6
14 (a Packaged YC Storage Area / IXHD \tHD 60 40 2.4 E 6
15 1 Bucking Room / 60 40 2.4 E 6
16 2 Lunch Rooin 1 60 40 2.4 E 6
17 1 Change Room I 60 40 2.4 E 6
18 I Administration Building \ 60 40 2.4 E 6
19 9- Warehouse \ 3 MIL 60 40 2.4 E 6
20 Maintenance Shop 60 40 2.4 E 6
21 Boiler ) 60 40 2.4 E 6
22 Vanadium Control Panel / 60 40 2.4 E 6
22A Vandium Drying / 11.'O? 60 40 2.4 E 6
23 Vanadium Filter Belt i:io 60 40 2.4 E 6
24 S Tails JO:ll 60 40 2.4 E 6
25 s Central Control Room \ 60 40 2.4 E 6
26 M Shifter's Office \ 60 40 2.4 E 6
27 Operator's Lunchroom \ 60 40 2.4 E 6
28 DumpStation 1/^21 3'.50 120 4 2.4 E 6
29 S / Vl5 60 40 2.4 E 6
30 3 . Truck Shop / E:SO 60 40 2.4 E 6
31 i Womens Locker Room \X%£ 60 40 2.4 E 6
32 St Oxidation iD.'*n 60 40 2.4 E 6
33A South AF Pad 10: S£ 60 40 2.4 E 6
33B North AF Pad f 10: Hi 60 40 2.4 E 6
Denison Mines (USA) Corp.
White Mesa Mill
Radiation Monitoring
Area Airborne Sampling Location's Field Sheet
Month: March-10 Sampled By: Radiation Department
Filter
Id. Location/Description Pump # Date Time On Time Off
lotai
Sample
Time in
Minutes
Volume
in
L/Min. Total Volume
I Scalehouse 8972 3/2/2010 245 345 60 40 2.4 E 6
2 Ore Storage 8972 3/2/2010 923 1023 60 40 2.4 E 6
6 Sample Plant 8972 3/2/2010 918 1018 120 4 2.4 E 6
7 SAG Mill 8972 3/2/2010 732 832 60 40 2.4 E 6
8 Leach 8972 3/2/2010 730 830 120 4 2.4 E 6
9 CCD 8972 3/2/2010 851 951 60 4 2.4 E 6
10 SX South 8972 3/2/2010 218 318 60 40 2.4 E 6
11 SX North 8972 3/2/2010 215 315 60 40 2.4 E 6
12 YC Precip 8972 3/2/2010 845 945 60 40 2.4 E 6
12A North Dryer 8972 3/2/2010 235 335 60 4 2.4 E 6
12B South Dryer 8972 3/2/2010 204 304 60 40 2.4 E 6
BA13 Pkg Area 8972 3/2/2010 1243 1343 60 40 2.4 E 6
BAI 3 A Pkg Enclosure 8972 3/2/2010 240 340 60 40 2.4 E 6
14 Packaged YC Storage Area 8972 3/2/2010 1240 1340 60 40 2.4 E 6
15 Bucking Room 8972 3/2/2010 328 428 60 40 2.4 E 6
16 Lunch Room 8972 3/2/2010 602 702 60 40 2.4 E 6
17 Change Room 8972 3/2/2010 600 700 60 40 2.4 E 6
18 Administration Building 8972 3/2/2010 555 655 60 40 2.4 E 6
19 Warehouse 8972 3/2/2010 342 442 60 40 2.4 E 6
20 Maintenance Shop 8972 3/2/2010 345 445 60 40 2.4 E 6
21 Boiler 8972 3/2/2010 855 955 60 40 2.4 E 6
.. 22 Vanadium Control Panel 8972 3/2/2010 1245 1345 120 4 2.4 E 6
22A Vandium Drying 8972 3/2/2010 1108 1208 60 40 2.4 E 6
23 Vanadium Filter Belt 8972 3/2/2010 1310 1410 120 4 2.4 E 6
24 Tails 8972 3/2/2010 911 1011 60 40 2.4 E 6
25 Central Control Room 8972 3/2/2010 846 946 60 40 2.4 E 6
26 Shifter's Office 8972 3/2/2010 736 836 60 40 2.4 E 6
27 Operator's Lunchroom 8972 3/2/2010 735 835 60 40 2.4 E 6
28 Dump Station 8972 3/2/2010 1250 1350 120 4 2.4 E 6
29 Emergency Generator Station 8972 3/2/2010 1215 1315 60 40 2.4 E 6
30 Truck Shop 8972 3/2/2010 850 950 60 40 2.4 E 6
31 Women's Locker Room 8972 3/2/2010 1235 1335 60 40 2.4 E 6
32 Oxidation 8972 3/2/2010 1047 1147 60 40 2.4 E 6
33A South AF Pad 8972 3/2/2010 1055 1155 60 40 2.4 E 6
Denison Mines (USA) Corp.
White Mesa Mill
Radiation Monitoring
Area Airborne Sampling Location's Field Sheet
Month: April-10 Sampled By: Radiation Department
Filter
Id. Location/Pescription Pump # Date Time On Time Off
Total
Sample
Time in
Minutes
Volume
in
L/Min. Total Volume
1 Scalehouse 8869 4/5/2001 1845 245 60 40 2.4 E 6
2 Ore Storage 8869 4/5/2001 600 1400 60 40 2.4 E 6
6 Sample Plant 8915 4/5/2001 605 1405 120 4 2.4 E 6
7 SAG Mill 8972 4/5/2001 643 1443 60 40 2.4 E 6
8 Leach 8869 4/5/2001 710 1510 120 4 2.4 E 6
9 CCD 8915 4/5/2001 715 1515 60 4 2.4 E 6
10 SX South 8369 4/5/2001 600 1400 60 40 2.4 E 6
11 SX North 8869 4/5/2001 600 1400 60 40 2.4 E 6
12 YC Precip 8915 4/5/2001 720 1520 60 40 2.4 E 6
12A North Dryer 8972 4/5/2001 735 1535 60 4 2.4 E 6
12B South Dryer 8869 4/5/2001 730 1530 60 40 2.4 E 6
BA13 Pkg Area 8915 4/5/2001 745 1535 60 40 2.4 E 6
BA13A Pkg Enclosure 8869 4/5/2001 740 1540 60 40 2.4 E 6
14 Packaged YC Storage Area 8869 4/5/2001 725 1525 60 40 2.4 E 6
15 Bucking Room 8915 4/5/2001 1835 235 60 40 2.4 E 6
16 LunchRoom 8972 4/5/2001 607 1407 60 40 2.4^6
17 Change Room 8869 4/5/2001 617 1417 60 40 2.4E6
18 Administration Building 8915 4/5/2001 1830 230 60 40 2.4 E 6
19 Warehouse 8869 4/5/2001 605 1504 60 40 2.4 E 6
20 Maintenance Shop 8869 4/5/2001 1840 240 60 40 2.4 E 6
21 Boiler 8915 4/5/2001 730 1530 60 40 2.4 E 6
22 Vanadium Control Panel 8972 4/5/2001 930 1730 120 4 2.4 E 6
22A Vandium Drying 8869 4/5/2001 930 1730 60 40 2.4 E 6
23 Vanadium Filter Belt 8915 4/5/2001 930 1730 120 4 2.4 E 6
24 Tails 8869 4/5/2001 740 1530 60 40 2.4 E 6
25 Central Control Room 8869 4/5/2001 600 1400 60 40 2.4 E 6
26 Shifter's Office 8915 4/5/2001 659 1459 60 40 2.4 E 6
27 Operator's Lundiroom 8972 4/5/2001 657 1457 60 40 2.4 E 6
28 Dump Station 8869 4/5/2001 800 1000 120 4 2.4 E 6
29 Emergency Generator Station 8915 4/5/2001 720 1520 60 40 2.4 E 6
30 Truck Shop 8869 4/5/2001 620 1420 60 40 2.4 E 6
31 Women's Locker Room 8877 4/5/2001 615 1415 60 40 2.4 E 6
32 Oxidation 8915 4/5/2001 730 1530 60 40 2.4 E 6
33A South AF Pad 8915 4/5/2001 730 1530 60 40 2.4 E 6
Demnsoffii Mames (USA) Corp.
White Mesa Mil!
Area Airborme Sampling Location'
Sampled By:
s Field Sheet
Radiation pepartment
Location/Description Pump # Date Time On Time Off
TOtar
Sample
Time in
Minutes
Volume
in
L/Min. Total Volume
Scalehouse 1 W-s-40 --2:4-5.6
Ore Storage 40 2.4 06
Sample Plant v2:4E6
SAG Mill Wm mi 40 2.4 E 6
V^2.4E6 Leach '4'^0
CCD 2.4-E6
10 SX South H/6//0
ML
40 2.4 Efi
11 SX North 1 tioi^'*' 40 2.4,E6
12
12A
12B
YC, Precip
North Dryer
Soiith Dryer
Pkg Area
Pkg Enclosure ^7^ ' "
111
T-:HO
40
3 -4-T/£)
40
40
40
^•4E6
2.4 E 6
2.4 E 6
2.4 E 6
.Z4£6
14 Packaged YC Storage Area T. 2< 40 2.4 E 6
15 BuckitigRbpm MM 40 2.4 E6 \
16 Lunch Room eo 40 2.4 E 6
17 . Chajige Room 40 2.4 E 6
18 Administra:tion Building L£i2. 40 2.4 Z 6
19 Warehouse 40 2;4J6
20 Mainteinance Shop HrlrfO 40 :2.4 E 6
21 Boiler; 40 (2.4E6
22 Variadiuhi Control Panel \2.4E6
:22A Vandium Drying 40 2.4 E 6
23 Vanadium Filter Belt 6 •.'ho 120 2.4 E 6
24 Tails M2d 7: HO 40 2.4 E 6
25 Ceiitral Control Room 3,; OO'Af 40 2.4iE 6
26 Shifter^s Office 40 ;2:4E6
27 Operator's Lunchroom 40 2,4 E 6
28 Dimip Station iO'.Od 2.4 E 6
29 Emergency Generator Station 40 2.4E6
30 Truck Shop •lirrlio 40 2.4 E 6\
31 Women's Locker Room / ST 40 2.4 E 6/
32 Oxidation 40 2.4 E &
33A South AF Pad 4-1-t^ 40 2.4 E 6
33B
34
North AF Pad
KGL
M->|0
H-?-ib Vy(t
40
40
2.4 E 6
2i4E6
Denison Mines (USA) Corp.
White Mesa Mill
Radiation Monitoring
Area Airborne Sampling Location's Field Sheet
Month: May-10 Sampled By: Radiation Department
Filter
Id. Location/Description Pump# Date Time On Time Off
Total
Sample
Time in
Minutes
Volume
in
L/Min. Total Volume
1 Scalehouse 8972 5/7/2010 1002 1102 60 40 2.4 E 6
1 Ore Storage 8972 5/7/2010 857 957 60 40 2.4 E 6
6 Sample Plant 8869 5/7/2010 859 959 120 40 2.4 E 6
7 SAG Mill 8972 5/7/2010 917 1017 60 40 2.4 E 6
8 Leach 8869 5/7/2010 1303 1403 120 40 2.4 E 6
9 CCD 8869 5/7/2010 911 1011 60 40 2.4 E 6
10 SX South 8869 5/7/2010 1409 1509 60 40 2.4 E 6
11 SX North 8972 5/7/2010 1407 1507 60 40 2.4 E 6
12 YC Precip 8972 5/7/2010 1300 1400 60 40 2.4 E 6
12A North Dryer 8972 5/7/2010 1230 1330 60 40 2.4 E 6
12B South Dryer 8972 5/7/2010 835 935 60 40 2.4 E 6
BA13 Pkg Area 8869 5/7/2010 1226 1326 60 40 2.4 E 6
BA13A Pkg Enclosure 8972 5/7/2010 1335 1435 60 40 2.4 E 6
14 Packaged YC Storage Area 8869 5/7/2010 1336 1436 60 40 2.4 E 6
15 Bucking Room 8972 5/7/2010 940 1040 60 40 2.4 E 6
16 Lunch Room 8972 5/7/2010 933 1033 60 40 2.4 E 6
17 Change Room 8972 5/7/2010 1010 1110 60 40 2.4 E 6
18 Administration Building 8972 5/7/2010 741 841 60 40 2.4 E 6
19 Warehouse 8869 5/7/2010 1109 1209 60 40 2.4 E 6
20 Maintenance Shop 8972 5/7/2010 1115 1215 60 40 2.4 E 6
21 Boiler 8869 5/7/2010 1426 1526 60 40 2.4 E 6
22 Vanadium Control Panel 8869 5/7/2010 1003 1103 120 4 2.4 E 6
22A Vandium Drying 8869 5/7/2010 1115 1215 60 40 2.4 E 6
23 Vanadium Filter Belt 8972 5/7/2010 958 1058 120 4 2.4 E 6
24 Tails 8972 5/7/2010 1057 1157 60 40 2.4 E 6
25 Central Control Room 8972 5/7/2010 756 856 60 40 2.4 E 6
26 Shifter's Office 8972 5/7/2010 1030 1130 60 40 2.4 E 6
27 Operator's Lunchroom 8869 5/7/2010 841 941 60 40 2.4 E 6
28 Dump Station 8972 5/7/2010 1600 1800 120 4 2.4 E 6
29 Emergency Generator Station 8869 5/7/2010 1040 1140 60 40 2.4 E 6
30 Truck Shop 8972 5/7/2010 1045 1145 60 40 2.4 E 6
31 Women's Locker Room 8972 5/7/2010 732 832 60 40 2.4 E 6
32 Oxidation 8972 5/7/2010 1358 1458 60 40 2.4 E 6
33A South AF Pad 8869 5/7/2010 1323 1423 60 40 2.4 E 6
1.1 •
Denssom Mimes (US A) Corp.
White Mesa IWill
Radiation Monitoring
: Moiith: Sam )led By: Radiation Department
Filter
Id.
-1-.—:. 1.
Location/Description Pump# Date T ime On Time Off
Ibtal
Sample
Time in-
Minutes
Volume
in
L/Min. Total Volume
1 J Scalehouse U 60 40 2.4 E 6
f^tffc fJwirOre Storage 60 40 . 2.4 E 6
6 0 A^'t/lH 120 • 4 2.4 E 6
7 _ . ' ' SAG Mill "1 /^.' 77 60 40 2.4 E 6
^8' ^ 7. 120 4 2.4 E 6 •
> 9 ini pr Vuv^^XCD ' 60 2.4 E 6 •;.
10 M*^Ci;,ti\^ SX South, 60 40 2.4 E 6
11 . • SX North /7 •»j—>^ 1
7'. :i -7 60 40 2.4 E 6
" 12 , T^^k tCR YC Precip
/•
60 40 2 4E'6
- 12A ' North Dryer 7 /r?r7i 60 4 . 24E6
12B • South Dryer ; 60 40 , 24E6
"BAI 3. Pkg Area I'lG • 60 40 2'.4E6 "
BA13A - ' ^ Pkg Enclosure :^ 60 40 \ 2 4B6 ^
-14 , , - Packaged YC Storage Area r- i- IC? /; 60 40 - .2.4 E,6 .
: '^5' \ £«ri>cibr Bucking Roora^j^. /n/v,,n 60 40 . 2 4E-6,
'16 . Lunch Roofh / '"C 10 60 40 " ' 2.4 E 6 ;
17 ' T '; Change Room s // ^ /^;/t?^>t li-fO 60 40 2 4E.6
18 S i Adniinistration Building s:? / 60 40 -.^ 2 4:E6
19' ' , ^ • Warehouse / mm • ' f— 60 40 / fv 2 4E'6
;''20 ' • •f' : ^ Maintenance Shop / ll 1 Sr 60 ' 40 24E6
W21, iJo'j'i.iii, Sy Boiler (Jf^i-f-: 60 40 2 4 E 6
. 22^ Vanadium Control Panel 7. S'll^U\ .120 4 , 2 4&6
--22A • VandiumDrying mpL T 60 40 • 2 4 E 6
23 ' ': • : Vanadium -FilterBelt 120 4 4 2.4E'6.r
24 hix^'^ uv^ Tails isi t ^v • 60 40 ^ . <:'2:4.E6 : :
25 ^Central Control.Room 60 40 , 2.4 E 6 '
26 J:<S«T S^Ufc Shifter's Office taOM 60 40 . 2.4 E:6 •*
27 IfiB < 1 ^Operator's Lunchroom S «W f^^lh i\if1 ^:«'/ . 60 40 2.4 E 6
28 --•fCW"^ DumpStation U : : 120 4 • 2.4E6 >
29 jff Emergency Generator Station Jag 60 40^ - 2.4 E 6
30 Truck Shop l<> /. VC^^ 60 ~ - 40 ' 2.4 E 6
31 Women's Locker Room 60 40> 2.'4 E 6
32 Rf^i'/ 7-ci.vvJC.Oxidation I'KV 60 40 2.4 E 6
33A South AF Pad 60 ; 40 2.4 E 6
33B : ^i^^ North AF Pad 60 40 ' 2.4 E 6- '
34 : ; KGL ; 60 40 . . 2.4 E 6.
• ••" ^' / / ! /
/